Privacy Policy

Introduction

Indulge Microﬁnance Bank Limited, also known as Indulge, is a registered company with the Corporate Affairs Commission (CAC) and licensed by the Central Bank of Nigeria (CBN).

Our Privacy Policy outlines the ways in which we collect, utilize, and share your information while you use our services. It also informs you of your privacy rights and how legal protection applies to you. If you disagree with our policies and practices, you have the option to not use our Service. Please note that this policy may be subject to updates and changes (as stated in section, ‘Changes to this Privacy Policy’).

By accessing or utilizing the Service, you are consenting to the collection and utilization of your Personal data to enhance and provide the Service in accordance with our Privacy Policy.

Meaning and Clarification of Terms Used

An “Account” is a unique account created for the user to access the company’s service or certain parts of it.
An “Application” is the software program provided by the company that the user can download onto an electronic device, called Indulge Website, Indulge Internet Banking, Indulge Mobile Banking App, Indulge USSD etc.
The “Company” (referred to as “the Company”, “We”, “Us”, or “Our” in this Agreement) is Indulge, located at 56, Opebi Road, Ikeja Lagos.
“Cookies” are small ﬁles placed on the user’s computer, mobile device, or other device by a website, which contain information about the user’s browsing history on that website and have multiple uses.
“Country” refers to Nigeria only.
A “Device” is any gadget that can access the service, such as a computer, smart phone, or electronic tablet.
“Personal Data” is any information related to an identiﬁed or identiﬁable person or Individual.
The term “Service” refers to either the Mobile Banking Applications or the Website, or both.
A “Service Provider” is any individual or legal entity who collects and processes information for the company, including third-party ﬁrms or persons hired by the company to enable the service, offer the service on the company’s behalf, execute activities relating to the service, or assist the company in assessing how the service is being used.
A “Third-party Social Media Service” is any website or social network website that allows users to log in or establish an account in order to utilize the service.
“Usage Data” refers to information gathered automatically, either via the usage of the service or from its infrastructure, such as the length of a page visit.
Our “Website” is Indulge, which may be found at https://www.indulgemfb.com.
‘You’ refers to the person reaching or using the Service, or the corporation or other legal entity on whose behalf such person is obtaining or employing the Service, as available.

Personal Data

When You use Our Service, We may ask You for particular personal information that can be used to contact or identify You. This may include: Email address, name, phone number, address, usage data, bank veriﬁcation number, national identity number, picture, date of birth, and image of a government-issued identiﬁcation document (Voters Card, Nigerian Passport, NIN, Driver’s License).

Usage Data

When you use our service, we automatically collect usage data. This data may include information such as your device’s IP address, browser type and version, pages visited on our service, date and time of visit, time spent on those pages, unique device identifiers and other diagnostic information.

If you access our service through a mobile device, we may also collect information such as the type of mobile device used, mobile device unique ID, IP address, mobile operating system, and type of mobile internet browser used. Additionally, we may collect information that your browser sends when visiting our service or accessing it through a mobile device.

Please note that the data we collect is used to improve and optimize our service for you. In compliance with data privacy laws, we take necessary measures to keep your information secure and only use it for the purpose intended.

Third-Party Social Media Service Information

We may collect information from third-party social media services when you connect your account to our service. This may include your proﬁle information, friend lists, and other data shared publicly on the social media platform. This information will be used to personalize your experience on our service and improve our understanding of our users.

We will only access and collect this information with your explicit consent and in accordance with the terms and conditions of the third-party social media service.”

Data Obtained While Using the Application or Website

Information Collected:

When using the Application, we automatically collect usage data. This includes:

Internet Protocol address (IP address) of your device
Type and version of browser used
Pages visited on the Application and the time spent on them
Unique device identiﬁers
Other diagnostic data (Specify what types of diagnostic data if it is clear)
When accessing the Application through a mobile device, we may also collect:
Type of mobile device used
Mobile device unique ID
IP address of the mobile device
Mobile operating system
Type of mobile internet browser used
Unique device identiﬁers
Other diagnostic data (Specify what types of diagnostic data if it is clear)

Purpose:

We collect this information to understand how users interact with the Application, improve the user experience, and diagnose any technical issues. All data collected is kept conﬁdential and used only for the purpose of maintaining and improving the Application.

We may request certain permissions from Users to access their device data, as outlined above. These permissions must be granted by the User before any information can be accessed. Users have the ability to revoke these permissions at any time by adjusting their device settings or contacting us for support at the provided contact details. Please note that revoking permissions may affect the proper functioning of the application.

