1. Introduction

This Privacy Policy applies to the website(s) and mobile applications (together, the "Sites") provided by SUREWORD INVESTMENT AND CREDIT LIMITED, a company incorporated in Nigeria, authorised and regulated by the Central Bank of Nigeria with its registered office address at 15, Oladosu Street, Lagos State, Nigeria, and/or the other Products of SUREWORD INVESTMENT AND CREDIT LIMITED. ("SUREWORD", “we, “us”) who act as data controllers with respect to the personal data you share with SUREWORD under this Policy.

SUREWORD knows that your privacy is important to you and takes user privacy very seriously. We are committed to protecting your personal data (i.e. any information you provide to us from which you can be identified) in accordance with this Privacy Policy and in compliance with the Nigeria Data Protection Act (NDPA) 2023.

SUREWORD reserves the right, at its sole discretion, to alter and update this Privacy Policy from time to time. We therefore invite you to review the current version of the Privacy Policy each time you return to our Sites.

2. What information we’ll hold about you

By “information we mean all of the personal and financial information about you that we collect, use, share and store. The information we hold will vary according to the account and relationship you have with us

SUREWORD INVESTMENT AND CREDIT LIMITED may need to collect information about you and your computer to allow you to use some of our services. The personal information may include:

• Identity data: First name, middle name, last name, marital status, title, date of birth and gender.
• Contact data: billing address and telephone numbers, email address.
• Financial data: bank account, BVN and payment card details.
• Transaction data: details about payments to and from you and other details of products and services you have subscribed to.
• Technical data: internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile data: your username and password, your interests, preferences, feedback and survey responses.
• Usage data: information about how you use our website, products and services.
• Marketing and communications data: your preferences in receiving marketing from us and our third parties and your communication preferences.

3. How We Collect Your Personal Information

• Direct Engagement: when you register or log on to the website or when you choose to use an available SUREWORD service via the website, mobile app, including when you fill out forms, transfer any policies into our agency, upload any documentation, send SUREWORD any communication by email, phone or post, make an enquiry, or any other communication that SUREWORD receives directly or indirectly from you.
• When you browse the SUREWORD website: information relating to your browsing patterns and technical data about the equipment you are using to access the website is automatically collected using cookies, server logs and other similar technologies. You can select your preference from the cookies settings on any of our websites
• Automatically: As you browse our websites certain information relating to your browsing patterns and technical data about the equipment you are using to access the website is automatically collected using cookies, server logs and other similar technologies. Please see our Cookie preference for further information.
• From third parties/public sources:
• technical data may be obtained from the following parties:
• analytics providers
• advertising networks
• search information providers
• Contact, financial and transaction data may be obtained from providers of technical, payment, credit referencing.
• We utilise third-party service providers to secure information related to financial crime, fraud, sanctions and Politically Exposed Persons.
• From recorded images and calls: We'll record or monitor phone calls with you for regulatory purposes, for training and to ensure and improve quality of service delivery, to ensure safety of our staff and customers, and to resolve queries or issues. We also use CCTV on our premises to ensure the safety and security of our staff and customers.

4. Why we need the information and what we use it for

The Nigeria Data Protection Act requires us to have one or more of the following reasons for using your information:

Consent – in some cases we may obtain your consent to use information in a particular way or where the law requires consent to be obtained. Using your information
• Contract performance – the information needed to deliver your account, product or service, e.g. we’ll need to hold your transaction history to give you an account statement.
• Legal obligation – we are required by law to process your information, e.g. to verify your identity.
• Legitimate interest – we’re allowed to use your information where, on balance, the benefits of us doing so are legitimate and not outweighed by your interests or legal rights e.g. we have an interest in knowing what our customers do and don’t like so we can offer better products and services

These are the main ways we’ll use your information (and the reasons for doing so):

• Check your identity and eligibility for an account
• Manage your account and relationships with us
• Assess risk and carry out credit scoring
• Recover money that is owed to us
• Improve our services and computer systems
• Identify other products and services from us and our partners that you may find useful
• Manage and organise our business
• To manage relationships with third parties who introduce customers to us
• To advise on the suitability of our mortgage

5. How long we hold information

How long we keep your information for depends on the products and services we deliver to you.

We’ll retain information for no longer than is necessary to manage your relationship with us and this will mean that we’ll continue to hold some information for a period of time after your account has closed or our relationship has ended, for example where required by a regulator, for active or potential legal proceedings, to resolve or defend claims, or for making remediation payments.

If you would like any further information about how long we hold your information, please contact our DPO by email at dpo@surewordcredit.com.ng

6. Accuracy of Your Data

It is important that the personal data SUREWORD holds about you is accurate and up-to-date. Please keep SUREWORD informed if your personal data changes during your relationship with us. With our customer facing products, you can update your personal data or contact our Data Protection Officer when you want to exercise your right to Rectification.

7. Security of Your Data

In order to protect your personal data, SUREWORD has appropriate organisational and technical security measures. These measures include storing data on a dedicated and secure server, restricting access to your personal data to certain employees, ensuring the SUREWORD’s internal IT systems are suitably secure, and implementing procedures to deal with any suspected data breach.

In the unlikely event of a data breach, SUREWORD will take steps to mitigate any loss or destruction of data and, if appropriate, will notify you and any applicable authority of such a breach.

8. Data Transfers and Sharing

SUREWORD may need to pass your information to third party service providers which maintain, administer or develop the website on our behalf and the information will only be provided for such limited purposes and as detailed below. In addition, SUREWORD may provide aggregate statistics about its customers, sales, traffic patterns and related website information to reputable third-parties, but these statistics will include no personally identifiable information.

