Privacy Policy

Introduction

Welcome to the Lilycash App! Lilycash (referred to as “we”) understands the importance of your personal information and is committed to protecting your privacy and personal data. We will explain, in accordance with legal requirements, how we process your personal information while you use the Lilycash platform’s products or services through the Lilycash Privacy Policy (hereinafter referred to as “this policy”). This document also details how you can access, update, delete, and protect your information.

Important Notice: Before using the products or services of the Lilycash platform, please make sure you read this policy carefully, especially the provisions highlighted in bold. You should focus on reading these terms and, only after fully understanding and agreeing, proceed to use the Lilycash platform. If you or your guardian (if you are a minor) disagree with any part of this policy, you will not be able to use the products or services on the platform. If you have any questions, comments, or suggestions regarding this policy, you can contact us using the details provided in Section 9.

Please note the scope of this policy: It applies to all products and services provided by the Lilycash platform. If a product or service from us or our affiliates uses Lilycash without having a separate privacy policy, this policy will apply. However, if a separate privacy policy exists, the independent policy takes precedence.

Last Updated : Sept 20, 2024

Definitions

  • Lilycash Loan/We: Refers to MAGNET LENDING LIMITED, the company that develops and operates the Lilycash loan platform.
  • Lilycash app: Refers to the Lilycash loan website and client (including App or H5 pages), and the client terminal devices include but are not limited to PCs, tablets, mobile phones, etc.
  • Affiliated Companies: Refers to a party’s affiliated companies, which are directly or indirectly controlled by a party; or directly or indirectly controlling a party; or jointly controlling the same company or being able to exert significant influence on it; or entities directly or indirectly controlled by the same company as a party. This includes, but is not limited to, a party’s parent company, subsidiaries; subsidiaries controlled by the same parent company as the party; joint ventures, associates, etc. Here, “entities” refer to any company, enterprise, or other legal entity; “control” refers to the ability to influence the management of the entity, whether through ownership, voting shares, contracts, or other means recognized by the court.
  • User/You: Refers to the natural persons who access or use the products/services provided by the Lilycash loan platform, including registered and non-registered users.
  • Personal Information: Refers to various types of information recorded electronically or otherwise that can identify a specific natural person’s identity either alone or in combination with other information, or reflect a specific natural person’s activities.
  • Sensitive Personal Information: Refers to personal information that, if leaked, illegally provided, or misused, could harm personal or property safety, lead to reputational damage, physical or mental health harm, or result in discriminatory treatment. The sensitive personal information covered in this policy includes basic personal information, occupational information, family relations, contact persons, financial account information, etc.
  • Deletion of Personal Information: Refers to the removal of personal information in systems involved in the daily business functions, ensuring that the information remains in a state that cannot be retrieved or accessed.
  • Children: Refers to minors under 14 years of age.
  • Minors: Refers to natural persons under the age of 18. Minors over the age of 16 who rely mainly on their labor income for their livelihood are regarded as persons with full civil capacity.

This privacy policy aims to explain and help you understand the following:

  1. How we collect and use your personal information.
  2. How we use cookies and similar technologies.
  3. How we share, transfer, delegate processing, and publicly disclose your personal information.
  4. How we store and transmit your personal information across borders.
  5. How we protect the security of your personal information.
  6. How we protect the personal information of minors.
  7. Your personal rights.
  8. Our non-malware commitment.
  9. Amendments and notifications regarding this policy.
  10. How to contact us.

1. How We Collect and Use Your Personal Information

When you use our products/services, you may be required or have the option to authorize us to collect and use your personal information under the following circumstances:

  1. To provide you with the basic functions of our products/services, you need to authorize us to collect and use necessary information. If you refuse to provide such necessary information, you will not be able to use our products/services normally.
  2. To provide you with additional features of our products/services, you can choose to authorize us to collect and use information. If you refuse to provide such information, you will not be able to use the related additional features or achieve the intended functionality, but it will not affect your normal use of the basic functions of our products/services.

