Simi Cash iOS Privacy Policy

1. INTRODUCTION

CAREFREE TECHNOLOGY LIMITED ("we," "us," or "our") operates the Simi Cash iOS mobile application ("Simi Cash" or the "App"), a digital lending platform that provides short-term loan services to eligible individuals in Nigeria. We are committed to protecting your privacy and the security of your personal information.

This Privacy Policy explains how we collect, use, disclose, transfer, and safeguard information when you download, install, and use our App and related services. By using Simi Cash, you acknowledge that you have read, understood, and agreed to this Privacy Policy. If you do not agree, please do not use the App or our services.

This Privacy Policy is prepared in accordance with the Nigeria Data Protection Act 2023, applicable Nigerian data protection requirements, Apple App Store Review Guidelines, and other applicable laws.

2. WHO WE ARE

Simi Cash is operated by CAREFREE TECHNOLOGY LIMITED, a company duly registered and incorporated under the laws of the Federal Republic of Nigeria.

Product Name: Simi Cash
Company Name: CAREFREE TECHNOLOGY LIMITED
Registered Address: No 20, Wuse Zone 6 Abuja, Federal Capital Territory, 905102 Nigeria
Contact Email: carefreetechnologylimited@gmail.com

3. INFORMATION WE COLLECT

3.1 Personal Identifiers Provided by You

When you register for an account or apply for a loan, you may voluntarily provide:

• Full legal name, phone number, and email address
• Date of birth, gender, and residential address
• Bank account number and bank name
• BVN (Bank Verification Number)
• Selfie or photograph for identity verification

3.2 Device Information Collected Automatically

Our servers and integrated third-party SDKs may automatically collect:

• Device model (such as iPhone or iPad), iOS version, and build number
• Device identifiers, such as Identifier for Vendors (IDFV)
• Apple Advertising Identifier (IDFA), where you have permitted tracking
• IP address, mobile carrier, network type, and connection status
• Screen resolution, display density, language, and timezone settings

3.3 Location Information (Coarse / Approximate Location)

With your explicit prior permission, we may collect your approximate location to verify your residential address, prevent address-related fraud, tailor services to your region, and comply with applicable requirements. We do not collect precise GPS location or track your real-time location.

3.4 Network Data

With your explicit prior permission, we may collect network-related technical data, including your IP address, mobile carrier name, network type, and connection status, solely to:

• Protect the security and integrity of our services
• Detect and prevent fraud and abuse
• Diagnose connectivity issues and improve service performance

Please note: We do not collect the contents of your communications, calls, messages, or other private content through this network-related data.

3.5 Advertising ID

We collect your Apple Advertising Identifier (IDFA) only where you have permitted tracking and provided any required consent. It is used for marketing measurement, relevant in-app notifications, and fraud prevention. You can limit ad tracking or reset your Advertising Identifier through iOS privacy and advertising settings.

3.6 Camera and Photo Library Access

With your explicit prior consent, we may access your camera and photo library to capture facial photos for liveness verification and to upload photos voluntarily submitted through the in-app feedback feature.

3.7 Contact List (Emergency Contacts / Referees)

With your explicit prior consent, we access only the contact information for referees or emergency contacts that you specifically select and authorize for submission. We do not silently scan or collect your entire contact list.

3.8 Loan and Transaction Data

We collect information about loan applications, borrowing history, loan amounts, interest rates, repayment schedules, repayment behavior, and any defaults or disputes to process loans and disbursements, manage accounts, maintain credit history, make lending decisions, and improve credit assessment models.

4. HOW WE USE YOUR INFORMATION

• To provide loan services, including account management, application evaluation, disbursement, repayment processing, and loan notifications.
• For identity verification and KYC compliance, including facial recognition and cross-checking with credit bureaus and financial institutions.
• To prevent fraud and manage risk using device, location, and network data.
• To improve our services through in-app interaction analysis, testing, analytics, and research.
• For marketing communications, where you have consented.
• To comply with legal obligations and lawful regulatory or law-enforcement requests.

