HerVest For Women Limited (“HerVest”, “We”, “Us”, “Our”) is highly committed to protecting and respecting your privacy. This Privacy Policy (“Policy”) explains our privacy practices with respect to personal information shared on our website, www.hervest.ng, and our mobile application (together, the “Platform”). It sets out how HerVest collects, uses, maintains, safeguards and discloses the personal information of the users of our Platform (“User” or “You”).
HerVest is the data controller of the personal information described in this Policy. We process personal information in accordance with the Nigeria Data Protection Act 2023 (“NDPA”), the regulations and guidance issued by the Nigeria Data Protection Commission (“NDPC”), and other applicable laws.
This Policy should be read together with our Terms and Conditions and our Cookie Policy.
1. Applicability of this Policy
This Policy applies to your interaction with us on the Platform. It also applies to your interaction with us through our customer service officers, social media pages, events, campus ambassador programmes and other direct conversations, whether online or offline.
We advise that you read this Policy before you provide us with your personal information or continue to use our Platform, and that you review it from time to time in light of any changes we may make. We will notify you when we make material changes to this Policy.
Please do not access any of our products or services if you do not agree with the terms of this Policy.
2. Personal Information We Collect
Personal information is any information that identifies an individual, or from which an individual could be identified. We only collect personal information that is adequate, relevant and limited to what is necessary for the purposes described in this Policy.
Information you give us. When you visit the Platform, register as a User, open a savings or investment plan, apply for a product, fill out a form or speak with our customer care representatives, we may collect:
Identity information such as your full name, date of birth, gender, photograph or selfie, and government-issued identification (for example, your National Identification Number (NIN), international passport, driver’s licence or voter’s card);
Contact information such as your email address, telephone number and residential or mailing address;
Financial information such as your Bank Verification Number (BVN), bank name and account number, debit card details (which are processed by our licensed payment partners), transaction history, savings and investment preferences, and, where relevant to a product you apply for, your income, employment and source of funds;
Verification documents such as a utility bill or bank statement showing your name and address, provided to meet our “Know Your Customer” (KYC) obligations;
Next of kin or beneficiary details you choose to provide; and
Communications including messages, feedback, survey responses and recordings of calls with our customer care team.
Information we collect automatically. While you use the Platform, the following information may be collected automatically from your device:
details of your device, unique device identifiers (such as IMEI or serial number), information about your SIM card and mobile network, operating system and browser settings;
log and usage information, such as your IP address, the pages and features you use, the time and date of access and the actions you take on the Platform; and
location information from your device’s GPS, where you have granted the mobile application permission to access it. Turning off location services may make some of our services unavailable.
Information from third parties. We may receive information about you from:
identity verification providers and databases, such as the BVN and NIN registries, to confirm that the details you provide are accurate;
banks, payment processors and card networks involved in your transactions;
licensed credit bureaus, where you apply for a credit or loan product; and
partners and Users who refer you to HerVest.
We only collect personal information that you voluntarily submit to us or that is necessary to provide our services. You may refuse to supply your personal information; however, this may prevent you from fully taking advantage of our services, as some information is required by law before we can open an account for you.
3. Non-Personal Information We Collect
We may collect information that cannot be used to identify you, such as anonymous usage data, preferences you submit and preferences generated from the data you submit, your browser name, the type of device used to access the Platform, and other technical information about your means of connection to the Platform. We track some of this information using cookies. Please read our Cookie Policy to learn more.
4. How We Use Your Personal Information
We may use your personal information for the following purposes:
to create and manage your HerVest Account and verify your identity;
to provide our savings, investment and other financial services, including processing deposits, withdrawals, payouts and interest;
to assess your eligibility for, and to provide, any credit or loan product you apply for;
to display content on the Platform that is relevant to you and to personalise your experience;
to respond to your enquiries, requests and complaints effectively and efficiently;
to send you service messages, such as transaction alerts, security notices and updates to our terms;
to send you financial education content, newsletters and information about products and offers, where you have agreed to receive them;
to detect, prevent and investigate fraud, money laundering, terrorism financing and other unlawful activity, and to protect the security of the Platform and our Users;
to comply with our legal and regulatory obligations, including KYC, anti-money laundering, tax and reporting requirements, and to respond to lawful requests from courts and regulators;
to analyse information in aggregate form to understand how our Users use the Platform, and to improve our products and services; and
to establish, exercise or defend legal claims.
