APICES FINANCE
Partnership for Prosperity
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Privacy Policy

APICES FINANCE COMPANY LIMITED

DATA PRIVACY POLICY

Effective Date: March 10, 2026

1. Introduction
Apices Finance Company Limited ("Apices Finance," "we," "us," or "our") is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you interact with our services, visit our offices, use our website, mobile applications, or engage with us through any channel.
We are dedicated to maintaining the highest standards of data protection in compliance with the Nigeria Data Protection Act (NDPA) 2023, Nigeria Data Protection Regulation (NDPR), and other applicable laws and regulations.
By using our services or providing us with your personal information, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy.

2. Information We Collect
We collect various types of information to provide and improve our financial services to you.
2.1 Personal Information
We may collect the following personal information:

Identity Information: Full name, date of birth, gender, photograph, signature, and government-issued identification numbers (e.g., National Identity Number, Bank Verification Number, International Passport, Driver's License)
Contact Information: Residential and business addresses, email addresses, telephone numbers
Financial Information: Bank account details, income information, employment details, credit history, loan repayment records, asset and liability information
Transactional Information: Details of financial products and services you have obtained from us, transaction history, account balances

Biometric Information: where applicable and with your consent, fingerprints or facial recognition data for identity verification
Documentary Information: Utility bills, tax identification, business registration documents, certificates of incorporation, references

2.2 Information Collected Automatically
When you use our digital platforms, we may automatically collect:

Device information (IP address, browser type, operating system)
Usage data (pages visited, time spent, features accessed)
Location data (with your permission)
Cookies and similar tracking technologies

2.3 Information from Third Parties
We may receive information about you from:

Credit reference bureaus and credit rating agencies
Fraud prevention agencies
Identity verification services
Business partners and service providers
Publicly available sources
Guarantors and referees you provide


3. How We Use Your Information
We use your personal information for the following purposes:
3.1 Service Delivery

Processing loan applications and credit assessments
Opening and managing accounts
Providing financial products and services
Processing transactions and payments
Managing collateral and security interests

3.2 Legal and Regulatory Compliance

Complying with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations
Fulfilling regulatory reporting obligations
Responding to lawful requests from regulatory authorities
Preventing and detecting fraud, money laundering, and financial crimes
Enforcing our terms and conditions

3.3 Business Operations

Assessing creditworthiness and managing credit risk
Conducting internal audits and quality assurance
Developing and improving our products and services
Training our staff
Managing our relationship with you

3.4 Communication and Marketing

Sending account statements and transaction notifications
Providing customer support
Informing you about new products, services, and promotional offers (with your consent)
Conducting customer satisfaction surveys

3.5 Legal Basis for Processing
We process your personal information based on:

Contractual necessity: To fulfill our obligations under agreements with you
Legal obligation: To comply with applicable laws and regulations
Legitimate interests: To operate our business, prevent fraud, and improve our services
Consent: Where you have given explicit permission for specific processing activities


4. How We Share Your Information
We may share your personal information with third parties in the following circumstances:
4.1 Service Providers
We engage trusted third-party service providers to perform functions on our behalf, including:

Credit bureaus and rating agencies
Debt collection agencies
Payment processors
Technology and IT service providers
Legal, accounting, and consulting professionals
Marketing and communication services

4.2 Regulatory and Legal Authorities
We may disclose your information to:

Central Bank of Nigeria and other financial regulators
Nigeria Deposit Insurance Corporation (NDIC)
Law enforcement agencies
Courts and tribunals
Tax authorities
Nigerian Data Protection Commission (NDPC)

4.3 Business Transfers
In the event of a merger, acquisition, reorganization, or sale of assets, your information may be transferred to the relevant parties, subject to confidentiality obligations.
4.4 Credit Reference Agencies
We share information with credit reference bureaus to assess creditworthiness and manage credit risk. This information may be accessed by other financial institutions for similar purposes.
4.5 With Your Consent
We may share your information with other parties when you have provided explicit consent for such disclosure.
We do not sell your personal information to third parties for marketing purposes.

