GENER8 INTEGRATED SERVICES LTD, a company duly incorporated under the laws of the Federal Republic of Nigeria and registered with the Federal Competition and Consumer Protection Commission (FCCPC), operates the digital financial services platform “GIVO.” We are fully committed to protecting your personal data and maintaining your privacy and information security.
This Privacy Policy explains how GIVO (“we”, “our”, or “us”) collects, uses, discloses, and safeguards your personal data when you access or use our mobile applications, websites, and related services (collectively, the “Services”), in compliance with the Nigerian Data Protection Act 2023 and the Nigerian Data Protection Regulation (NDPR) 2019. It also describes your rights and available data protection mechanisms.
If you do not agree with any part of this Policy, you have the right to discontinue using our Services. This Policy may be updated periodically — see Section 9, “Policy Updates,” for details.
By using the GIVO Platform, you consent to the collection, use, storage, and sharing of your personal data as outlined in this Privacy Policy.
1. Information We Collect
1.1 Personal Data You Provide
To provide our loan and financial services and comply with regulatory requirements, we may ask you to share personal information when using our Services. Personal data refers to any information that can identify you directly or indirectly, excluding anonymized data. Such data helps us verify your identity, evaluate creditworthiness, process applications, and enhance service quality and security.
Examples include (but are not limited to):
Full name, Bank Verification Number (BVN), Date of Birth, National Identification Number (NIN), photographs, and valid government-issued identification (National ID, Passport, Driver’s License, Voter’s Card, etc.).
Employment, income, and bank account details.
Contact details such as email, phone number, WhatsApp number, and residential address.
Alternative contact lists, customer support information, and communication records.
1.2 Data Collected Automatically
We automatically collect certain information through cookies and similar tracking tools, in line with applicable laws and platform policies (e.g., Google Play Store and Apple App Store Developer Policies). If disclosure or user authorization is required, we will seek your explicit consent.
This data may include:
Device Information: device type, operating system, IP address, device ID, and network type — used for fraud prevention and risk assessment.
SMS Verification: on Android, we use Google’s SMS Retriever API to auto-fill verification codes (without reading other messages). On iOS, you may use Apple’s built-in OTP autofill or input codes manually.
Location Data: approximate location (GPS, Wi-Fi, or mobile network) to verify identity, prevent fraud, and meet legal obligations.
Camera Access: with your consent, we may use your camera for identity verification and KYC purposes; we never access unrelated files or media.
Installed Apps (Selective): per CBN guidelines, we may collect a limited app list (names, install/update dates, and versions) strictly for fraud detection and credit assessment.
Diagnostics & Usage: app interaction logs, crash reports, battery data, etc., to improve stability and performance.
You can grant or revoke permissions at any time via your device settings. Revocation may affect certain functionalities.
1.3 Cookies and Tracking Technologies
We use cookies, beacons, and similar tools to analyze user behavior, store preferences, and personalize your experience.
Session Cookies: deleted when your browser closes.
Persistent Cookies: retained to remember preferences such as login details or language.
You may disable cookies via browser settings, but doing so may limit some features.
1.4 Information from Other Sources
We may receive additional personal data through:
Customer service interactions, emails, surveys, or complaints.
Third-party sources such as credit bureaus and financial institutions (with your consent).
Job applications, where education, employment, or health information may be requested for lawful HR purposes.
2. How We Use Your Information
2.1 Purposes
We use personal data to:
Deliver, maintain, and monitor the Services.
Manage user accounts and enable account-specific features.
Fulfill contractual and regulatory obligations.
Communicate updates, alerts, or changes to our Services.
Send marketing materials about similar products/services (unless you opt out).
Handle inquiries, feedback, and support requests.
Analyze usage trends and improve user experience.
Facilitate mergers, acquisitions, or reorganizations (if applicable).
2.2 Data Sharing
We may share data:
With trusted third-party partners for service delivery, credit verification, and fraud detection.
With affiliates or business partners under this Policy’s conditions.
During corporate transactions (e.g., mergers, acquisitions).
With regulators, banks, or credit bureaus to fulfill legal or operational obligations.
When you explicitly consent to data sharing.
Aggregated or anonymized data may be used for analytics or research.
3. Data Protection Measures
We apply industry-standard security measures, including:
HTTPS encryption during transmission.
AES-256 encryption for sensitive data.
Access controls and confidentiality agreements with staff.
Three-layer security framework: physical, technical, and administrative controls.
While no system is completely secure, in case of a data breach, we will notify the Nigeria Data Protection Commission (NDPC) within 72 hours per NDPA Section 33.
4. Data Retention and Disclosure
We retain data only as long as necessary to fulfill its intended purpose or comply with legal obligations.
Retention examples:
BVN/NIN Data: 6 years after account closure (CBN AML Regulation).
Loan Contracts: 10 years (Companies Income Tax Act).
We may share data with regulators, financial partners, or legal entities when required by law or court order, including:
FCCPC and tax authorities.
Payment systems and partner banks.
Credit bureaus (fraud/credit scoring).
Legal representatives for dispute resolution.
5. Account Deletion
You may request account closure through:
In-App Customer Support, or
Email: service@givo.ng
Requests will be processed within 30 days, after which data will be deleted unless retention is legally required.
6. Child Protection
Our Services are not intended for individuals under 18 years. We do not knowingly collect data from minors. If discovered, such data will be promptly deleted.
7. Automatic Charge Authorization
By enabling recurring payments, you authorize GIVO to debit your BVN-linked account per CBN Electronic Payment Guidelines (2021).
You will receive at least 3 days’ notice before each deduction.
You agree to maintain sufficient balance and valid payment credentials.
8. Your Data Rights
Under Nigerian data protection law, you have the right to:
Access your data and understand how it is processed.
Rectify inaccurate or incomplete data.
Withdraw consent at any time (without affecting prior lawful processing).
Opt out of marketing via unsubscribe links or by contacting us.
Contact: service@givo.ng
9. Policy Updates
We may revise this Policy due to legal, technical, or business changes. Updates will be published on the GIVO platform, with the latest revision date displayed. Continued use of our Services implies acceptance of the updated Policy.
10. Contact Us
For inquiries, feedback, or complaints about this Privacy Policy:
Email: service@givo.ng
Phone: 07071883681
Company: GENER8 INTEGRATED SERVICES LTD (RC 1803425)