5. Lawful Basis for Processing
We only process your personal information where we have a lawful basis to do so under the NDPA. Depending on the purpose, we rely on one or more of the following:
Contract: where processing is necessary to provide the services you have signed up for, or to take steps at your request before entering into a contract with you;
Legal obligation: where we are required by law to process your information, for example to verify your identity and to meet anti-money laundering requirements;
Legitimate interests: where processing is necessary for our legitimate business interests, such as preventing fraud, securing the Platform and improving our services, provided those interests are not overridden by your rights and freedoms; and
Consent: where you have given us your consent, for example to send you marketing communications or to access your device location. You may withdraw your consent at any time, without affecting the lawfulness of processing carried out before you withdrew it.
7. International Transfers
Some of our service providers, such as cloud hosting providers, may store or process your information outside Nigeria. Where we transfer personal information outside Nigeria, we do so only in accordance with the NDPA, for example where the recipient country provides an adequate level of protection, or where appropriate safeguards such as contractual protections are in place to ensure your information receives a level of protection equivalent to that required under Nigerian law.
8. How Long We Keep Your Information
We keep your personal information only for as long as is necessary for the purposes for which it was collected, including to satisfy any legal, regulatory, accounting or reporting requirements.
Anti-money laundering laws require us to keep records of your identity and transactions for at least five (5) years after our relationship with you ends or after the relevant transaction is completed, and we may keep information for longer where required by law or to resolve a dispute.
When your information is no longer required, we will securely delete it or anonymise it so that it can no longer be associated with you.
9. How We Protect Your Information
We use appropriate technical and organisational measures to protect your personal information against unauthorised access, loss, misuse, alteration and destruction. These include encryption of data in transit, access controls that limit access to staff and service providers who need it, and regular review of our security practices.
You also play an important role in keeping your information safe. Please keep your password and PIN confidential, do not share your login details with anyone, and contact us immediately if you suspect any unauthorised access to your HerVest Account. HerVest will never ask for your password or PIN by phone, email or social media.
No method of transmission over the internet or of electronic storage is completely secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the NDPC and, where required, notify you, in accordance with the NDPA.
10. Your Rights
Subject to the NDPA and other applicable laws, you have the right to:
Access the personal information we hold about you and receive a copy of it;
Rectification of personal information that is inaccurate or incomplete. You can update many of your details directly in the mobile application;
Erasure of your personal information where it is no longer needed, subject to our legal obligation to retain certain records;
Restriction of the processing of your personal information in certain circumstances;
Data portability, to receive your personal information in a commonly used, machine-readable format, or to have it transmitted to another controller where technically feasible;
Object to processing based on our legitimate interests, and to object at any time to direct marketing;
Withdraw your consent at any time, where we rely on consent; and
Not be subject to a decision based solely on automated processing that produces legal or similarly significant effects on you, except where permitted by law, and to request human review of such a decision.
To exercise any of these rights, please contact us using the details in the “Contact Us” section below. We may need to verify your identity before acting on your request. We will respond within the time required by law.
If you are not satisfied with how we have handled your personal information, you have the right to lodge a complaint with the Nigeria Data Protection Commission (ndpc.gov.ng).
11. Marketing Communications
With your consent, we may send you financial education content, newsletters and information about our products, offers and events by email, SMS, push notification or other channels. You can opt out at any time by using the unsubscribe link in our emails, changing your notification settings in the mobile application, or contacting us. Opting out of marketing will not stop us from sending you service messages about your account and transactions.
13. Children’s Privacy
Our services are intended for persons who are at least 18 years of age. We do not knowingly collect personal information from children. If you believe that a child has provided us with personal information, please contact us and we will take steps to delete it.
14. Third-Party Websites and Services
The Platform may contain links to websites, applications and services operated by third parties. This Policy does not apply to those third parties, and we are not responsible for their privacy practices. We encourage you to read the privacy policies of any third-party service you use.
15. Changes to this Policy
We may update this Policy from time to time to reflect changes in our services, the law or our practices. When we make changes, we will publish the updated Policy on the Platform and update the “Last updated” date above. Where the changes are material, we will also notify you by email or through the Platform before they take effect.
16. Contact Us
If you have any questions about this Policy, or wish to exercise any of your rights, please contact us:
The Data Protection Officer, HerVest For Women Limited, No. 23 Hughes Avenue, Yaba, Lagos State, Nigeria.