SOAR-GLOBAL TECH SERVICES LTD is the data controller and operates the Uni Loan mobile application. Uni Loan is a financial service product, not a separate legal entity.
This Privacy Policy explains how we collect, use, disclose, retain and protect personal data when you use Uni Loan or apply for a loan. We process personal data in accordance with applicable data-protection and financial-services laws and regulations in Nigeria.
By using Uni Loan, you acknowledge that you have read this Privacy Policy. Where we rely on your consent, we will ask for it separately at the relevant time. If you do not agree with a processing activity that is necessary to provide a service you request, we may be unable to provide that service.
01Data We Collect
Most information used by the credit service is provided directly by you when you use the App or submit a loan application. The App automatically collects only the device model described below.
- Identity and contact data: name, date of birth, gender and phone number, where requested in the application.
- Loan-application data: BVN, Nigerian bank-account details, requested loan amount, loan term and loan purpose. We do not collect income or employment information.
- Device data: device model, collected automatically only to support app compatibility and basic service security.
We do not request an email address or residential address during the loan application process. If you contact us by email, we may process your email address and message to respond to your request. Our own service servers may retain limited operational access logs containing the request time, requested service endpoint, response status and an internal account or transaction reference where applicable. These logs are used only to maintain and secure the service. We do not retain IP addresses or crash logs, and we do not collect device identifiers or operating-system versions. We do not obtain personal data from third-party identity-verification, credit-reference, analytics, advertising or external risk-scoring services. We also do not access, upload or collect your device's address book, contacts, SMS messages, call logs, photos or gallery.
02Why We Use Your Data and Our Lawful Bases
We process personal data to:
- review the information you submit, including your BVN and bank-account details, to assess your loan application;
- provide, administer and collect repayments for loan services;
- communicate about your application, repayments and support;
- maintain app compatibility and basic service security; and
- comply with legal obligations and establish, exercise or defend legal claims.
Depending on the processing activity, we rely on one or more lawful bases, including performance of our contract with you, compliance with a legal obligation, our legitimate interests such as service security, your consent, or another basis permitted by applicable law. Where consent is required, we will obtain it separately and you may withdraw it at any time.
03Automated Decisions and Human Review
We use our own risk-control strategy to assess loan applications. This strategy applies internal assessment rules to the information you submit and may include automated decision-making as well as manual review by authorised personnel. We do not use third-party risk-scoring, credit-reference or identity-verification services.
An automated assessment may affect whether an application proceeds for approval, the amount offered or the terms made available. Where applicable, an authorised member of our team may review the assessment and the information you submitted before a final decision is made.
04How We Share Data
We do not sell personal data or share it with advertising, analytics, credit-reference, identity-verification or external risk-scoring providers. We may share limited information only as necessary to:
- use Nigerian telecommunications providers to send verification, service or repayment messages;
- use Nigerian payment or banking service providers to process repayments or disburse approved funds; and
- respond to regulators, law-enforcement agencies, courts or other authorities where required by law.
The SMS, payment and banking providers used for the service are located in Nigeria. We require these providers to process personal data only for the requested service, follow our documented instructions and provide the same or an equivalent level of protection described in this Privacy Policy. We do not provide personal data to other third parties for advertising, analytics, identity verification, credit-reference or external risk-scoring purposes. We do not track your activity across apps or websites owned by other companies.
05International Transfers
We do not intentionally transfer your personal data outside Nigeria for the services described in this Privacy Policy. Our service servers and the SMS, payment and banking service providers used for the service are located in Nigeria. If this changes, we will update this Privacy Policy and apply the safeguards required by applicable Nigerian data-protection law.
06Data Retention
We retain personal data only for as long as reasonably necessary to provide and service loans, maintain required records, comply with legal, regulatory and accounting obligations, resolve disputes and protect the security of our service.
We determine the retention period for each category of data based on its purpose, applicable legal or regulatory requirements and whether the data is still needed. We do not retain personal data for longer than necessary.
Our service servers may retain limited operational access logs containing the request time, requested service endpoint, response status and an internal account or transaction reference where applicable, only for as long as needed to maintain and secure the service. We do not retain IP addresses or crash logs.
When personal data is no longer required, we delete it, anonymise it or securely isolate it in accordance with our documented retention procedures. Some records may be retained after account deletion where required by law or necessary to establish, exercise or defend legal claims.
You may contact dpo@soarglobaltech.com to ask about the retention period applicable to your personal data.
07Your Rights and Choices
Subject to applicable law, you may request access to, correction or deletion of, or restriction of processing of your personal data. You may object to certain processing, including direct marketing; withdraw consent where processing is based on consent; request human review of an eligible automated decision; and exercise any data-portability right available under applicable law.
You may withdraw consent through the privacy settings in the App or by contacting dpo@soarglobaltech.com. You may initiate a request to delete your Uni Loan account in the app from My > Account & App > Account deletion request, or email dpo@soarglobaltech.com with the subject "Account Deletion Request". We will verify your identity before processing your request. Certain data may be retained to satisfy legal, tax and regulatory obligations even after account deletion.
You may also lodge a complaint with the Nigeria Data Protection Commission or another competent authority.
08Permissions
We do not request access to your device's address book, SMS messages, contacts, call logs, photos or gallery. If we introduce a feature that requires a device permission, we will explain the purpose before requesting it. You may manage any granted permission in your device settings, and we will not require unnecessary permissions to use the core loan service.
09Security
We use reasonable technical, organisational and administrative safeguards to protect personal data. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.
9.1 Personal Data Breach
In the event of a personal data breach likely to result in a risk to your rights and freedoms, we will comply with applicable breach-notification obligations, including notifying the Nigeria Data Protection Commission within 72 hours of becoming aware of the breach where required by law. Where a breach is likely to result in a high risk to affected users, we will also notify them in plain and clear language.
10Children
Uni Loan is not intended for persons under 18 years old. We do not knowingly collect personal data from children. If we become aware that a person under 18 has used the service, we will take reasonable steps to restrict or terminate the account, cancel any pending application and prevent further disbursement. We will review and handle related personal data in accordance with this Privacy Policy and applicable Nigerian law. If you believe a child has provided personal data to us, contact us at dpo@soarglobaltech.com.
11Changes to This Policy
We may update this Privacy Policy when our practices or legal requirements change. We will post the updated version in the app and update the "Last updated" date. Where required, we will seek renewed consent.
12Contact Us
Data Controller: SOAR-GLOBAL TECH SERVICES LTD
CAC Number: 8154064
Address: PLOT 1395, ALONG 1M ROAD, FHA, LUGBE, AMAC, FCT, Abuja, Nigeria
Data Protection Officer / Privacy Contact: dpo@soarglobaltech.com
Customer Support: support@soarglobaltech.com
LEGAL & PRIVACY