App Store Image  Maywood Lending

Privacy Policy

Privacy Policy

This Privacy Policy outlines how we collect, use, and disclose your information when you use our services, and provides information on your privacy rights and how the law safeguards them. If you disagree with our policies and practices, you have the option to refrain from using our services. For more details about Best Cash, please visit the “Privacy Policy” section on our official website. This policy may be updated periodically. If a specific product we offer has its own privacy policy or special provisions in the user service agreement, that product’s privacy policy will take precedence; otherwise, this policy will apply. We use your personal data to enhance and improve our services. By accessing or using our services, you agree to the collection and use of your information as outlined in this Privacy Policy.

This Privacy Policy explains how we gather, utilize, and share your personal information when you access our services. It also outlines your privacy rights and the legal measures in place to protect them. If you do not agree with our policies, you may choose not to use our services. For further details about Best Cash, please refer to the “Privacy Policy” section on our official website. Please note, this policy may be revised from time to time. If a specific product we provide includes its own privacy policy or distinct terms in the user service agreement, those terms will take precedence. Otherwise, this Privacy Policy will apply. We process your personal information to deliver and improve our services. By using our services, you consent to the practices described in this Privacy Policy.

Summary and Analysis of Privacy Policy

The privacy policy serves as a critical bridge between businesses and users, ensuring the protection of personal information. Its purpose is to clearly define the methods of collecting, using, and safeguarding user data. Below is an organized summary and analysis of the key elements and significance of the provided privacy policy:

1. Overview of Core Content

  1. Emphasis on User Privacy The policy begins by highlighting the company’s commitment to protecting user privacy, establishing a foundation of trust by clarifying the context and purpose of information collection.
  2. Collection and Use of Information It outlines the scope, methods, and purposes of personal information collection in various business scenarios while explaining the potential impacts of a user’s refusal to provide information. The emphasis on legality, legitimacy, and necessity ensures compliance and transparency.
  3. Rules for Information Sharing The policy specifies the conditions, scope, and security measures for sharing personal information with partners or third parties, highlighting the use of encrypted transmission and confidentiality agreements to reinforce responsibility and data security.
  4. Information Protection Measures By detailing technical measures (e.g., encryption, anti-attack mechanisms, access control) and internal management practices (e.g., employee training), the policy demonstrates a comprehensive and professional approach to safeguarding information.
  5. User Rights to Manage Information Users are given the rights to access, correct, delete their data, withdraw consent, and deactivate accounts. The policy provides clear contact channels and response timelines, ensuring transparency and respect for user autonomy.
  6. Scope of Policy Applicability The policy defines its applicability and outlines responsibilities when using third-party services. It advises users to review third-party privacy terms carefully to make informed decisions.

2. Key Elements Summary

  1. Transparency The structured and detailed content clearly explains each step of information handling, allowing users to understand the policy intuitively and build trust.
  2. Security The emphasis on dual-layer protection (technical and administrative) ensures robust security measures, enhancing the reliability of the policy.
  3. User Rights Protection The policy empowers users with comprehensive rights management options, offering flexibility and accessible support mechanisms.
  4. Legal Compliance The policy aligns with relevant data protection laws and regulations (e.g., GDPR), reflecting the company’s commitment to compliance and mitigating legal risks.

3. Importance Analysis

  1. Foundation of User Trust A well-structured and transparent privacy policy is vital for building user trust and fostering long-term relationships between users and the company.
  2. Assurance of Legal Operations With increasing regulatory requirements for data protection, a thorough privacy policy is essential for lawful operations and avoiding legal disputes.
  3. Enhancement of Brand Image Demonstrating a commitment to data privacy reflects the company’s sense of social responsibility, enhancing its reputation and competitive advantage.

Conclusion

A privacy policy is more than just a compliance document; it is a testament to the company’s responsibility. By clearly defining rules for data collection, use, and protection, the policy safeguards user rights and strengthens trust. This policy sets a commendable example in its clarity, organization, and adherence to legal standards, benefiting both the company and its users.

Table of Contents

  1. How We Collect Your Personal Information
  2. How We Use Your Personal Information
  3. How We Use Cookies and Similar Technologies
  4. How We Store, Share, Transfer, and Disclose Your Personal Information
  5. How We Protect Your Personal Information
  6. Your Rights
  7. How We Handle Personal Information of Minors
  8. How This Policy is Updated
  9. How to Contact Us
  10. Definitions of Key Terms in This Policy

1. How We Collect Your Personal Information

We adhere to the principles of legality, fairness, and necessity when collecting and using your personal information under this policy. The information collected includes data you provide voluntarily, data generated during your use of our services, and data obtained from third parties. If we need to use your personal information for purposes not stated in this policy or for purposes different from those initially intended, we will notify you appropriately and seek your explicit consent.

1.1 Categories of Personal Information

When using our services, we may ask you to provide the following categories of personal information to deliver a better experience:

  • Basic Information: Email address, full name, phone number, address (state, province, city, postal code).
  • Account Information: Bank account number, BVN (Bank Verification Number).
  • Additional Information: Usage data, date of birth, transaction history, and more.