SUREWORD may transfer your personal data to third parties of the following types:

• companies providing identity or financial validation services;
• financial product providers;
• Payment services companies acting on your, or our behalf;
• banks;
• companies providing analytics services;
• data, service and software providers;
• marketing services companies;
• Regulatory and law enforcement bodies.

The security of your data is important to us and SUREWORD will therefore, only transfer your data to such third parties if one or more of the following apply:

• you have expressly consented to your data being shared with specific third parties;
• the third party needs to access the personal data for the purposes of providing any contracted services to you;
• the third party has agreed to comply with SUREWORD’s instructions, NDPA 2023, required data security standards, policies, and procedures and put adequate security measures in place;

As at the last update to this Privacy Policy, SUREWORD does not share data with any Organisation(s) outside Nigeria.

9. Your Rights as a Data Subject

Your personal data is protected by legal rights as stated in the Nigeria Data Protection Act (NDPA) 2023. These rights include:

• Right to rectification: you have the right to require us to correct any inaccuracies in your data.
• Right to erasure: you have the right to require us to delete your data, subject to certain legal requirements.
• Right to restriction of processing: you have the right to require us to restrict the way in which we process your personal data. You may wish to restrict processing if, for example:
  • You contest the accuracy of the data and wish to have it corrected;
  • You object to processing but we are required to retain the data for reasons of public interest; or
  • As a customer, you do not wish to receive marketing communication.
• Right to data portability: you have the right to obtain from us easily and securely the personal data we hold on you for any purpose you see fit.
• Right to object to processing: you have the right to require us to stop processing your personal data should you wish the data to be retained but no longer processed. Please be aware that this may prevent us from continuing to provide services to you.
• Right of access: you have the right to request access to personal data that we may process about you.
• Right to withdraw consent: you have the right at any time to withdraw consent allowing us to process your personal data. This will not affect the legality of any processing prior to the date of such withdrawal.

If you would like to exercise any of the above rights, please:

• Put your request in writing and send it to us through your usual registered channel (e.g. registered e-mail);
• Specify the ‘Right’ you wish to exercise.

For more information or to exercise your data protection rights please, please contact our Data Protection Officer at: dpo@surewordcredit.com.ng

SUREWORD will endeavor to process all subject access requests within 30 days and if any further extension is required, we will communicate same through existing consented channels – at no cost. However, please note that you may continue to receive existing communications for a transitional period whilst we update your preferences.

10. Job Applicants

If you apply for a job at SUREWORD, you will be asked to submit information to SUREWORD such as your name, contact details, information about your education and work history and any other background information that might be relevant for your application or that you choose to share with SUREWORD. If you do not provide this information to us, we might not be able to process your applicatio

SUREWORD will use this information to assess your application and candidacy for the position to which you have applied. Without limiting the generality of the foregoing, this may include:

• Evaluating your skills and experience in relation to the qualification required for the job to which you have applied;
• Tracking feedback and interactions we have with you throughout the recruiting process. We may also use your information when analyzing our internal recruiting processes to determine:
  • Which recruit sources to focus on;
  • How to improve integration and training programs for new hires with different educational backgrounds and work experience;
  • How to enhance our interview model to improve hiring quality

The information you provide may also be used to communicate with you about SUREWORD events and to send you publications that we think may be of interest to you.

We might share your personal data with other companies affiliated to SUREWORD as well as with third parties such as recruitment service providers, background check providers and IT system providers. These SUREWORD companies and third parties might be located in a different country than your country of residence.

We will keep your application data for up to 1 year. If you no longer wish for SUREWORD to process your data or if you wish to exercise your rights, please contact dpo@surewordcredit.com.ng

11. Cookies

Cookies are small files placed on your computer’s hard drive that enables our website to identify your computer as you view different pages. Cookies allow websites and applications to store your preferences in order to present contents, options or functions that are specific to you. Like most interactive websites, our website uses cookies to enable the tracking of your activity for the duration of a session. Our website uses only encrypted session cookies which are erased either after a predefined timeout period or once the user logs out of the platform and closes the browser. Session cookies do not collect information from the user’s computer. They will typically store information in the form of a session identification that does not personally identify the user.

12. Updates to the Privacy Policy

We are constantly trying to improve our Websites and Services, so we may need to change this Privacy Policy from time to time as well. We will alert you to material changes by, for example, placing a notice on our Websites and/or by sending you an email (if you have registered your e-mail details with us) when we are required to do so by applicable law. We reserve the right to update this Privacy Policy from time to time. If you believe at any time that we have not handled your data in accordance with this Policy you should contact the Data Protection Officer at dpo@surewordcredit.com.ng. You may also contact the Nigeria Data Protection Commission at: services@ndpc.gov.ng.

We have appointed a data protection officer (DPO) who is responsible for dealing with any such concerns, in addition to overseeing questions in relation to this Privacy Policy and handling requests in relation to the exercise of your rights. If you have any concerns or questions, please contact the Data Protection Officer using the details set out below.

12. Contact

Data Controller
SUREWORD INVESTMENT AND CREDIT LIMITED.
138, Abuloma Road, Port-Harcourt,
Rivers State, Nigeria
dpo@surewordcredit.com.ng

If you have any questions, comments and requests regarding your privacy and rights, please let us know how we can help:

Data Protection Officer
dpo@surewordcredit.com.ng
April, 2026