1. About Unloc

Unloc is a digital lending platform operated by Ricchezza Capital Limited that provides eligible users with access to loan products and related financial services.

2. Information We Collect

We may collect and process the following categories of personal information:

3. How We Collect Information

• Information provided directly by users during registration and loan application processes.
• Identity verification and KYC processes.
• Information generated through the use of the application.
• Authorized third-party service providers.
• Credit bureaus and verification agencies.
• Regulatory and publicly available sources where permitted by law.

4. Purposes of Processing

• Creating and managing user accounts.
• Processing loan applications.
• Conducting identity verification and Know Your Customer (KYC) checks.
• Assessing creditworthiness and eligibility.
• Making lending decisions.
• Disbursing approved loans.
• Processing repayments.
• Preventing fraud, money laundering, and financial crimes.
• Communicating with users regarding their accounts and loans.
• Improving our products and services.
• Complying with legal and regulatory obligations.
• Managing disputes and enforcing contractual rights.

5. Automated Decision-Making

Unloc uses an automated Decision Engine (DE) to support the assessment of loan applications.

The automated assessment may consider information including:

• Identity verification results.
• Credit bureau information.
• Financial information.
• Repayment history.
• Risk assessment indicators.
• Other information relevant to credit evaluation.

Automated assessments assist in determining eligibility and loan terms. Where applicable, users may contact us for additional information regarding decisions made using automated processing.

6. Lawful Bases for Processing

• Consent provided by the user.
• Performance of a contract.
• Compliance with legal and regulatory obligations.
• Protection of vital interests.
• Legitimate business interests.
• Public interest obligations where applicable.

7. Permissions Used by the Application

8. Identity Verification and KYC

To comply with regulatory requirements and combat fraud, Unloc performs identity verification and Know Your Customer (KYC) checks.

Verification may include:

• BVN verification.
• NIN verification.
• Address verification.
• Identity document validation.

These services may be performed by authorized third-party providers, including DeKript and other approved verification partners.

9. Sharing of Personal Information

We do not sell personal information to third parties.

10. Cross-Border Transfers

Where personal information is transferred outside Nigeria, Ricchezza Capital Limited will ensure that appropriate safeguards are implemented in accordance with applicable data protection laws and regulatory requirements.

11. Data Retention

We retain personal information only for as long as necessary to:

• Provide our services.
• Comply with legal and regulatory obligations.
• Resolve disputes.
• Enforce agreements.
• Protect our legitimate business interests.

Personal data may be retained after account closure where required by law, regulation, audit, risk management, fraud prevention, or record-keeping obligations.

When personal data is no longer required, it will be securely deleted, anonymized, or archived in accordance with applicable laws.

12. Data Security

Ricchezza Capital Limited implements appropriate technical, administrative, and organizational safeguards to protect personal information against:

• Unauthorized access.
• Unauthorized disclosure.
• Loss or destruction.
• Misuse.
• Alteration.
• Accidental damage.

Security measures include encryption, access controls, monitoring systems, secure infrastructure, and periodic security reviews.

13. Your Rights

Subject to applicable laws, users may exercise the following rights:

• Right to access personal information.
• Right to request correction of inaccurate information.
• Right to request deletion of personal information where legally permissible.
• Right to restrict processing.
• Right to object to certain processing activities.
• Right to data portability.
• Right to withdraw consent where consent is the lawful basis for processing.
• Right to lodge a complaint with the Nigeria Data Protection Commission (NDPC).

14. Children's Privacy

Unloc is intended only for individuals who are legally eligible to enter into financial agreements.

We do not knowingly collect personal information from children or minors.

15. Changes to this Privacy Policy

We may update this Privacy Policy from time to time.

Any changes will be published on our website and within the application. Continued use of Unloc following publication of an updated Privacy Policy constitutes acceptance of the updated terms.

16. Contact Us

If you have any questions, requests, complaints, or concerns regarding this Privacy Policy or the processing of your personal information, please contact:

Users also have the right to lodge complaints with the Nigeria Data Protection Commission.