Please note that due to the variety of products and services we offer, we will collect and use your personal information based on the “reasonable, legitimate, and necessary” principles according to the specific products/services you choose to use. In addition, you understand and agree that to provide you with better products and services, we may introduce new or optimized features from time to time, which may involve changes in the purpose, scope, and method of personal information collection and usage. We will notify you of such changes through policy updates, pop-up windows, or in-app messages, and provide you with an option to consent. If you have any questions, suggestions, or concerns during this process, you can contact us through the contact details provided in Article 9 of this policy.

1.1 Help You Register and Manage Lilycash Loan Accounts

1.1.1 Account Registration

If you wish to use Lilycash Loan platform products/services, you first need to register an account with Lilycash Loan platform and become a member. To create an account on the platform, we need to collect your phone number to identify your online identity. If you refuse to provide your phone number, we will not be able to create an account for you on the platform, and you will not be able to use our services. If you use different devices under the same account, we may associate information collected from these devices to provide you with a consistent service experience.

1.2.1 Account Login

When you log in to the Lilycash Loan platform using your phone number for the first time, we will send you a one-time verification code to verify your identity for account security and to comply with legal regulations.

1.3.1 Profile Maintenance and Account Management

To maintain your personal information and improve your service experience, we will keep your information confidential.

1.2 Providing Security Features

1.2.1 Real-Name Authentication and Management

When you use Lilycash Loan services (including credit services, payments, and repayments), you need to provide your identity information for real-name authentication, including name, gender, occupation, address, ID type, number, marital status, work information, and contact details. We will submit this information to legitimate verification agencies to ensure accuracy. If you do not comply with real-name authentication requirements, you will not be able to use the Lilycash Loan platform’s products or services.

1.2.2 Providing Security Assurance

To ensure the stability and security of our system, prevent illegal access to your personal information, and enhance account security, we may collect your transaction details, log information, device application list, location, financial account ID, IMEI, IMSI, and basic device information. If you refuse to provide such information, you may not be able to use our services properly.

1.2.3 Credit Evaluation

To accurately assess your creditworthiness and repayment ability, we require you to provide personal details such as your name, ID number, address, occupation, and income information when applying for credit services on the platform. If you refuse to provide such information, we will not be able to evaluate your eligibility and credit.

1.3 Providing Customer Service and Dispute Resolution

To ensure the security of your account, our customer service team will verify your identity using your account information (registered phone number), identity information (name, ID number), and order information. When you require us to provide customer service or after-sales support related to your transaction information, we will retrieve your identity information, transaction data, behavior data, browsing history, frequently used device or software information, items of interest, and any relevant information you provide during your contact with customer service from our backend. If you request assistance from customer service to modify certain information (such as personal data, contact details, or phone number), you may need to provide additional information beyond what was previously mentioned to complete the modification. Some of the aforementioned data may involve sensitive information, and if you refuse to provide it, you may not be able to use our services normally.

When you contact us, we may retain the communication/phone records and the content of your conversations, or any contact details and relevant information you provide, to keep in touch with you, help resolve your issue, or record the handling process and outcomes. These recordings will be automatically deleted after being retained for the minimum required time stipulated by law (30 days), unless compliance or legitimate interests necessitate their retention.

1.4 Facilitating Borrowing and Repayment

When you use Lilycash loan services to borrow or repay loans, depending on the type of service, you may need to provide your bank card number or an account associated with a mobile phone number that supports receiving funds. Some of this information involves sensitive data, and if you refuse to provide it, you may not be able to use our services properly.

1.5 Sending Product/Service Information to You

We will send you the latest information about our products or services, including but not limited to the most up-to-date Lilycash loan products and promotions, via in-app messages, pop-up notifications, SMS, emails, or phone calls. If you choose not to receive such information services from us, you can disable these commercial information pushes through settings outlined in this policy or by calling our customer service hotline. Disabling these messages will not affect your use of the basic functions of the Lilycash loan platform.

1.6 Providing Order Management Functionality

When you are about to order a product/service on the Lilycash loan platform, the system will automatically generate your loan order. During the order management process, we may collect the following information:

(1) Information required by the loan product/service you have chosen;

(2) The names and phone numbers of your emergency contacts;

(3) Order information generated while using Lilycash loan platform products/services.

