Privacy Policy
This page is used to inform visitors regarding this privacy policy (the ‘Policy’) with the collection, use, and disclosure of Personal
Information if anyone decided to use our Service.
If you choose to use our Service, then you agree to the collection and use of information in relation to this policy. The Personal
Information that we collect is used for providing and improving the Service. We will not use or share your information with anyone
except as described in this Privacy Policy.
The terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, which is accessible at Palmcredit
unless otherwise defined in this Privacy Policy.
Information Collection And Use
We collect several different types of information for various purposes to provide and improve our Service to you.
Types of Data Collected
Personal information
(i) Throughout this policy, we use the term "personal information" to describe information that can be associated with a specific
person and can be used to identify that person. We do not consider personal information to include anonymous information that does
not refer to a specific user.
(ii) We may collect and process the following types of personal information in order to provide you with access to our App and the
Services:
• We may ask to access your SMS permission for financial transactions, and related activity including One-time Password account
verification for financial transactions and fraud detection;
• personal data such as name, age, email address, phone number, physical contact information, personal description, photograph,
username, password, other registration information and (depending on the service used) sometimes financial information, such as
Bank Verification Number, credit card or bank account numbers;
• transactional information based on your activities on the App (such as products or service purchased, content you generate or that
relates to your account), billing, and other information you may have provided in connection with your orders;
• personal information you provide to us through information pages, correspondence, chats, complaints, customer service channels,
or provided to us from other social applications or services;
• additional personal information we ask you to submit as part of our verification process (for example, we may ask you to send us an
identification document or utility bill to verify your address, or to answer additional questions online to help us verify your identity);
• other supplemental information obtained from third parties such as demographic and navigation data, credit check information,
and additional information about you from a credit bureau, as permitted by law;
• information from your interaction with our App, services, content and advertising, including, but not limited to, device ID, device
type, unique device identifiers; geo-location information, computer, operating system and connection information, statistics on page
views, IP address and standard web log information;
• information stored on your device, including contact lists, call logs, SMS logs, Facebook friends, contact lists from other social
media accounts, photos, videos or other digital content;
• details of any of your visits to the App; including, but not limited to, traffic data, location data, weblogs and other communication
data.
(iii) This information may be provided or collected by:
• filling in forms on the App;
• corresponding with us (for example, by e-mail or chat);
• registering to use the App;
• subscribing to any of our Services;
• sharing data via the App’s social media functions;
• entering a competition, promotion or survey;
• reporting an issue with the App or our Services.
(iv) To comply with local Know Your Customer policy (authenticity or effectiveness or completeness of any client's identity materials),
we may dial someone in your contact list, SMS, call list or other personal information you provide to us. During the verification,we
will not leak your personal information to others.

Usage Data
When you access the Service with a mobile device, we may collect certain information automatically, including, but not limited to, the
type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the
type of mobile Internet browser you use, unique device identifiers and other diagnostic data ("Usage Data").
Tracking and cookies
(i) We may use mobile tracking technologies and/or cookies to distinguish you from other users of the App. This helps us to improve
the user experience on the App.
(ii) While you are free to decline our cookies if your browser permits, please note that doing so may interfere with your use of some of
our Services.
(iii) Please also note that:
• certain features are available only through the use of cookies;
• we use cookies to help identify you and maintain your signed-in status;
• most cookies are "session cookies" meaning that they are automatically deleted from your hard drive at the end of a session;
• you may encounter cookies from third parties, which are cookies from our service providers, that we have allowed on our App that
assist us with various aspects of our App operations and services;
• you may also encounter cookies from third parties on certain pages of the App that we do not control and have not authorised (for
example, if you view a web page created by another user, there may be a cookie placed by that web page).
Examples of Cookies we use:
• Session Cookies. We use Session Cookies to operate our Service.
• Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
• Security Cookies. We use Security Cookies for security purposes.
• Use of your information
(i) Our primary purpose in collecting personal information is to provide you with access to our App and our Services, and provide you
with a smooth and efficient experience. You agree that we may use your personal information to:
• calculate your credit limit and decide the amount that Transsnet may provide to you as a loan;
• provide you with access to the App, the Services and any customer support that you may request;
• resolve complaints and disputes, collect fees, and troubleshoot problems;
• prevent, detect, and investigate prohibited or illegal activities, and enforce our Terms and Conditions;
• customise, measure, and improve our contents, advertising and Services;
• inform you about our Services, deliver targeted marketing, service updates, and promotional offers based on your communication
preferences;
• compare information for accuracy, and verify it with third parties;
• contact you using the telephone numbers you have provided as authorised by our Terms and Conditions;
• provide you with other services requested by you as described when we collect the information.
(ii) We may associate any category of information with any other category of information and may treat the combined information as
personal information in accordance with this Policy for as long as it is combined.

Transfer Of Data
• Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state,
province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
• If you are located outside China and choose to provide information to us, please note that we transfer the data, including Personal
Data, to China and process it there.
• Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
• Palmcredit will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy
Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place
including the security of your data and other personal information.

