Privacy Policy & Data Protection

Data Protection Principles

Capitalwise Dynamic Pay Ltd (“Capitalwise”, “we”, “us”, or “our”) is committed to maintaining the highest standards of data privacy, confidentiality, and security. In accordance with the Nigeria Data Protection Act (NDPA 2023), all personal data is processed lawfully, fairly, transparently, and solely for specified, explicit, and legitimate financial service purposes.

Information We Collect

To operate NGN wallets, investment arrangements, loan applications, and business accounts, we collect and process the following categories of data:

• Personal identifying information. Full legal name, date of birth, residential address, email address, primary phone number, and passport photograph.
• Government-issued identifiers. Bank Verification Number (BVN), National Identification Number (NIN), Tax Identification Number (TIN), or CAC registration documents.
• Financial and transaction records. Wallet transaction history, funding and payout records, 6 to 12 months of bank statements, credit history reports, and debt service ratios.
• Technical and device data. IP address, browser type, operating system details, mobile app device ID, geolocation data, and access timestamp logs.

Purposes & Lawful Basis

We process your personal information strictly under the following lawful bases:

• Contract performance. To open your wallet, process money transfers, and assess, disburse and collect the loan facilities you request.
• Regulatory and legal obligations. To fulfil Anti-Money Laundering (AML) checks, Know-Your-Customer (KYC) verification tiers, and reporting obligations to the relevant Nigerian authorities.
• Legitimate interests. Underwriting credit applications, scoring borrower risk profiles, fraud prevention, and system security monitoring.

Credit Bureau Reporting

By applying for any Capitalwise loan product (Business Loan, LPO Financing, Salary Advance, Asset, Auto or Renewable Credit) or by acting as a Portfolio Manager, you consent to the retrieval of your credit history from licensed credit bureaus including CRC Credit Bureau, CreditRegistry, and FirstCentral Credit Bureau. We also report loan performance data, including overdue repayments, to licensed bureaus in accordance with Nigerian credit reporting regulations.

Security & Encryption Standards

Capitalwise enforces enterprise-grade security protocols to prevent unauthorised access, data alteration, disclosure, or destruction.

Your Data Rights

Under the Nigeria Data Protection Act (NDPA), you hold statutory rights regarding your personal information:

• Right of access. Request a copy of all personal records held by Capitalwise.
• Right to rectification. Request correction of inaccurate identity or financial records.
• Right to object. Opt out of non-essential promotional communication at any time.
• Right to erasure. Request data deletion, subject to mandatory financial record-keeping laws.

Data Protection Officer

For any data protection enquiries, privacy rights requests, or compliance questions, please contact our Data Protection Officer.