Effective Date: July 1, 2025
Last Updated: July 26, 2026

1) Scope

This policy applies to information collected through:

• The REAL Lending mobile application
• Related services and communications connected to the App

By using the App, you acknowledge that you have read and understood this Privacy Policy.

2) Information We Collect

We may collect the following types of information:

2.1 Personal information

• Full name
• Phone number
• Email address
• Other details you provide during account registration or profile updates

2.2 Identity and KYC information

To meet compliance and risk requirements, we may collect identity and verification information, including:

• BVN and/or NIN
• Supporting verification details or documents you submit

2.3 Employment and payroll-related information (where applicable)

• Information required to support employment-linked lending and payroll/HR-related services

2.4 Loan and transaction information

• Loan applications and supporting details
• Loan status, repayment schedules, and repayment records
• Transaction and payment references

2.5 Recruitment and job application information (where applicable)

• Profile details
• CV/resume uploads
• Job application submissions and related communications

2.6 Device and usage information

• Device type and operating system
• App activity and usage patterns
• Diagnostic and performance logs
• Device identifiers and similar technical data used for security, fraud prevention, and analytics

3) How We Use Your Information

We use your information to:

• Create and manage your account
• Verify identity and perform KYC/compliance checks (including BVN/NIN where required)
• Process loan applications and provide lending-related services
• Provide payroll/HR and recruitment features (where applicable)
• Communicate with you about your account, applications, repayments, and updates
• Improve the App, troubleshoot issues, and enhance user experience
• Prevent fraud, enforce our terms, and maintain security
• Comply with legal and regulatory obligations

4) Legal Basis for Processing (NDPR)

Where required under applicable law (including the Nigeria Data Protection Regulation (NDPR)), we process personal information based on one or more of the following:

• Your consent (where requested)
• Performance of a contract (to provide the App and requested services)
• Compliance with legal obligations
• Our legitimate interests (such as improving security, preventing fraud, and improving the App), provided those interests do not override your rights

5) Payments & Direct Debit

Where payments or repayments are required, REAL Lending may use third-party payment and direct debit providers such as Paystack and Remita (Direct Debit) to process card payments, bank transfers, and direct debit transactions.

Direct debit transactions require a mandate/authorisation. To set up and manage mandates and payments, we may share necessary transaction, payer, and mandate-related details with these providers.

REAL Lending does not store full card details on its servers where a third-party processor is used.

6) Sharing of Information

We may share your information:

• With service providers who support app operations (e.g., hosting, analytics, customer support), under confidentiality obligations
• With payment and direct debit providers (e.g., Paystack, Remita) to process transactions and manage mandates
• With verification, compliance, and risk partners where required to provide lending services and perform KYC checks
• With employers/partners where necessary for employment-linked verification and payroll-related processes (where applicable)
• When required by law, regulation, court order, or government request
• To protect the rights, safety, and security of users, our business, and the public

We do not sell your personal information.

7) Analytics and Performance Monitoring

We may use analytics and performance monitoring tools to understand how the App is used, improve features, and troubleshoot issues. These tools may collect device and usage information such as device identifiers, crash logs, and interaction data.

8) Data Security

We take reasonable administrative, technical, and physical measures to protect your information. However, no method of transmission or storage is 100% secure.

9) Data Retention

We retain information only as long as necessary for the purposes described in this policy, including compliance, dispute resolution, and enforcement of agreements, unless a longer retention period is required by law.

10) Your Choices and Rights

Depending on your location and applicable laws, you may have rights to:

• Access, update, or correct your personal information
• Request deletion of your account and certain data (subject to legal retention requirements)
• Withdraw consent where processing is based on consent

To make a request, contact us using the details below. We will respond within a reasonable timeframe and may require verification of your identity before processing certain requests.

11) Children’s Privacy

REAL Lending is not intended for individuals under 18. We do not knowingly collect personal information from children.

12) International Users

If you access the App from outside our primary operating regions, your information may be processed in countries where our service providers operate, subject to appropriate safeguards.

13) Changes to This Policy

We may update this Privacy Policy from time to time. We will post the updated version on this page and update the “Last updated” date.

14) Contact Us

• Email: Support@reallending.ng
• Phone/WhatsApp: +234 904 342 0796
• Website: https://www.reallending.ng

18. EFFECTIVE DATE

This Privacy Policy is effective from July 1st, 2025, and supersedes all previous versions.

ACKNOWLEDGMENT

By using our services, you acknowledge that you have read, understood, and consent to the practices described in this Privacy Policy.

REAL Recruitment Employment Agency Limited
July 1st, 2025