PRIVACY POLICY

Effective Date: March 30, 2026

1. Scope and Application

1.1 LUMORA EDGE LTD (“FTcredit”) is a duly registered Digital Money Lender operating in Nigeria under authorization from the Federal Competition and Consumer Protection Commission (FCCPC). As the data controller, FTcredit determines how and why personal information is collected when you install, access, or use our mobile application or any of our official service channels.

1.2 In specific situations, FTcredit may process personal data on behalf of another entity (data controller) where you maintain a direct relationship with that party. In such instances, processing will strictly follow their documented instructions.

1.3 If you have any inquiries regarding this Privacy Policy or how your data is handled, you may contact us via lumoratide@lumoraedgeltdng.com.

1.4 This Policy explains how your personal data is managed in accordance with the National Information Technology Development Agency Act (2007) and the Nigeria Data Protection Act (2023). By using FTcredit, you acknowledge that you have read, understood, and agreed to the practices described herein.

1.5 FTcredit does not offer services to individuals below the age of eighteen (18), and we do not knowingly collect data from minors.

2. Key Definitions

2.1 “Privacy Policy” refers to this document outlining how FTcredit collects, uses, and safeguards personal data.

2.2 “Platform” means any system through which FTcredit delivers services, including its mobile app and website.

2.3 “Minor” refers to any individual under the age of 18.

2.4 “Consent” means a clear, informed, and voluntary indication of agreement to data processing.

2.5 “User” or “Customer” refers to any individual accessing FTcredit services within Nigeria.

2.6 “Personal Data” means any information that can identify an individual directly or indirectly.

2.7 “Sensitive Data” includes data such as religion, health information, biometric identifiers, ethnicity, or similar protected categories.

2.8 “Services” refers to financial and related products provided by FTcredit.

2.9 “We,” “Us,” or “Our” refers to LUMORA EDGE LTD (FTcredit).

2.10 “You” refers to the individual using our services.

3. Consent and User Authorization

3.1 By installing and using the FTcredit application and accepting required permissions, you:

4. Information We Collect

4.1 Categories of Data

Approximate Location
With your approval, FTcredit may access general location data to confirm jurisdiction, support regulatory compliance, and mitigate fraud risks. Precise GPS tracking is not performed, and location data is not used for advertising.

Identity Information
This may include your name, date of birth, gender, religion, and official identification details for identity verification and compliance purposes.

Profile Information
Details such as employment status, income range, education level, marital status, and survey responses may be collected to assess eligibility and enhance service personalization.

Financial Information
We may obtain banking details including account number, bank name, and BVN to facilitate transactions, assess repayment capability, and comply with AML/CTF obligations.

Camera Access
With your consent, the camera may be used for identity verification processes such as facial recognition or document capture. It is never activated without your knowledge or in the background.

Emergency Contact Information
Limited contact details (name, relationship, phone number) may be collected strictly for verification or emergency purposes. Full contact lists are not accessed.

Device Information
Technical data such as device type, operating system, IP address, mobile network, IDFA, and IDFV may be collected to improve performance and strengthen security.

Advertising Identifier (IDFA)
Only collected upon your explicit permission via Apple’s tracking prompt. It is used exclusively for internal optimization and fraud prevention—not for third-party advertising.

Usage Information
We may log user activity, authentication details (including OTPs), and interactions within the app to maintain system integrity and improve functionality.

Third-Party Information
Data may be received from credit bureaus, verification providers, and business partners to validate identity, assess risk, and prevent fraud.

4.2 Additional Data

We may collect supplementary data as disclosed at the point of collection.

4.3 Data Sources

- Directly from you (forms, app usage, communication)
- From your device (via granted permissions)
- From third parties and public databases (credit agencies, financial partners, verification providers)

4.4 Purpose of Processing

Your information is used to:
- Deliver financial services
- Meet regulatory requirements
- Improve product performance
- Prevent fraudulent activities

We do not process personal data beyond these purposes without consent unless required by law.

4.5 Failure to Provide Data

Failure to provide required information may result in inability to access certain services.

4.6 Data Transmission

Data collected through FTcredit is securely encrypted and transmitted via:
https://api.lumoraedgeltdng.com
No data is transmitted when the app is inactive.

4.7 Confidentiality Commitment

We do not sell, publicly disclose, or misuse your personal data beyond the purposes stated in this Policy.

5. Legal Grounds for Processing

We process your data based on:
- Your consent
- Contractual necessity
- Legal obligations
- Legitimate business interests (e.g., fraud prevention)

6. Automated Decision-Making

FTcredit may use automated systems for:
- Credit assessment
- Risk evaluation
- Fraud detection

These systems rely on algorithmic analysis and may determine eligibility, loan limits, or restrictions without manual review.

6.1 Your Rights

You may request human review of automated decisions by contacting:
lumoratide@lumoraedgeltdng.com

7. Data Sharing

Your information may be shared with:
- Credit bureaus
- Regulatory authorities
- Service providers (e.g., verification, collections)
- Business partners and affiliates
- Legal advisors and courts

In case of business restructuring, data may be transferred to successor entities under the same protections.

8. Cross-Border Transfers

Your data may be processed outside Nigeria using secure infrastructure. Equivalent protection standards are applied across all jurisdictions.

9. Data Security

We implement industry-standard safeguards to protect your data.

You are responsible for safeguarding your login credentials. FTcredit will never request your password or OTP.

In case of a data breach, we will notify users and regulators where required.

10. Data Retention

We retain data:
- As long as necessary for service delivery
- For at least 5 years to comply with AML/CTF laws
- As required for legal claims

Data no longer needed will be securely deleted or anonymized.

11. Your Rights

You have the right to:
- Access your data
- Correct inaccuracies
- Request deletion (subject to legal limits)
- Object to processing
- Request data portability
- Restrict processing under certain conditions

Requests can be made via:
lumoratide@lumoraedgeltdng.com

12. Policy Updates

We may revise this Policy periodically. Updates will be communicated through the app, website, or other official channels.

13. Contact Details

Company: LUMORA EDGE LTD
Address: 33, Shola Martins Street, New Oko Oba Abule Egba Bus Stop, Off Abeokuta Expressway, Lagos State, Nigeria
Phone: +234 9160378737
Email: lumoratide@lumoraedgeltdng.com