1. Introduction/Scope

This document is prepared in accordance with the provisions of the Nigeria Data Protection Act (NDPA), and by extension, the EU General Data Protection Regulation (GDPR). It sets out how Bridge Credit Limited (BCL) applies and complies with the principles of the Act in processing the personal data of individuals, clients, vendors, and even third parties that interact with BCL. For personal data of individuals, this document also highlights their rights and covers the data subject(s) whose personal data is collected and processed in compliance with the GDPR/NDPR.

2. Roles and Responsibilities

3. Policy Statement.

Bridge Credit Limited (BCL) is committed to protecting the privacy and security of our personal data. We are responsible for determining how we hold and use personal information about our data subjects. According to the Nigeria Data Protection Act (NDPA), BCL is required to notify data subjects of the information contained in this document.

3.1 Who We Are.

Bridge Credit Limited is a leading consumer credit company established to offer Nigerians easy access to loans to meet personal financial obligations and improve their living standards.
At BCL, we are focused on improving living standards through innovative financial services, and our vision is to be the best customer-celebrated financial services company in Africa.
Our strength, performance and continuous existence are drawn from our core values (EPIC).

Empathy: We understand and share the feelings of our customers.

Professionalism: We maintain high ethical standards, competence and efficiency in all transactions.

Integrity: You can trust us as we are transparent and always keep to our word.

Commitment: We are dedicated to service that delights our stakeholders. Collectively, these values drive our approach to doing business, how we build enduring relationships with our customers and how our team relates with both internal and external stakeholders.

3.2 What Personal Data Do We Need?

The personal data we would collect and process, depending on the particular processing requirement, are under the following categories:

3.3 Why Do We Need the Data?

BCL ensures that the personal data collected and processed is necessary for the purpose of collection, and BCL shall not collect or process more data than is reasonably required for a particular processing activity. In addition, every processing purpose has at least one lawful basis for processing to safeguard the rights of the data subjects, as listed below:

• Consent obtained from the data subject
• Performance of a contract where the data subject is a party
• Legal obligation that the BCL is required to meet
• Protection of vital interests of the data subject, including the protection of rights and freedom of the data subject
• Official authority of BCL, or to carry out the processing that is in the public interest
• National law, such as biometric data.

Consequently, BCL uses the following lawful grounds for processing of personal data, as listed below;

4. Processing of Personal Data Based on Consent

Where applicable, BCL will require explicit consent of customers, visitors and other relevant stakeholders to process collected personal data.

Visitors to the BCL’s website are expected to read, understand and agree to the privacy policy and website’s terms of use.

BCL requires your explicit consent to process collected personal data. And by consenting to this privacy policy, you are permitting us to use/process your personal data specifically for the purpose identified before collection.

It should be noted that while processing, there may be a need to share personal data with service providers for services in line with the customer’s service subscription from time to time and accredited third parties or agencies in accordance with the Nigeria Data Protection Act 2023 If, for any reason, BCL is requesting sensitive personal data from you, you will be rightly notified why and how the information will be used.

You may withdraw consent at any time by requesting for Withdrawal of Consent form, following the BCL Withdrawal of Consent Procedure.

5. Disclosure to Third Parties and Cross-Border Transfer.

BCL will not pass on your personal data to third parties without first obtaining your consent. In a case where the disclosure is to third parties outside the jurisdiction of the GDPR and NDPR, BCL will ensure that the third party meets the core regulatory standards prior to the transfer. This may include transferring the personal data to a third party where BCL has satisfied that:

• - The country of the recipient has adequate data protection controls established by a legal or self- regulatory regime
• - BCL has a contract in place that uses existing or approved data protection clauses to ensure adequate protection
• - BCL is making the transfer under approved binding corporate rules
• - BCL is relying on approved codes of conduct or certification mechanisms, together with binding and enforceable commitments in the foreign country or international organisation to apply the appropriate safeguards in relation to data subject rights
• - Provisions inserted into administrative arrangements between public authorities or bodies authorised by the competent supervisory authority

6. Retention of Records

In compliance with the GDPR/NDPA data retention policy, BCL will process your personal data for [state how long you intend to process the personal data of data subject(s)] and will retain the personal data for [state the retention period of the personal data of data subject(s)].

This retention period has been established to enable us to use the personal data for the necessary legitimate purposes identified, in full compliance with the legal and regulatory requirements. When we no longer need to use your personal information, we will delete it from our systems and records, and/or take steps to encrypt/anonymise it to protect your identity as the case may be.

7. Data Subject Rights

Data subjects, according to the provision of the GDPR/NDPA, have certain rights. At any point while BCL are in possession of or processing your personal data, you, the data subject, have the right to:

• - Request a copy of the information that we hold about you
• - Correct the data that we hold about you that is inaccurate or incomplete
• - Ask for the data we hold about you to be erased from our systems/record
• - Restrict processing of your personal data where certain conditions apply
• - Have the data we hold about you transferred to another organisation
• - Object to certain types of processing like direct marketing
• - Object to automated processing like profiling, as well as the right to be subject to the legal effects of automated processing or profiling
• - Judicial review. In the event that BCL refuses your request under rights of access, we will provide you with a reason as to why.
• -Right to lodge a complaint to the supervisory authority on info@ndpc.gov.ng

All of the above requests will be forwarded on should there be a third party involved in the processing of your personal data.

Data Subjects can exercise their rights in writing directly to the DPO on ocaleb@bridgecredit.com.ng

8. Complaints

To file a complaint about how your data is handled, contact:

• Supervisory Authority (Nigeria Data Protection Commission – NDPC) dpo@ndpc.gov.ng or info@ndpc.gov.ng
• Data Protection Officer (DPO) ocaleb@bridgecredit.com.ng