We collect this information to help you confirm transactions, process payments, receive notifications, assist you in querying and managing order details, and provide customer service and after-sales support. Additionally, we use your order information to assess whether your transactions are abnormal in order to protect their security.

For example, when using financial products and services, you will need to provide and allow us to collect your identity information (depending on the loan product requirements, this may include name, gender, type of ID document), bank card or third-party payment account (mobile account) details, phone number, and basic personal information. According to Nigerian laws and regulations governing financial services, if you do not provide the required information for real-name authentication to verify your identity, you will be unable to use financial products or services. You may be required to provide additional necessary information to complete the use of loan products and services, as shown in the loan process prompts or authorizations. Please read carefully.

1.7 Explanation of Device Permission Usage

To enhance the user experience, you can use additional features based on the relevant permissions granted through your mobile device’s operating system. If you choose not to enable these permissions or provide the personal information collected through these permissions, you will still be able to book and use various services on the Lilycash loan platform. However, please note that these permissions may vary depending on your mobile device’s operating system.

Be aware that enabling any permission indicates that you authorize us to collect and use the corresponding personal information to provide related services. Once you disable any permission, you are canceling the authorization, and we will no longer collect or use the relevant personal information, nor will we be able to provide the services associated with that permission. However, your decision to disable permissions will not affect the information collected and used based on your prior authorization.

You can visit the Lilycash loan terminal’s device permission guide to review the permissions that the platform may request and use.

Android system application permission explanation:

Calendar Permission

  • Purpose of Permission: We may use your calendar permission to help you manage and remind you of repayment dates, loan due dates, and other important financial events. Granting this permission will help you track your financial plans more effectively. If you choose not to provide calendar permission, you won’t be able to set automatic reminders through the app, but you can still set them manually.
  • Data Usage: With your consent, we will access and process your calendar information, including the event date, title, and related notes to ensure that you receive relevant notifications and reminders.
  • Data Security: Your calendar information will only be used for reminders and notifications, and it will not be shared with third parties. The data will be encrypted using HTTPS (https://app.lilycash.club) during transmission to protect your privacy.

Approximate Location Permission

  • Purpose of Permission: We use approximate location (coarse location) permission to optimize the services we provide to you, especially to recommend suitable loan products and promotions. Granting this permission will help us offer personalized services based on your location.
  • Data Usage: With your consent, we will collect your approximate geographic location (without pinpointing specific addresses). This information will be used to analyze regional loan demand and user behavior to improve the user experience.
  • Data Security: Your location data will be encrypted using HTTPS (https://app.lilycash.club) during transmission and will not be shared with unauthorized third parties. We ensure that your location is only used to enhance user experience.

Device Information Permission

  • Purpose of Permission: We may collect your device information (such as device model, operating system version, unique device identifier, etc.) to optimize the compatibility and functionality of the app, ensuring a smooth user experience. If you choose not to provide device information permission, some features may not work properly.
  • Data Usage: With your consent, we will collect and analyze your device information to optimize app performance, ensure compatibility with your device, and provide relevant technical support.
  • Data Security: All device information will be strictly confidential, used only to improve app performance and functionality, and will not be shared with third parties. The data will be encrypted to using HTTPS (https://app.lilycash.club) during transmission.

Camera Permission (Selecting Photos)

  • Purpose of Permission: By granting camera permission, you will be able to take or select photos for identity verification or to upload a profile picture. If you decline to provide camera permission, you won’t be able to use the photo upload feature, but you can still upload files through other methods.
  • Data Usage: With your consent, the app will allow you to take photos using your camera or select images from your gallery. These images will only be used for account verification or profile settings.
  • Data Security: Your photos will be encrypted using HTTPS (https://app.lilycash.club) during transmission and will not be shared or used for other purposes without your consent.