5. LEGAL BASIS FOR PROCESSING

Under the NDPA 2023, our legal bases include your explicit consent (for example, camera, photo library, location, and contacts permissions), performance of a contract, compliance with legal obligations, and legitimate interests that do not override your rights, such as fraud prevention, security, service improvement, and risk management.

6. DATA SHARING AND DISCLOSURE

• Third-party SDK providers that provide identity verification, notifications, analytics, attribution, and storage services.
• Financial institutions and payment partners for disbursement and repayment collection.
• Credit bureaus and reference agencies, with your consent, for credit reporting and anti-fraud purposes.
• Legal and regulatory authorities where required by law, court order, or regulatory direction.
• Business transferees in connection with a merger, acquisition, or asset sale; we will notify you by reasonable means.
• Other third parties where you have provided explicit consent.

7. THIRD-PARTY SDKs AND SERVICES

Dyna.Ai: Processes facial photos and device information for liveness detection, facial matching, and KYC.

AppsFlyer: Supports marketing attribution, campaign analytics, and fraud detection; it may process IDFA where permitted, installation source, in-app interaction data, and events.

AWS (Amazon Web Services): Securely stores facial photos uploaded for liveness verification, photos voluntarily submitted through the in-app feedback feature, application records, and backups.

8. DATA TRANSMISSION SECURITY

Personal data transmitted between your device and our servers is encrypted using industry-standard TLS/SSL. We also use measures including AES-256 encryption at rest, server-side cloud-storage encryption, strict access controls, and regular security assessments and penetration testing. No method of internet transmission or electronic storage is completely secure.

9. DATA RETENTION PERIODS

We retain personal information only for as long as necessary for the purposes described in this Privacy Policy, unless a longer period is required or permitted by law.

After the applicable period, we will securely delete, anonymize, or archive personal data in accordance with applicable law and our retention policy.

10. YOUR RIGHTS UNDER THE NDPA 2023

• Right of access to the personal data we hold about you.
• Right to rectification of inaccurate or incomplete data.
• Right to erasure where legal conditions are met.
• Right to restriction of processing in specified circumstances.
• Right to data portability in a structured, commonly used, machine-readable format.
• Right to withdraw consent without affecting processing before withdrawal.
• Right to object to certain automated decision-making and request human intervention.
• Right to lodge a complaint with Nigeria's National Data Protection Commission (NDPC).

11. AGE RESTRICTION

Simi Cash is not intended for individuals under 18 years of age. In line with Apple App Store Review Guidelines and applicable Nigerian laws, we do not knowingly collect personal information from persons under 18. If we become aware that such information has been collected, we will promptly delete it.

12. INTERNATIONAL DATA TRANSFERS

Simi Cash operates from Nigeria. Your data may be processed or stored in Nigeria and other countries where our third-party service providers operate. We use appropriate safeguards, such as data processing agreements incorporating approved standard contractual clauses, for international transfers.

13. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy to reflect changes in our practices, technologies, legal requirements, or operational needs. We will communicate material changes through an in-app notification, an updated “Last Updated” date, or publication of the revised policy on our website or in the App.

14. ACCOUNT DELETION

You may request deletion of your Simi Cash account and associated personal data by emailing carefreetechnologylimited@gmail.com with the subject line “Account Deletion Request.” We will verify your identity, initiate deletion within a reasonable timeframe, retain information where legally required, and notify you when the process is complete.

15. CONTACT US

For questions, requests, complaints, or concerns about this Privacy Policy or your personal data, please contact us:
Company: CAREFREE TECHNOLOGY LIMITED
Address: No 20, Wuse Zone 6 Abuja, Federal Capital Territory, 905102 Nigeria
Email: carefreetechnologylimited@gmail.com

By using Simi Cash, you confirm that you have read, understood, and agreed to be bound by this Privacy Policy.