LAST UPDATED IN MARCH, 2026

Privacy Policy

1. Introduction

Hello! We have created this Privacy Policy to describe your privacy rights with respect to the use of our Services.

SunFi Technology Solutions Limited ("SunFi", "we", "us", "our"), recognises the importance of privacy, the sensitivity of personal data, and the need to comply with applicable data protection laws, including the Nigeria Data Protection Act, 2023 (the "NDPA"), and the General Application and Implementation Directive, 2025.

This Privacy Policy explains how we collect, use, store, share and protect your personal data when you visit our website, mobile applications, digital platforms, products, financing services, and any other channels operated by us (the "Services").

By accessing or using our Services, you acknowledge that you have read, understood and consented to the terms of this Privacy Policy. You may withdraw your consent at any time, although such withdrawal may affect our ability to provide certain Services to you.

2. Legal Basis for Processing Personal Data

We process personal data based on the following lawful bases:

2.1.

Contractual necessity: to provide financing, process applications, coordinate installations, and deliver our Services.

2.2.

Legal and regulatory obligations: including identity verification (KYC), anti-money laundering and countering the financing of terrorism laundering requirements, credit reporting, tax and financial services compliance, and NDPC obligations.

2.3.

Legitimate interest: to protect the platform used for our Services, prevent fraud, improve user experience, conduct risk assessments, and maintain internal business operations.

2.4.

Consent: for specific activities that require your explicit permission (such as certain marketing communications). You may withdraw consent at any time, but withdrawal does not affect processing carried out under other lawful bases.

3. Data We Collect

SunFi collects personal data directly from you, automatically through your use of our Services, and from verified third-party sources. Data you provide may include:

3.1.

name, email address, phone number, date of birth, business or residential address;

3.2.

identification data such as National Identification Number and Bank Verification Number (BVN);

3.3.

3.4.

any other details you submit while interacting with us.

3.5.

Automatically collected data may include:

3.5.1.

Internet Protocol (IP) addresses, browser type, device details;

3.5.2.

pages viewed, time spent on our website, mobile platform, referral source; and

3.5.3.

cookies and general usage analytics.

We may also receive data from identity verification providers, open banking service providers, credit bureaus, financial institutions, payment partners, and other authorised third parties. Your BVN may be used for lawful purposes in compliance with Applicable Law.

4. How We Use Your Personal Data

SunFi uses your personal data to:

4.1.

verify your identity, conduct KYC, and assess creditworthiness;

4.2.

process financing applications and manage contractual obligations;

4.3.

coordinate installations and facilitate repayments;

4.4.

improve and personalise our Services;

4.5.

communicate with you and provide support;

4.6.

comply with regulatory obligations;

4.7.

prevent fraud, carry out risk analysis, and maintain internal business records; and

4.8.

conduct research and support customer service.

When you use repayment channels such as direct debit, virtual accounts or card payments, we process necessary financial information to complete transactions securely. We do not store your full card details or online banking credentials, as these are handled securely by approved payment partners.

5. Data Accuracy

We take reasonable steps to ensure that all personal data we collect, or process is accurate and up to date. Please notify us promptly when your information changes.

6. Other Data We Collect

We may collect additional technical and behavioural data when you utilise our Services, including your geographical location, operating system, access times, session behaviour and other analytics. We may also use cookies and similar tools to track your interactions with our website, personalise your experience, and enhance security. Please review our Cookie Policy here.

7. Data Confidentiality

Your personal data is treated as confidential and will only be shared as necessary under Applicable Law. While SunFi is responsible for safeguarding your data, you are also responsible for maintaining the confidentiality of your login details, securing your devices and ensuring that you interact only with authorised SunFi personnel.

8. Data Sharing and Disclosures

SunFi does not sell, trade or rent your personal data. We may disclose your data to third parties solely for the purposes outlined in this Privacy Policy. We may also share your credit data with licensed credit bureaux as required by regulation and industry standards. If legally required or necessary to protect life, property or the public, SunFi may disclose personal data to regulatory authorities or law enforcement agencies. We will notify you, where practicable, before making such disclosures.