SMS Permission

  • Purpose of Permission: When you use our application, we access your financial SMS information to assess your cash flow. We can identify your bank accounts and their transaction history, which helps us detect potential fraud or unauthorized use of our services. You may choose to grant or deny this permission, but if you refuse, we may be unable to accurately assess your risk and creditworthiness.
  • Data Usage: With your consent, we will collect your SMS data, including the content of the message, the date it was sent, and the sender’s phone number. This data will help us recognize your banking information and financial patterns. We also collect and process your phone’s SMS logs.
  • Data Security: Your SMS data will be encrypted using HTTPS (https://app.lilycash.club) during transmission. Your data will not be shared with any third parties without your permission.

Call Log Permission

  • Purpose of Permission: In order to ensure the security of the user’s account and to prevent unauthorised use, we will verify the user’s identity through voice authentication code and collect the user’s call logs, including data such as the call number, date of the call, and duration of the call.

  • Data Usage: When you register or log in to our app, we send a voice verification code to your device as login credentials. We read and analyse your call log data for the following purposes::

    • User Authentication:Verify that you are the rightful account holder with a voice verification code。
    • Fraud Prevention:The device that uses the App service and the device that logs in are the same device。
  • Data Security: Your call log data will be encrypted using HTTPS (https://app.lilycash.club) during transmission. Your data will not be shared with any third parties without your permission.

App List Permission

  • Purpose of Permission: To ensure transaction security during payments, assess your creditworthiness when applying for loans, and prevent fraud, we require permission to access the list of apps installed on your phone.
  • Data Usage: We collect information such as the version number of the installation package, app names, installation time, last update time, and package names to prevent unauthorized access to your personal data and to protect your account security.
  • Data Security: The information collected will be highly encrypted and securely uploaded via HTTPS servers (https://app.lilycash.club). Your data will not be shared with third parties without your consent.

Phone Permission

  • Purpose of Permission: We need access to your device permissions to gather device information such as operating system, system version, IMEI number, IMSI number, MAC address, serial number, Android ID, screen size, and other hardware information. This helps us identify your device and ensure that unauthorized devices do not act on your behalf, protecting against fraud.
  • Data Usage: With your permission, this data is used to ensure the security and authenticity of your device.
  • Data Security: We guarantee that your data will not be shared with any third parties without your consent. Your device information will be securely uploaded via HTTPS servers (https://app.lilycash.club).

Contacts Permission

  • Purpose of Permission: Based on the added functionality of your contact list, once you enable this permission, we can match and display the contacts or phone numbers you select, allowing you to easily choose relevant contacts. We will only record and match the information of the contacts you choose, not your entire contact list. When applying for a loan service via the Lilycash app, you may directly select and import the chosen contact from your address book. If this permission is not granted, you will not be able to use the mentioned services or features.
  • Data Usage: We only collect information for the contacts you specify, including their name, relationship to you, and phone number. This data is used for risk management and anti-fraud verification.
  • Data Security: Rest assured that without your explicit consent, we will not share this information with any third parties. The data will be securely transmitted to Lilycash’s servers (https://app.lilycash.club).

1.8 Improving Lilycash Loan Platform Products/Services

(1) We may anonymize the information collected and conduct research, statistical analysis, and forecasting to improve the content and layout of the Lilycash loan platform. This helps support business decision-making and enhances our products and services.

(2) We may use your order data for data analysis to understand your location, preferences, and demographic information or match it with other sources (including third-party data) to develop and improve our products and services.

(3) We may invite you to participate in market surveys using the contact information you provided. Based on the information you offer through the surveys, we will analyze and assess your interest in our products, services, and website to further develop and improve them. If you choose not to participate in market surveys or provide related information (as per the survey display page), it will not affect your use of basic functions of the Lilycash loan platform.

1.9 Special Instructions on the Collection and Use of Your Personal Information

(1) If the information you provide contains personal information of other users, for example, if you order products or services on the Lilycash loan platform on behalf of others and need to submit the actual recipient’s personal information, or if the information you voluntarily upload involves other users’ personal information, you must ensure that you have obtained their consent before providing such information to the Lilycash loan platform. You must also ensure they are aware of and accept this policy. If children’s personal information is involved, you need to obtain the consent of the child’s guardian in advance. Unless otherwise exempted by authorization consent requirements (as detailed in this policy under “How We Collect and Use Your Personal Information”), we will obtain your separate consent in certain scenarios involving sensitive personal information. The method of obtaining such consent will be displayed on specific functional pages.