Disclosure of your information
(i) We may disclose personal information in order to respond to legal or regulatory requests, enforce our policies, or protect anyone's
rights, property, or safety. Such information will be disclosed in accordance with applicable laws and regulations.
(ii) We may disclose your personal information to any member of our group (which means our subsidiaries, affiliates, our holding
company and its subsidiaries) in order to provide joint content and services (for example, customer support), to help detect and
prevent potentially illegal acts and violations of our policies, and to guide decisions about their products, services, sites, applications,
tools and communications. These entities may use this information to send you marketing communications and you may unsubscribe
from their mailing list.
(iii) We may also disclose your personal information:
• to other business entities, should we plan to merge with or be acquired by that business entity in which case personal data held by
Transsnet about its customers may be one of the transferred assets. Should such a combination occur, we will endeavour to minimise
the changes to this Policy, however, we will notify you if there are changes to our privacy policy as a result of such acquisition, merger
or combination;
• to third parties in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the
prospective seller or buyer of such business or assets;
• to law enforcement agencies, governmental agencies, or other authorised third parties if we are under a duty to disclose or share
your personal data in order to comply with any legal or regulatory obligation or request; (for example, a request relating to a civil or
criminal investigation or alleged illegal activity or any other activity that may expose you or Transsnet to legal liability);
• to third parties in order to enforce our Terms and Conditions and other agreements or to investigate potential breaches; or for the
purpose of publishing statistics relating to the use of the App, in which case all information will be aggregated and made anonymous;
• to third parties to whom you explicitly ask us to send your information (or about whom we explicitly notify you and obtain your
consent before sending your information to such third parties;
• to credit bureaus. We may report information about your account to credit bureaus. Late payments, missed payments, or other
defaults on your account may be reflected in your credit report.
(iv) Save in compliance with an order of a Court, an Arbitral Panel, a Tribunal, an investigatory panel, or any other legal or regulatory
obligation, we do not disclose information about identifiable individuals to other parties, but we may provide them with anonymous
or aggregate information about our users.

Storage of your information
(i) The data that we collect from you may be transferred to, and stored at, a destination outside Nigeria. It may also be processed by
staff operating outside Nigeria, who work for us or for one of our suppliers. These staff members may be engaged in the fulfillment of
your requests on the App or the provision of Services to you. By submitting your personal data, you agree to the collection, transfer,
storage or processing of your personal data in the manner set out above. We will take all steps reasonably necessary to ensure that
your data is treated, stored and processed securely and in accordance with this Policy.
(ii) Where we have given you (or where you have chosen) a password that enables you to access certain parts of the App, you are
responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission
of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot
guarantee the security of your data transmitted to the App; any transmission is at your own risk. Once we have received your
information, we will use strict procedures and security features to try to prevent unauthorised access.
(iii) We expect that the personal information that you provide to us is accurate and up to date, and we will provide you with the
opportunity to update your information through your account profile settings. We retain information as long as it is necessary and
relevant for our operations. In addition, we may retain personal information from closed accounts to comply with the law, prevent
fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms and Conditions
and take other actions permitted by law.

Your rights
(i) We will use your data for the purposes of compiling statistics relating to our user base and may disclose such information to any
third party for such purposes, provided that such information will always be anonymous.
(ii) Should we wish to use your personal information for marketing purposes, we will inform you prior to such use. You shall be entitled
to prevent such usage by informing us, within 3 days of being informed of the proposed use, that you do not wish to disclose such
information in this manner. You can also exercise this right at any time by contacting us at email: Palmcredit.support@transsnet.com.
This does not, however, preclude us from using your information as part of anonymous or aggregate information for our marketing
purposes.
Security Of Data
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic
storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its
absolute security.
Service Providers
We may employ third-party companies and individuals due to the following reasons:
• To facilitate our Service;
• To provide the Service on our behalf;
• To perform Service-related services; or
• To assist us in analyzing how our Service is used.
We want to inform users of this Service that these third parties have access to your Personal Information. The reason is to perform the
tasks assigned to them on our behalf. However, they are obligated not to disclose or use the information for any other purpose.

Links to Other Sites
This Service may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external
sites are not operated by us. Therefore, we strongly advise you to review the Privacy Policy of these websites. We have no control
over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Children’s Privacy
These Services do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from
children under 13. In the case we discover that a child under 13 has provided us with personal information, we immediately delete this
from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please
contact us so that we will be able to do necessary actions.

Changes to This Privacy Policy
We may update our Privacy Policy from time to time. Thus, you are advised to review this page periodically for any changes. We will
notify you of any changes by posting the new Privacy Policy on this page. These changes are effective immediately after they are
posted on this page.
Contact Us
If you have any questions or suggestions about our Privacy Policy, do not hesitate to contact us by email:
Palmcredit.support@transsnet.com