Cashfilly — Privacy Policy

1. Scope of This Privacy Policy

1.1 WEALTHY-SUM TECH AND GLOBAL LTD (“Cashfilly”) is a licensed Digital Money Lender in Nigeria, duly authorized by the Federal Competition and Consumer Protection Commission (FCCPC). Acting as the data controller, we are responsible for the collection and processing of your personal information whenever you download and use the Cashfilly mobile application, hosted on the Apple App Store, or when you access our services through other official channels.

1.2 In certain circumstances, Cashfilly may also act as a data processor on behalf of another data controller with whom you have a contractual relationship. In such cases, Cashfilly will process your personal information strictly in accordance with that controller’s instructions.

1.3 For any questions or concerns regarding this Privacy Policy, please contact us at info@wealthy-sumtechandgloballtd.com.

1.4 Please read this Privacy Policy carefully to understand how we handle your personal data in compliance with the National Information Technology Development Agency Act (2007) and the Nigeria Data Protection Act (2023). By accepting this Privacy Policy and using Cashfilly, you acknowledge and consent to the processing of your personal information as described herein.

1.5 Cashfilly’s services are not intended for individuals under eighteen (18) years of age. We do not knowingly collect or process any personal data from minors.

2. Definitions

2.1 “Privacy Policy” refers to this document — the Cashfilly Privacy Policy — which explains how we collect, process, and protect personal information obtained from you through the Cashfilly App or website.

2.2 “Channel” refers to any system or medium provided by Cashfilly, including our mobile application and website, which enables you to access our services.

2.3 “Child” or “Children” refers to any individual below the age of eighteen (18).

2.4 “Consent” means your voluntary, explicit, informed, and unambiguous agreement, given by statement or affirmative action, permitting Cashfilly to process your data.

2.5 “Customer” or “User” refers to any natural person within Nigeria who uses the services provided by Cashfilly.

2.6 “Personal Data” refers to any information that can identify you, such as name, address, phone number, ID number, date of birth, gender, financial or transaction data, or any other personal attributes.

2.7 “Sensitive Personal Data” includes information relating to race, health, ethnic origin, religion, genetic or biometric data, property details, family status, or sexual orientation.

2.8 “Services” means the financial products and related services made available through Cashfilly or its authorized partners.

2.9 “We,” “Our,” or “Us” refers to WEALTHY-SUM TECH AND GLOBAL LTD and Cashfilly.

2.10 “You” or “Your” refers to the user or customer of Cashfilly.

4. The Personal Information We Collect

4.1 Categories of Data

Location Data (Approximate)
With your permission, Cashfilly may collect your approximate location. This helps us confirm your region, ensure compliance with local lending regulations, and enhance fraud prevention. We do not collect your precise location and never use location data for advertising or marketing purposes.

Identity Data
We may collect your name, date of birth, age, gender, religion, and identification number to verify your identity, assess your eligibility for financial services, and meet legal obligations.

Profile Data
We may collect details such as education, employment status, income level, marital status, and information you voluntarily provide through surveys. These details help us assess creditworthiness and personalize your experience.

Financial Data
We may collect your bank name, account number, and Bank Verification Number (BVN) to process loans, verify repayment ability, and comply with AML and CTF requirements.

Camera Permission
With your consent, Cashfilly may use your camera for liveness detection and identity verification (e.g., capturing a selfie or ID photo). We do not use the camera in the background or share captured images with third parties.

Emergency Contact Data
We may collect your emergency contact’s name, relationship, and phone number solely for verification or emergency purposes. We do not access your full contact list.

Device Data
We may collect information such as device model, OS version, IP address, network operator, Identifier for Advertisers (IDFA), and Identifier for Vendors (IDFV). This helps us improve app performance, prevent fraud, and maintain account security.

Identifier for Advertisers (IDFA)
Collected only if you consent via “Allow App to Track.” Used solely for fraud prevention and product optimization, never for third-party advertising. You may withdraw consent anytime in your device settings.

Usage Data
We may record account credentials, OTPs, and interaction history within the Cashfilly App to maintain security, process transactions, and enhance usability.

Third-Party Data
We may receive information from partners, credit bureaus, identity verification providers, and marketing affiliates to validate your data, perform credit scoring, and prevent fraud.

4.2 Additional Information

We may also collect additional information about you, your device, and your interactions with the App or other channels, as described at the time such data is collected.

4.3 Sources of Personal Data

4.3.1 Information You Provide
This includes information that you submit to us directly, or that you permit us to access within the Cashfilly platform—for example, by completing forms, contacting us through our website or official social media accounts, or providing data within the App.

4.3.2 Information Collected from Your Device
This includes information obtained through the permissions you grant while installing or using the Cashfilly App (e.g., device information, camera access, and location).

