Privacy Policy

Introduction

Scope

This policy applies to personal data collected, used, stored, or otherwise processed by Lily Fintech Ltd. through its website, mobile applications, customer support channels, and related financial services operations.

Data Lily Collects

• Personal identifiers, including name, date of birth, gender, nationality, BVN, NIN, passport number, or similar government-issued identifiers.
• Contact details such as phone number, email address, and physical address.
• Financial records, including bank account details, balances, statements, transaction history, investment amounts, transaction types, and investment preferences.
• Employment information, including occupation, employer details, and related work information where needed.
• KYC and AML information used for identity checks, risk assessment, and regulatory compliance.
• Technical and usage information, including IP address, device identifiers, browser type, operating system, location data, cookies, app activity, support chats, and call records.

Legal Basis for Processing

• Consent, where you agree to a specific use such as marketing communication.
• Contractual necessity, where processing is required to deliver services or take pre-contract steps at your request.
• Legal obligation, including compliance with the Nigerian Data Protection Act 2023, SEC rules, and other applicable requirements.
• Legitimate interests, including service improvement, support quality, personalized communication, fraud prevention, and security monitoring.

How Lily Uses Personal Data

• Delivering financial services, account management, transactions, portfolio services, and investment-related support.
• Meeting regulatory, compliance, KYC, AML, and reporting obligations.
• Responding to support requests and resolving technical or account issues.
• Sending service updates, newsletters, offers, and personalized recommendations where permitted.
• Detecting, preventing, and investigating fraud, unauthorized activity, or other illegal conduct.
• Analyzing usage patterns so Lily can improve the app, website, and customer experience.

Sharing and Disclosure

• Regulators and public authorities where required by law or regulation.
• Service providers that support payments, analytics, customer support, infrastructure, communications, and similar business operations.
• Affiliates and trusted partners where needed for continuity and service delivery, subject to data protection requirements.
• Courts, enforcement bodies, advisers, or other parties where disclosure is needed to comply with law or protect Lily's rights.

International Transfers

Where personal data is transferred outside Nigeria, Lily applies appropriate safeguards such as contractual protections and other lawful transfer mechanisms so your rights remain protected under applicable data protection standards.

Retention

Lily keeps personal data only for as long as it is needed for the purpose collected or as required by law. Identification data may be retained during your relationship with Lily and for a period afterward, financial and transaction records may be retained for regulatory periods, and data that is no longer needed is deleted or anonymized.

Security

Lily uses technical and organizational controls, including encryption and restricted access, to protect personal data. You should also use strong passwords, keep devices updated, and watch for suspicious emails, links, or requests.

Cookies

Lily uses cookies and similar technologies to keep the website working, measure performance, improve functionality, and personalize parts of the service. You can manage cookie preferences through your browser settings.

Policy Updates

This policy may change to reflect legal, regulatory, operational, or service updates. Where changes are significant, Lily may notify users through email, website notices, in-app messages, or social media channels.

Your Rights

• Access a copy of your personal data.
• Correct inaccurate or incomplete information.
• Request deletion where the law allows it.
• Ask Lily to restrict certain processing activities.
• Receive your data in a structured, commonly used format.
• Object to processing based on legitimate interests or direct marketing.

Exercising Your Rights

To make a privacy request, contact Lily with your name, contact details, and a clear description of the request. Lily may verify your identity before acting on the request and aims to respond within 30 days.

Accessibility

Lily aims to make this policy accessible. If you need help accessing the information in another format, contact the support or data protection team.

Review Frequency

Lily reviews this policy at least annually and may review it more often when legal, regulatory, product, or business changes require an update.