(2) If we intend to use your information for purposes not outlined in this policy or use information collected for a specific purpose for other purposes, we will re-obtain your authorization and consent.

(3) With your consent, we may also obtain your personal information from affiliates of Lilycash, partners, credit institutions, and other legally established third parties that legally hold your relevant information to provide identity verification, security assurance, and credit assessment services. Since the required personal information may vary across different products or services, we will request your consent before you use a specific product or service via page prompts or interaction processes. The scope of personal information obtained will be governed by the agreement or rules of the specific product or service you agree to. For example, when you apply for a credit loan from our affiliated company or business partners, the partner may share details like your loan amount, interest rate, and approval status with us so that we can display this information to you. We will require the third party to explain the source of your personal information before collection and confirm its legality. If we plan to use the information beyond the third party’s authorized scope, we will seek your consent before processing the personal information. As the products and services we provide continue to be updated, if any product or service not previously mentioned collects your information, we will explain the information collection through page prompts, interaction processes, website announcements, etc., to obtain your consent. Such information is subject to this privacy policy.

(4) Exceptions to Authorization Consent You fully understand that, under the requirements of laws and regulations, we may collect and use your personal information without your authorization and consent in the following situations:

  • When required to fulfill legal obligations or statutory duties of Lilycash;
  • When related to national security or defense;
  • When related to public safety, public health, or significant public interest;
  • When related to criminal investigations, prosecution, trial, or judgment execution;
  • When necessary to enter into or perform a contract to which you are a party;
  • When, in emergency situations, necessary to protect your or other individuals’ life, health, and property;
  • When personal information is publicly disclosed by the information subject or legally made public;
  • When collecting your personal information from legitimate sources, such as lawful news reports, government information disclosure, etc.;
  • When necessary for public interest reporting, media supervision, or within a reasonable scope for processing personal information;
  • When necessary to maintain the security and stability of the products or services provided, such as detecting and addressing product or service malfunctions;
  • When academic research institutions, based on public interest, require it for statistical or academic research, provided that personal information contained in research results is anonymized;
  • Other situations as specified by laws and national standards.

Please be aware that, according to applicable laws, if we use technical measures or other necessary steps to process personal information so that the recipient cannot re-identify the specific individual, we are not required to notify you or seek your consent for such processing.

This privacy policy applies only to situations where we need to process your personal information to provide Lilycash loan app products and services.

How We Use Cookies and Similar Technologies

(1) Cookies for Service Quality To ensure you can use our services normally or receive a higher quality of service, we store small data files called cookies on your device. When users visit services or information that require login, we encrypt and store the login name in the cookie file on the user’s device. Since the login information is stored in an irreversible encrypted format, others, even if they use the same computer, cannot recognize the user’s username and password. Users do not need to take any additional steps, as all collection and storage is handled automatically by the system. We will not use cookies for purposes other than those outlined in this privacy policy.

(2) Managing Cookies You have the right to accept or refuse cookies. If your browser automatically accepts cookies, you can modify your browser settings to refuse them as needed. Please note that if you choose to refuse cookies, you may not be able to fully use the services we provide.

(3) Pixel Tags for Ad Monitoring In addition to cookies, we use pixel tag technology on our website to monitor the effectiveness of advertising. With pixel tags, we can better understand whether users have viewed the ads we have displayed.

How We Share, Transfer, Delegate, and Publicly Disclose Your Personal Information

3.1 Sharing and Provision

3.1.1 Processing Principles

We may share your order information, account information, and device information with third-party partners to ensure that the services we provide to you are completed smoothly. However, we will only share your personal information for legitimate, necessary, and specific purposes and only the information required for the service. We will assess the legitimacy and necessity of third parties collecting your personal information and require them to process your information within the scope of your authorization, using appropriate management and technical measures to prevent data leakage, damage, loss, or alteration. Third parties are not permitted to use your shared personal information for any other purpose, and any changes to the handling of your information will require your renewed authorization.