SunFi may engage third-party processors within Nigeria to assist in providing some services. All third-party processors operate under binding contracts requiring compliance with NDPA 2023 and implementation of appropriate security measures.

9. Transfer of Personal Data

SunFi does not transfer data outside Nigeria. However, if your personal data must be transferred outside Nigeria, SunFi ensures that such transfers comply with the requirements of Applicable Law. We will inform you if your data is transferred outside of Nigeria.

10. Your Rights

Under Applicable Law, you have several rights, including:

10.1.

the right to be informed about data processing activities;

10.2.

the right to access your personal data;

10.3.

the right to request correction or erasure;

10.4.

the right to restrict processing;

10.5.

the right to withdraw consent;

10.6.

the right to data portability; and

10.7.

the right to object to processing and request that we stop further dissemination of your data.

You are entitled to receive notification of any data breach affecting your personal data and may lodge a complaint with the Nigeria Data Protection Commission (the "NDPC"), if you believe your rights have been violated.

11. Data Security

SunFi is committed to ensuring that your data is secure. We implement physical, electronic and managerial safeguards such as encryption, firewalls, secure sockets layer (SSL) technology, role-based access, authentication controls and secure data storage to prevent unauthorised access, disclosure, modification or loss of personal data.

12. Training

SunFi ensures that employees who handle personal data receive adequate data protection training. We maintain an internal compliance framework and develop bi-yearly capacity-building programmes to ensure that our employees understand and comply with data protection obligations under Applicable Law.

13. Data Retention

We retain your personal data for as long as necessary to provide our Services, meet legal obligations, resolve disputes, prevent fraud, process transactions, verify data and comply with regulatory requirements. When data is no longer needed, we securely delete or anonymise it.

14. Data Breach Management Procedure

If a personal data breach occurs that is likely to result in a risk to your rights or freedom, we will take the following steps in accordance with Applicable Law:

14.1.

promptly assess the nature, scope and impact of the breach;

14.2.

notify the NDPC without undue delay and, where feasible, within seventy (72) hours of becoming aware of the breach;

14.3.

notify affected individuals as soon as practicable, especially where the breach is likely to cause significant harm;

14.4.

investigate the cause of the breach and determine the extent of the compromise;

14.5.

take immediate corrective and mitigating actions to contain the breach and prevent further incidents;

14.6.

address and resolve identified vulnerabilities, including implementing additional security measures where required; and

14.7.

document all breach-related activities and maintain records as required under Applicable Law.

15. Third-Party Links

Our Services may contain links to external websites. SunFi is not responsible for the content or privacy practices of third-party sites.

Please review their privacy policies before sharing personal data.

16. Limitation of Liability

While SunFi takes reasonable measures to safeguard your personal data, we are not liable for unauthorised access or disclosures caused by events beyond our control or by your failure to secure your login details, devices or communication channels. You are encouraged to take appropriate steps to protect your own data.

17. Updates to this Privacy Policy

We may revise this Privacy Policy from time to time. When updates are made, we will change the "Last Updated" date at the top of the Privacy Policy. Where a change materially affects your rights or how we process your personal data, we will provide additional notice as appropriate (e.g., website notice, in-app notification, or email).

We encourage you to review this Privacy Policy periodically.

18. Governing Law

This Privacy Policy is made pursuant to the the Nigeria Data Protection Act (NDPA) 2023 and the General Application and Implementation Directive 2025 and other laws, regulations or international conventions applicable in Nigeria to our Services, as may be amended or replaced from time to time (the "Applicable Law"). Where any provision of this Privacy Policy conflicts with a mandatory requirement of law, such law shall prevail to the extent of the inconsistency.

19. Contact Us

If you have any questions, comments or requests regarding this Privacy Policy or the handling of your personal data, please contact us at:

Email: [email protected]
Telephone: +2348022426861

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