4.3.3 Third-Party and Public Sources
We may receive information about you from external partners, financial service providers, credit reference agencies, identity verification services, sanctions-screening providers, and publicly available databases, including:

Financial, profile, and transaction data from technology or financial partners (e.g., money service businesses);
Contact, financial, and transaction data from verification or credit agencies;
Identity and contact data from business partners and public sources.

4.4 Purpose of Collection

Cashfilly collects and processes your personal information to deliver financial services, comply with legal and regulatory obligations, and enhance product performance. We will not collect or share personal data without your explicit consent, except where legally required.

4.5 Failure to Provide Data

If you choose not to provide certain personal information requested by Cashfilly, we may be unable to provide you with our services.

4.6 Data Transmission

With your consent, personal data collected during App usage is securely encrypted and transmitted via https://api.cashfilly.com to Cashfilly’s servers. No information is transmitted when the App is idle or running in the background.

4.7 Data Confidentiality

We will never publicly disclose, sell, or use your personal data for any purpose other than those stated in this Privacy Policy.

5. Legal Basis for Processing

We process your data only where lawful, including:

When you give consent;
When necessary to enter or perform a contract;
To comply with legal obligations;
When required for our legitimate interests (e.g., risk management, fraud prevention), provided your rights are not overridden.

6. Use of Your Personal Information

6.1 Cashfilly may rely on automated decision-making and profiling technologies to determine certain outcomes in delivering its products and services. These determinations may occur without direct human involvement but always in line with applicable data-protection principles.

6.1.1 When you apply for a loan or related financial product, automated systems may analyze your submitted information to decide whether credit can be granted and under what conditions. This automation allows us to provide customers—especially those lacking a previous credit history or formal financial records—with quick, flexible, and customized lending services.

6.1.2 Our credit-assessment and underwriting engines employ advanced data-science and machine-learning techniques to evaluate your creditworthiness. The evaluation process is primarily algorithm-based, with limited or no manual review. These models may automatically conclude that you are ineligible for certain services or that your loan limit or term must differ. Each model is periodically reviewed and recalibrated to maintain accuracy, fairness, and freedom from bias.

6.1.3 To safeguard the platform and users, Cashfilly also utilizes automated mechanisms for detecting, preventing, and managing fraud. These systems may flag users whose activities resemble money-laundering behavior, deviate significantly from normal usage patterns, or indicate an attempt to conceal true identity. If the algorithms assess that a transaction or user presents a fraud risk, access to our services may be restricted or suspended.

6.2 Your Rights Concerning Automated Decisions

6.2.1 If an automated credit, underwriting, or fraud-detection process results in your application being declined—or if you are informed that you do not meet eligibility standards for a product—you may request a manual review by our underwriting team. To do so, please contact info@wealthy-sumtechandgloballtd.com. You also retain the right to object to automated processing of your personal information; however, exercising this right may prevent Cashfilly from being able to offer you its financial services.

7. Disclosures of Your Personal Data

7.1 By consenting to share your personal information with Cashfilly, you also authorize us to disclose such data to certain external entities for the legitimate purposes outlined in this Policy.

7.2 These external third parties may include, but are not limited to, the following:

7.2.1 Credit Reference Agencies and Related Institutions

Reputable credit bureaus and other authorized organizations from which we may obtain or to whom we may provide your consumer credit data. Shared information may include your repayment behavior, default records, and details about account openings or closures.

7.2.2 Regulatory and Law Enforcement Authorities

Local or international law enforcement bodies, regulators, or government agencies that may request access to your information in order to prevent, detect, investigate, or prosecute criminal or fraudulent activities.

7.2.3 Authorized Service Providers

Third-party vendors engaged by Cashfilly, such as external debt collection agencies or customer verification partners, who process data strictly under our instructions and in compliance with confidentiality agreements.

7.2.4 Agents and Affiliates

Authorized representatives or business partners of Cashfilly, including any entity that becomes a subsidiary or affiliate of WEALTHY-SUM TECH AND GLOBAL LTD, for legitimate business purposes related to service delivery and operational efficiency.

7.2.5 Professional Advisors and Legal Representatives

External experts engaged by Cashfilly, such as legal counsel, auditors, or consultants, as well as courts or arbitration panels, when required for legal, regulatory, or audit proceedings.

7.3 In the event that we reorganize our business — such as by selling, assigning, transferring, or merging part of our operations or assets — your personal information may be shared with the acquiring or merging entity. Should such a transaction occur, the new owner will continue to process your personal data in accordance with the principles outlined in this Privacy Policy.

8. International Transfers

8.1 The personal data collected by Cashfilly may be stored or processed outside the borders of Nigeria in jurisdictions where WEALTHY-SUM TECH AND GLOBAL LTD, its affiliates, or its authorized partners maintain data-processing facilities. This may include the use of secure cloud-storage or cloud-computing technologies.