We also use tracking technologies such as cookies, beacons, tags, and scripts to collect information and improve our service. These technologies may be used to track activity on our service and store certain information.

Browser Cookie or Cookies:

A cookie is a tiny file that our website stores on your device. You may modify your browser settings to refuse all cookies or to alert you when a cookie is transmitted. Please keep in mind that if you opt to disable cookies, several elements of our service may not work correctly. Unless you have adjusted your browser settings to refuse cookies, our website will use cookies to provide you with the service.

Cookies can be either “persistent” or “session” cookies. Persistent cookies remain on your device even when you are oﬄine, while session cookies are deleted when you close your browser.

Flash Cookies:

Our Service uses Flash Cookies, also known as local stored objects, to collect and store information about your preferences and activity on our Service. These cookies are different from traditional browser cookies and are not managed through the same settings.

Web Beacons:

Our Service and emails may include small electronic ﬁles called web beacons that allow us to track website statistics, such as the number of visitors to a speciﬁc page or the number of emails opened. These web beacons are also known as clear gifs, pixel tags, and single-pixel gifs.

Analytics Cookies:

Type: Persistent Cookies Administered by: Third-Party Purpose: These Cookies collect information about how You use the Website, such as which pages You visit and which links You click on. The information is used to help us understand and improve the performance of the Website and to provide You with relevant content and advertising.

Advertising Cookies:

Type: Persistent Cookies Administered by: Third-Party Purpose: These Cookies are used to deliver targeted advertising to You, based on your browsing history and interests. They may also be used to limit the number of times You see an advertisement and to measure the effectiveness of an advertising campaign.

Social Media Cookies:

Type: Persistent Cookies Administered by: Third-Party Purpose: These Cookies are used to enable You to share content from the Website on social media platforms, such as Facebook and Twitter. They may also be used to track your activity on these platforms and to show you relevant content and advertising.

Please note that by using our Website, You consent to the use of these Cookies. If You would like to disable or delete any of the Cookies, you can do so through your browser settings. However, please be aware that disabling or deleting certain Cookies may affect the functionality of the Website. For more information on how to manage your Cookies, please refer to the help section of your browser or visit the website of the browser provider.

The Use of Your Personal Information

The Company may use Personal Data for the following purposes:

To provide and maintain our Service, including to monitor the usage of our Service.
To manage Your Account, to manage Your registration as a user of the Service, and to provide access to different functionalities of the Service that are available to You as a registered user.
For the performance of a contract, including the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
To contact You, including by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notiﬁcations regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about, unless You have opted not to receive such information.

To manage Your requests, to attend and manage Your requests to Us.
For business transfers, We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
For other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and Your experience.

We may share Your personal information in the following situations:

With Service Providers, to monitor and analyze the use of our Service, and to contact You.
For business transfers, in connection with, or during negotiations of, any merger, sale of Company assets, ﬁnancing, or acquisition of all or a portion of Our business to another company.

With Aﬃliates, Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us, and in which case we will require those aﬃliates to honor this Privacy Policy.

With business partners, to offer You certain products, services or promotions.
With other users, when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, proﬁle, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your proﬁle.
With Your consent, We may disclose Your personal information for any other purpose with Your consent.

Personal Data Storage and Retention

Indulge is committed to protecting the privacy of our users and we are transparent about the data we collect and how it is used. We will retain Your Personal Data only for as long as is necessary to fulﬁll the purposes outlined in this Privacy Policy. This includes providing personalized services, improving our products and services, and complying with legal obligations.

You have the right to request that we delete any personal data we have collected about you at any time. However, in certain circumstances, we may be required to retain your data to comply with legal obligations, resolve disputes, and enforce our legal agreements and policies.

In addition to personal data, we may also collect Usage Data, which includes information about how our service is used. This data is used for internal analysis to improve the security and functionality of our service. Usage Data is generally retained for a shorter period of time, except when it is necessary to strengthen the security or improve the functionality of our service, or when we are legally obligated to retain this data for a longer period.

We take the protection of your personal data seriously and will only retain it for as long as is necessary. We will also delete it at your request, unless there are legal or business reasons that require us to retain it.

Sharing of Your Personal Information

Your personal data, including information such as your name, address, and email address, will be collected, processed, and stored by Indulge at its operating oﬃces and in any other places where the parties involved in the processing are located. This means that your personal data may be transferred to and maintained on computers located outside of your state, province, country, or governmental jurisdiction where data protection laws may differ from those in your jurisdiction.

By providing your consent to this Privacy Policy and submitting your personal data, you agree to the transfer of your personal data as described.