Except for specific situations (outlined in the “How We Collect and Use Your Personal Information” section), we will obtain your separate consent in other cases before sharing or providing personal information as required by law. Regardless of whether separate consent is needed, we will clearly inform you of the third-party providers involved, their processing purposes, methods, and categories of personal information shared. The separate consent form will be shown on the service page.

3.1.3 Our Partners Include:
  1. Financial Institutions and Third-Party Payment Providers: When you create a loan order or request a refund, we may share specific order information with financial institutions or payment providers. If necessary for fraud detection, we will share other relevant information, such as your IP address. If you use our credit products, we may share identity information, contact details, bank account data, and other required information with partner financial institutions to enable them to provide services. Prior to using these services, we will inform you about the sharing rules and seek your consent.
  2. Business Partners: We may share necessary personal information with partners providing services such as delivery, communication, customer service, marketing, advertising, technical support, authentication services, and consulting. For example, to deliver better services, we may delegate advertising partners to process information related to ad coverage and effectiveness (e.g., unique device identifiers), but personal identity data will not be shared. Partners may combine anonymized data with other data for advertising purposes. To send you service or business notifications, we may share your phone number with SMS service providers.
  3. Affiliated Companies: We may share your personal information with affiliated companies to provide related products or services. These companies will follow the same protection measures as outlined in this policy. For fraud prevention and detection, we may share necessary information after careful internal evaluation, with the use of signed agreements to limit the purpose of this information.

3.2 Data Transfer

We will not transfer your personal information to any organization or individual unless:

  1. You have given explicit consent;
  2. It is required by law, legal proceedings, or mandatory administrative or judicial requests;
  3. In cases of mergers, acquisitions, or asset transfers, we will inform you of the receiving entity’s name and contact details and ensure that they adhere to this policy or obtain new authorization from you.

3.3 Public Disclosure

We will only publicly disclose your personal information under these circumstances:

  1. With your explicit consent and in a manner approved by you;
  2. When required by law or legal authorities. We will request legal documents, such as subpoenas, before disclosing any information.

How We Store Your Personal Information

4.1 Storage Principles

We will not transfer your personal information to any company, organization, or individual unless:

  1. We have your explicit consent to transfer your personal information to others;
  2. It is required by applicable laws, regulations, legal processes, or mandatory administrative or judicial requests;
  3. In cases of mergers, acquisitions, or bankruptcy, if personal information transfer is involved, we will require the new company or organization holding your personal information to continue to adhere to this policy or request the company to obtain new authorization from you.

4.2 Storage Duration

We will retain your information for the shortest period necessary to fulfill the purposes described in this policy (90 days), or as required by law. For instance, when you register on the Lilycash platform, we need to collect and retain your phone number during the time you use the platform to ensure the proper functioning of services and safeguard your account and system security. After the storage period has expired, or if you exercise your right to delete personal information or cancel your account, we will delete or anonymize your personal information.

However, in the following cases, we may adjust the retention period to comply with legal requirements:

  1. To comply with applicable laws and regulations;
  2. To comply with court rulings, decisions, or other legal processes;
  3. To fulfill requests from government agencies or legally authorized organizations;
  4. For the reasonable purposes of maintaining public interest, or protecting the safety, property, and other legal rights of Lilycash platform users, ourselves, our affiliates, other users, or employees.

4.3 Ceasing Operations

If we cease operations of Lilycash platform products or services, we will immediately stop collecting your personal information, notify you of the cessation through individual notices or public announcements, and delete or anonymize all retained personal information.

How We Protect the Security of Your Personal Information

5.1 Technical Security Measures

We have implemented industry-standard security measures to protect your personal information from unauthorized access, disclosure, use, modification, damage, or loss. We take all reasonable and feasible actions to safeguard your data, including but not limited to:

  1. Using encryption technologies to ensure the confidentiality of your data during storage, and employing trusted security mechanisms to prevent malicious attacks;
  2. When using your personal information, such as displaying it to you, evaluating or analyzing your data, or internally transferring data, we employ methods such as content replacement and anonymization to enhance security;
  3. When sharing your personal information externally, such as identity or bank card details, we encrypt data using various techniques based on the sensitivity of the information;
  4. Given the specific security requirements in the financial services sector, we ensure the safety of transactions and personal information through security management, policies, processes, and network architecture.