8.2 Whenever we transfer your personal information beyond Nigeria’s jurisdiction, we ensure that it remains subject to an equivalent level of protection. To achieve this, Cashfilly implements appropriate contractual, organizational, and technical safeguards and requires all affiliated entities, employees, and service providers to follow the same data-protection standards when handling your personal information.

9. Data Governance and Security

9.1 Cashfilly maintains a comprehensive information-security management framework designed to preserve the confidentiality, integrity, and availability of all information assets. These controls are implemented in accordance with our corporate commitments, industry standards, and internationally recognized best practices.

9.2 If you create or are provided with login credentials — including a password or one-time password (OTP) — to access restricted sections of the Cashfilly App or its service channels, you are solely responsible for keeping those credentials confidential. You must not disclose your password or OTP to any third party. Cashfilly will never request such information from you under any circumstance.

9.3 We have established internal protocols to detect and respond to any suspected data-security incident. In the event of a confirmed personal-data breach, and where legally required, we will promptly notify both affected users and the appropriate regulatory authorities.

10. Data Retention

10.1 Cashfilly and its authorized representatives will retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, and for a reasonable period thereafter to complete product delivery and service obligations. In compliance with Anti-Money-Laundering (AML) and Counter-Terrorism-Financing (CTF) regulations, we are legally required to retain certain personal data for a minimum of five (5) years, regardless of any deletion request. We may also retain data (i) where necessary to satisfy legal requirements, (ii) where retention is permitted by law, or (iii) for the establishment or defense of legal claims. Once data is no longer required for the purposes collected, it will be securely deleted or anonymized, unless ongoing retention is required to meet legal obligations.

10.2 In some cases, we may irreversibly anonymize your personal information so that it can no longer be linked to you. Once anonymized, the data ceases to constitute personal information and may be used for any lawful business or analytical purpose without further notice.

11. Your Data Subject Rights

11.1 As a data subject, you are entitled to exercise the following rights concerning the personal information we hold about you:

11.1.1 Right to Information – You may request clear details about why and how your personal information is processed.

11.1.2 Right of Access – You may obtain a copy of the personal information we maintain about you and be informed of:

the purposes for which we process it;
the categories of personal data involved;
the recipients or categories of recipients to whom the data has been or may be disclosed;
where feasible, the expected storage period or the criteria used to define that period; and
where the data was not collected directly from you, any available information regarding its source.

11.1.3 Right to Object – You may object to the processing of all or part of your personal data, unless we can demonstrate compelling legitimate grounds that outweigh your interests or where such processing is required for legal claims or defense.

11.1.4 Right to Rectification – You may request correction or update of inaccurate, incomplete, or outdated information, subject to verification through supporting documentation.

11.1.5 Right to Erasure – You may request deletion of data that is inaccurate, excessive, unlawfully obtained, or no longer necessary for the purposes collected. This right does not apply where continued processing is required by law or for the establishment, exercise, or defense of legal claims.

11.1.6 Right to Data Portability – You may request a copy of your personal data in a structured, commonly used, machine-readable format, or ask that it be transmitted to another data controller or processor.

11.2 You may also request that we restrict the processing of your personal information in the following circumstances:

11.2.1 When verification of contested data accuracy is pending;
11.2.2 When processing is unlawful and you prefer restriction to deletion;
11.2.3 When the purpose of processing has been achieved but the data is still required for legal claims; or
11.2.4 When you have objected to processing and we are determining whether overriding legitimate grounds exist.

11.3 If our processing relies on your consent as the legal basis, you may withhold or withdraw that consent at any time. However, withdrawal of consent may limit or prevent us from providing certain services to you.

11.4 You, or an authorized representative acting on your behalf, may exercise any of these rights by contacting us at info@wealthy-sumtechandgloballtd.com. All requests will be subject to verification of identity and lawful review.

11.5 You may request closure and deletion of your Cashfilly App account either through the in-app feature or an external request link. Cashfilly reserves the right to decline such requests where verification is not possible, where loan obligations remain outstanding, where the account is under investigation, or where legal retention obligations apply. In accordance with Anti-Money-Laundering regulations, Cashfilly must retain customer information for at least five (5) years. Even after an account-deletion request, records such as identity and transaction information will be preserved until the end of the mandatory retention period.

12. Changes to This Privacy Policy and Your Duty to Update Us

12.1 This Privacy Policy is reviewed on a regular basis. Any amendments will be published on this page and, where appropriate, communicated to you through the Cashfilly App, our official channels, website, email, or SMS notification.

12.2 The accuracy of your personal data is essential. Please inform us promptly of any changes to your information during the course of your relationship with WEALTHY-SUM TECH AND GLOBAL LTD, so that our records remain current and accurate.

13. Contact Information

Customer Service
Email: info@wealthy-sumtechandgloballtd.com
Phone Number: +234 (0) 901 024 2138
Office: Lawson Street Okeira, Aguda Ikeja, Lagos Nigeria