5. Data Security
We implement robust technical, physical, and administrative security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

Encryption of sensitive data in transit and at rest
Secure data centers with restricted physical access
Firewalls and intrusion detection systems
Regular security assessments and vulnerability testing
Staff training on data protection and confidentiality
Access controls limiting data access to authorized personnel only

However, no method of transmission or storage is completely secure. While we strive to protect your information, we cannot guarantee absolute security.

6. Data Retention
We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Retention periods vary depending on:

The nature of the information
The purpose for which it was collected
Legal, regulatory, and contractual requirements
Legitimate business needs

When personal information is no longer needed, we will securely delete or anonymize it in accordance with our data retention policy and applicable regulations.

7. Your Rights
Under the Nigeria Data Protection Act 2023 and other applicable laws, you have the following rights:
7.1 Right of Access
You have the right to request access to the personal information we hold about you and obtain a copy of such information.
7.2 Right to Rectification
You may request that we correct any inaccurate or incomplete personal information.
7.3 Right to Erasure
You may request the deletion of your personal information where there is no compelling legal or business reason for its continued processing.
7.4 Right to Object
You have the right to object to the processing of your personal information for direct marketing purposes or where we rely on legitimate interests as the legal basis.
7.5 Right to Restrict Processing
You may request that we restrict the processing of your personal information in certain circumstances.
7.6 Right to Data Portability
You have the right to receive your personal information in a structured, commonly used, and machine-readable format and transmit it to another data controller.
7.7 Right to Withdraw Consent
Where we process your information based on consent, you may withdraw your consent at any time without affecting the lawfulness of processing before withdrawal.
7.8 Right to Lodge a Complaint
You have the right to lodge a complaint with the Nigeria Data Protection Commission if you believe your data protection rights have been violated.
To exercise any of these rights, please contact our Data Protection Officer using the contact details provided in Section 12.

8. Cookies and Tracking Technologies
Our website and mobile applications may use cookies, web beacons, and similar technologies to enhance user experience, analyze usage patterns, and deliver personalized content.
8.1 Types of Cookies We Use

Essential Cookies: Necessary for the operation of our platforms
Performance Cookies: Help us understand how visitors interact with our platforms
Functionality Cookies: Remember your preferences and settings
Marketing Cookies: Used to deliver relevant advertisements (with your consent)

You can manage your cookie preferences through your browser settings. However, disabling certain cookies may affect the functionality of our platforms.

9. Third-Party Links
Our website and communications may contain links to third-party websites, applications, or services. We are not responsible for the privacy practices or content of these third parties. We encourage you to review their privacy policies before providing any personal information.

10. Children's Privacy
Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If you believe we have inadvertently collected information from a child, please contact us immediately so we can delete such information.

11. International Data Transfers
While we primarily operate within Nigeria, there may be circumstances where your personal information is transferred to, stored, or processed in jurisdictions outside Nigeria. When such transfers occur, we ensure appropriate safeguards are in place to protect your information in accordance with applicable data protection laws.

12. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data protection practices, please contact us:
Data Protection Officer
Apices Finance Company Limited
No. 1 Touggourt Street, Off Accra street, Wuse Zone 2, Abuja, Nigeria

Email: privacy@apicesfinance.com / dpo@apicesfinance.com
Phone: +234 803 069 1813
For general inquiries:
Email: support@apicesfinance.com
Website: www.apicesfinance.com

13. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. We will notify you of any material changes by posting the updated policy on our website and, where appropriate, through other communication channels.
The "Last Updated" date at the top of this policy indicates when it was most recently revised. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

14. Governing Law
This Privacy Policy is governed by and construed in accordance with the laws of the Federal Republic of Nigeria. Any disputes arising from this policy shall be subject to the exclusive jurisdiction of Nigerian courts.

15. Consent
By using our services, providing your personal information, or continuing to engage with Apices Finance Company Limited, you consent to the collection, use, and disclosure of your information as described in this Privacy Policy.
If you do not agree with this Privacy Policy, please do not use our services or provide us with your personal information.

Apices Finance Company Limited
Partnership for Prosperity
© 2026 Apices Finance Company Limited. All Rights Reserved.

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© 2026 APICES FINANCE COMPANY LIMITED. All rights reserved. RC8296128.

Licensed by the Central Bank of Nigeria.