Privacy policy
Privacy Policy
Effective Date: 1st August 2025
E and B Cooperative Society Limited ("we," "us," "our," or "the Society") is committed to protecting the privacy and security of our members' and users' personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our services, including our website (ebgrowthfund.com), mobile applications, and any other services (collectively, the "Services").
This Policy is formulated in accordance with the following Nigerian laws and regulations:
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Nigeria Data Protection Act (NDPA) 2023
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Central Bank of Nigeria (CBN) Regulatory Frameworks for financial institutions and mobile money services.
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The Cooperative Societies Act (of the relevant Nigerian state).
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CBN Consumer Protection Framework.
By accessing or using our Services, you consent to the practices described in this Policy.
1. Information We Collect
We collect information that is necessary for the performance of our contractual obligations to you, to comply with legal requirements, and for our legitimate business interests.
a. Personal & Financial Information:
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Identification Data: Full Name, Government-Issued ID Number (e.g., NIN, Voter's Card, International Passport), Photograph, Signature, Residential Address.
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Contact Data: Email Address, Phone Number, Physical Address.
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Financial Data: Bank Verification Number (BVN), Bank Account Details, Transaction History, Savings History, Loan History, Credit Reports from licensed bureaus.
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Biometric Data: (If applicable and with explicit consent) Fingerprint or facial recognition data for identity verification and secure login.
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KYC & AML Data: Information required to comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations as stipulated by the CBN.
b. Technical & Usage Data:
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Device Information: IP address, browser type and version, device type and operating system.
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Usage Data: Pages visited, features used, time spent on our Services, and other diagnostic data collected through cookies and similar tracking technologies.
2. Legal Basis & Purpose for Processing Your Data
We process your data based on the following legal grounds:
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Performance of a Contract: To create and manage your membership account, process your savings, disburse loans, and facilitate transactions.
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Legal Obligation: To comply with our regulatory obligations under the NDPA, CBN guidelines, Cooperative Laws, and AML/CFT regulations.
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Legitimate Interest: To improve our Services, ensure network and information security, prevent fraud, and for administrative purposes.
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Explicit Consent: For marketing communications and the processing of special categories of data (like biometrics). You may withdraw this consent at any time.
3. How We Share Your Information
We may share your information only as necessary and with the following categories of recipients:
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Regulatory Authorities: The Central Bank of Nigeria (CBN), Nigerian Financial Intelligence Unit (NFIU), and other law enforcement or government agencies as required by law.
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Service Providers: Trusted third-party vendors who provide services on our behalf (e.g., cloud storage, payment processing, SMS gateways, credit bureau checks). These partners are bound by strict data processing agreements.
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Credit Bureaus: To perform credit checks and assessments as part of our loan evaluation process, in line with CBN guidelines.
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Professional Advisers: Our auditors, lawyers, and other consultants under duties of confidentiality.
We do not sell or rent your personal data to third parties for their marketing purposes.
4. Data Security and Retention
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Security: We implement robust technical and organizational measures to protect your data, including encryption, access controls, secure servers, and regular security training for our staff.
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Retention: We will retain your personal data only for as long as necessary to fulfill the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements as stipulated by CBN and NDPA retention policies. Thereafter, your data will be securely archived or anonymized.
5. Your Data Subject Rights under the NDPA
As a data subject, you have the following rights, which you can exercise by contacting us at info@ebgrowthfund.com:
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Right to Access: You can request a copy of the personal data we hold about you.
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Right to Rectification: You can request that we correct inaccurate or incomplete data.
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Right to Erasure ("Right to be Forgotten"): You can request the deletion of your personal data, subject to our legal obligations to retain certain records.
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Right to Restriction of Processing: You can request that we suspend the processing of your personal data.
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Right to Data Portability: You can request a structured, commonly used, and machine-readable copy of your data to transfer to another controller.
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Right to Object: You can object to the processing of your personal data based on our legitimate interests.
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Right to Lodge a Complaint: You have the right to complain to the Nigeria Data Protection Commission (NDPC) if you believe our processing of your data violates the law.
6. Updates to This Policy
We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or other reasons. We will communicate any material changes by posting the updated policy on our website with a new effective date and, where required by law, by seeking your renewed consent.
7. Contact Us
For any questions, requests, or complaints regarding this Privacy Policy or your data, please contact our Data Protection Officer (DPO) at:
E and B Cooperative Society Limited
Email: info@ebgrowthfund.com (Please use "Data Privacy Request" in the subject line)
Phone: +2348104711125
Address: E and B Cooperative society, Opposit AA Rano full station, Suleja Niger State.