5.2 Institutional Security Measures

  1. We deploy access control mechanisms to ensure that only authorized personnel can access personal information, and these personnel are required to sign confidentiality agreements;
  2. We monitor processes and retain data access logs or other technical records for a reasonable period to maintain internal information security;
  3. We conduct security and privacy protection training for our employees to raise awareness of the importance of safeguarding personal information, and we conduct regular audits of information security;
  4. We utilize code security inspections and data access log analysis to perform personal information security audits;
  5. We take all reasonable and feasible measures to ensure that we do not collect irrelevant personal information and retain your data only for the period necessary to achieve the purposes stated in this privacy policy, unless an extension is required or permitted by law.

5.3 Handling Security Incidents

In the event of a personal information security breach, we will respond and handle the situation according to legal requirements, following these guidelines:

  1. Promptly inform you of the basic situation of the security incident, its potential impact, the measures we have taken or will take, suggestions for you to prevent or mitigate risks, and remedies for you;
  2. Notify you of the incident through email, letter, phone, or push notifications, and if it is difficult to inform each individual, we will take reasonable and effective measures to issue a public notice;
  3. We will also report the situation to the regulatory authorities in accordance with their requirements;
  4. If we terminate services or operations, we will notify you at least 30 days in advance through public announcements and delete or anonymize your personal information after service or operation termination;
  5. If your legitimate rights and interests are harmed, we will bear the corresponding legal responsibility.

How We Protect the Personal Information of Minors

  1. Protection for Minors’ Information: Lilycash takes the protection of minors’ personal information seriously. If you are a minor under the age of 18, we will not provide our services to you.
  2. Handling Minors’ Information Without Guardian Consent: If there is evidence that a minor has registered and used our services without obtaining consent from their guardian, the guardian may contact Lilycash customer service. Upon verification, we will promptly delete the relevant minor’s personal information.
  3. Inquiries About Children’s Information: If you have any comments, suggestions, or complaints regarding the personal information of minors, please contact us. Details on how to contact us are provided in the “How to Contact Us” section of this policy.

Your Personal Information Rights

According to Nigerian laws and regulations, we ensure that you can exercise the following rights regarding your personal information:

7.1 Access and Query Your Personal Information

You have the right to access your personal information, except in situations where laws or regulations provide otherwise. You can exercise your right to access through the following methods:

  • To access or view your account’s billing information, follow the path: [Home] — [Bills].

7.2 Correct Your Personal Information

If you find that the personal information we hold about you is incorrect, you have the right to request corrections. You can contact us via customer service, and we will complete the verification and processing within 15 working days.

  • You can adjust the scope of your consent by disabling certain device functions (e.g., SMS, contacts). Follow the path: [Home] — [My] — [Settings] — [Privacy Settings] — [Permission Management].
  • You can withdraw all your consent by canceling a specific product or deactivating your Lilycash account. Please understand that some business functions require certain personal information to operate. Once you withdraw your consent, we may no longer be able to provide the corresponding services.
  • Your withdrawal of consent will not affect the processing of your personal information carried out prior to the withdrawal. Additionally, if you have outstanding obligations (e.g., unpaid loans), you may not be able to withdraw your consent until these obligations are settled.

7.4 Delete Your Personal Information

You can request the deletion of your personal information under the following circumstances by contacting customer service:

  • If our processing of personal information violates the law;
  • If we collect or use your personal information without obtaining your consent;
  • If our processing of your personal information breaches the agreement with you;
  • If you no longer use our products or services, or you deactivate your account;
  • If we terminate our services or operations.

Upon agreeing to your deletion request, we will also notify any third parties with whom we shared your information to delete it, unless otherwise required by law. After deleting information from our services, it may not be immediately removed from backup systems but will be deleted upon the next backup update.