Indulge is committed to protecting the security and conﬁdentiality of your personal data. To ensure this, the company will take all reasonable steps necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. This includes implementing adequate controls, such as security measures, to protect your personal data during the transfer process. The company will not transfer your personal data to any organization or country unless the necessary controls are in place to safeguard the security of your data.

Your Personal Data Disclosure

Transactions in Business

In the event that the Company is involved in a merger, acquisition, or asset sale, your personal data may be transferred to the acquiring party. The Company will provide notice to you before your personal data is transferred and becomes subject to a different privacy policy.

Enforcement of the Law

The Company may be required to disclose your personal data in response to valid requests by public authorities, such as a court or government agency, if required to do so by law.

Additional Legal Requirements

The Company may also disclose your personal data in the good faith belief that such action is necessary to:

Comply with a legal requirement
Defend and protect the Company’s rights and property.
Prevent or investigate potential misbehavior in relation to the Service. Protect the personal safety of Service users or the general public.
Protect yourself from legal responsibility.

The ﬁrm will only release your personal data in compliance with relevant laws and regulations, ensuring that the disclosure is both necessary and reasonable. The organization will also ensure that the sharing is done securely and will take precautions to protect your personal information.

Security of Your Personal Data

At Indulge, the security of your personal data is of the utmost importance to us. We understand that entrusting us with your personal information requires a great deal of trust and we take that trust very seriously. We have implemented robust security measures to ensure the protection of your personal data against unauthorized access, use, or disclosure.

We use a combination of physical, electronic and procedural safeguards to protect your personal data. This includes the use of secure servers, ﬁrewalls, and encryption to protect against unauthorized access. We also regularly review and update our security systems to ensure that they remain effective and adapt to new threats.

However, it is important to note that no method of transmission over the internet or electronic storage is completely secure. While we make every effort to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

We encourage you to be proactive in protecting your personal data by keeping your passwords and other login information conﬁdential and by logging out of your account when using a shared device.

In the event of a data breach, we will promptly notify affected individuals and take all necessary steps to mitigate the impact and prevent any further breaches.

In conclusion, we are committed to protecting your personal data and take all necessary measures to ensure its security. However, please be aware that we cannot guarantee the absolute security of your personal data and encourage you to take additional steps to protect your personal data.

Children’s Privacy Policy

Our Service is not intended for children under the age of 13, and we do not knowingly collect personally identiﬁable information from children under the age of 13. If you are a parent or guardian and you become aware that your child has provided us with personal data without your consent, please contact us immediately. If we become aware that we have collected personal data from a child under the age of 13 without veriﬁcation of parental consent, we will take steps to promptly remove that information from our servers. If you believe we may have information from or about a child under the age of 13, please contact us using the information provided in the ‘Contact Us’ section below.

If it is necessary for us to rely on consent as a legal basis for processing your information and your country requires consent from a parent for children under the age of 13, we will obtain such consent from a parent or legal guardian before collecting and using the child’s information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit, as we have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Your Rights

You have rights under data protection laws in relation to your personal data, including the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request the erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request for erasure for speciﬁc legal reasons which will be notiﬁed to you, if applicable, at the time of your request.
Object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party). You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: If you want us to establish the data’s accuracy, where our use of the data is unlawful but you do not want us to erase it, where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims, or where you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen , your personal data in a structured, commonly used, machine readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent we may not be able to provide certain products or services to you. We will advise you if this is the case at such time when you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

In addition to existing legal rights, if you have a complaint about any breach of this privacy policy, you can contact NITDA at ‘https://app.ndpb.gov.ng/BreachReports/Create‘.

Modifications to this Privacy Policy Statement

We reserve the right to change Our Privacy Policy at any moment. Any modiﬁcations will be communicated to You by publishing the revised Privacy Policy on this page.

Prior to the modiﬁcation being effective, We will notify You through email and/or a conspicuous notice on Our Service, and we will update the “Last updated” date at the top of this Privacy Policy.

It is recommended that you examine this Privacy Policy on a regular basis for any updates. When changes to this Privacy Policy are posted on this page, they become effective.

Your continued use of the service following the implementation of modiﬁcations is deemed acceptance of such changes.

Contact Us

If you have any queries concerning our Privacy Statement, please contact us at:

Email us at operations@indulgemfb.com
Telephone: +234 915 050 9000
By going to https://www.indulgemfb.com/contactus on our website.

Data Protection Officer:
Oluwafemi Yanga
oluwafemi@indulgemfb.com
(+234) 807-9806-226

Thank you.