7.5 Deactivating Your Lilycash Account

  • You can deactivate your Lilycash account by following the path: [Home] — [My] — [Account and Security] — [Deactivate Account] or by contacting customer service. We will complete the verification and processing within 15 working days.
  • After deactivation, we will delete or anonymize your personal information. However, we are required to retain certain information during the time you use Lilycash for regulatory or legal purposes.

7.6 Unsubscribing From Service Notifications

  • To keep you informed about your use of Lilycash, we may send you service reminders. To unsubscribe, contact customer service. However, business notification messages related to your transactions, financial security, or credit cannot be unsubscribed from.
  • For marketing or commercial electronic messages, you can unsubscribe by contacting customer service as well.

7.7 Obtain a Copy of Your Personal Information

If you need a copy of your personal information, you can contact us using the details provided in section 9. After verifying your identity, we will provide you with a copy of your personal information, including basic profile and identity information, unless otherwise stipulated by law.

7.8 Transfer Your Personal Information

If you need to transfer your personal information to another service provider, you can contact us. Upon verifying your identity, we will provide the necessary support, subject to national regulations and standards.

7.9 Response to Your Requests

You may submit your requests, questions, or complaints via customer service. For security reasons, we will process your requests after verifying your identity, with a response within 15 working days. We generally do not charge a fee for reasonable requests. However, we may not respond to requests in the following situations:

  • Related to national security or defense;
  • Related to public safety, public health, or major public interests;
  • In connection with criminal investigations, prosecutions, trials, or enforcement of judgments;
  • Where there is sufficient evidence of malice or abuse of rights;
  • Where responding would harm the lawful rights and interests of you or others;
  • Where responding would violate commercial secrets.

7.10 Your Right to Know

You have the right to know how your data is shared. We will notify you under the following circumstances:

  • Advance notice: If we plan to share your data with a new type of third party or use your data in a new way, we will notify you in advance and obtain your consent.
  • Policy updates: If our data-sharing practices change significantly, we will update this privacy policy and notify you through the app or other appropriate means.

7.11 Your Right to Refuse

You have the right to refuse the following data processing activities:

  • Targeted advertising: If you do not want us to use your data for targeted advertising, you can opt-out.
  • Data sharing: You may refuse our sharing of your data with third parties unless required by law or necessary for providing the service.

Non-Malware Commitment

We deeply understand the importance of user privacy and data security, and we commit that our app is not malware. Our app will not engage in any of the following activities:

  • Data collection without user consent: We will not collect or store any personal data without the explicit consent of the user.
  • Data sharing without user consent: We will not sell, rent, or share users’ personal data with any unauthorized third parties without user consent.
  • Malicious behavior: Our app will not engage in any malicious actions, such as stealing data, damaging devices, displaying malicious ads, or performing any form of harmful activities.

How This Privacy Policy Is Updated

We may modify this privacy policy when necessary. Please understand that we may revise this policy from time to time, and we will indicate the most recent update date of this policy, which will take effect after being publicly announced. We will not reduce your rights under this policy without your explicit consent. For major changes, we will provide more prominent notifications (including sending notifications via email for certain services to explain specific changes in the privacy policy). We encourage you to frequently review this policy to stay informed about the latest version.

Major changes referred to in this policy include but are not limited to:

  1. Significant changes in our service model, such as changes in the purpose of processing personal information, the types of personal information processed, and how personal information is used.
  2. Major changes in ownership structure or organizational structure, such as changes in ownership due to business adjustments, bankruptcy, or mergers and acquisitions.
  3. Changes in the main recipients of shared, transferred, or publicly disclosed personal information.
  4. Significant changes in your rights related to personal information processing and how you can exercise them.
  5. Changes in the departments responsible for handling personal information security, contact methods, or complaint channels.
  6. If the personal information security impact assessment report indicates high risk.

How to Contact Us

If you have any questions about this policy or have any complaints or suggestions regarding the processing of your personal information, please contact us via the customer hotline or send an email to our customer service email. We will complete the verification and processing within 15 working days.

  • Company: MAGNET LENDING LIMITED
  • Address: 51 Apapa Warf road Expressway Lagos
  • Customer Hotline: +234 (0)2018889599
  • Customer Service Email: contacts@lilycash.club