1.2 Information Collection Channels

  • Information You Provide Voluntarily: This includes information you provide when registering, applying for services, filling out forms, participating in activities, submitting feedback, or contacting customer support.
  • Information Collected Automatically: Our systems automatically collect device information, access logs, and operation records when you use our website, app, or related services.

1.3 Information from Third Parties

If you grant us access to your third-party social media accounts, we may collect relevant information such as your name, email address, and activity data with your consent. You may also voluntarily share additional information through these accounts. By providing this information, you authorize us to use, share, and protect it in accordance with this Privacy Policy.

Through these diverse channels, we ensure that your personal information is collected only when lawful and necessary, aiming to enhance your user experience and provide services tailored to your needs.

1.4 Mobile Data Usage in the Application

To provide high-quality financial services and support anti-fraud systems, we may collect the following information with your consent:

  • Advertising ID:

    1. Collected during registration, login, and loan application processes to ensure online security, risk control, fraud prevention, and account safety.
    2. Device identifiers are used to optimize advertising campaign effectiveness.

  • Location: To enhance service quality and optimize user experience, we may collect location data with your consent:

  1. Service Personalization: Collected location information helps tailor services to your specific region, such as localized offers or financial solutions.
  2. Fraud Prevention: Location data is utilized to support security measures, ensuring compliance and preventing fraudulent activity.

Enabling this permission grants us access to location data only while the app is in use. You can disable this permission at any time, which will limit certain features but will not impact previously authorized data usage.

  • Photo: To improve your experience and streamline certain processes, we may request access to your photo library:
  1. Document Uploads: Enables you to upload required documents, such as identity verification or proof of income, directly from your photo library.
  2. Enhanced Features: Supports functionality like customizing your profile or saving transaction receipts.

Access is limited to the files you explicitly select, and no other photos will be accessed without your consent. You can revoke this permission at any time, which may disable related features.

We only request necessary device permissions and will clearly explain their purpose when requested for the first time. If business functions are adjusted, the requested permissions will also be updated accordingly. Enabling permissions indicates your consent for us to collect information to provide the corresponding features. Disabling permissions will be considered a withdrawal of consent, and we will cease collecting your information while being unable to offer those specific features. Previous operations under your authorization will not be affected.

2. How We Use Your Personal Information

To comply with national laws, regulations, and regulatory requirements, while providing high-quality services and ensuring the security of your account and funds, we use your personal information in the following ways:

2.1 Achieving the Purposes Stated in This Policy

We use your personal information to fulfill the purposes outlined in the section “What Information We Collect,” ensuring the smooth operation of relevant functions and services.

2.2 Ensuring Service Security and Stability

Your information is utilized for the following purposes:

  • Identity Verification: Ensuring you are an authorized user and preventing unauthorized access.
  • Security Measures: Monitoring abnormal behavior, preventing fraud, and addressing illegal activities.
  • Risk Management: Identifying potential risks and mitigating any adverse effects on you or us.
  • Archiving and Backup: Safeguarding data integrity and security to handle unforeseen circumstances.

2.3 Providing Service Notifications

We will send you service-related updates via SMS, email, or in-app notifications, such as account activity alerts, payment reminders, and other critical information, ensuring you remain informed about your account status.

2.4 Reporting to Relevant Authorities

In compliance with applicable laws and regulatory requirements, we may need to provide your information to government or regulatory bodies, such as for tax compliance, anti-money laundering, or legal obligations.

2.5 Customer Surveys and Service Improvement

To better understand your needs and enhance your experience, we may invite you to participate in customer satisfaction surveys or service feedback activities. Your feedback is invaluable to our improvements.

2.6 Enhancing and Optimizing Best Cash Services

Based on your usage patterns and feedback, we continually refine and optimize our products and services to improve user experience and maintain service excellence.

2.7 Processing Your Applications and Feedback

We ensure that any applications, inquiries, or feedback you submit regarding Best Cash products or services are addressed promptly and effectively.

2.8 Using De-identified Information for Analysis

After anonymizing your information through technical means (e.g., data de-identification), we may use such data for market analysis, product enhancement, or other commercial purposes without revealing your identity. De-identified information cannot be traced back to any individual.

2.9 Statistical Analysis and Trend Sharing

We conduct statistical analysis on the usage of our products and services. These statistics, which contain no personally identifiable information, may be shared publicly or with partners to demonstrate usage trends and showcase product value.

To protect your information, we use anonymization methods, such as content replacement, to display your personal data securely. Additionally, if we need to use your information for purposes not specified in this policy or for other purposes, we will provide detailed explanations and obtain your explicit consent beforehand. If you choose not to provide the required information, you may be unable to access specific services, but this will not affect your use of other services. These measures ensure that your information is used responsibly, transparently, and in compliance with legal requirements.

3. How We Use Cookies and Similar Technologies

We use cookies and similar technologies (such as web beacons and pixel tags) to ensure the proper functioning of the Best Cash website and enhance the service experience. Cookies help us provide products and services conveniently and allow you to manage or delete these files based on your preferences. We also track email clicks and user activities through web beacons and pixel tags to understand your preferences and improve services. If you do not wish for your activities to be tracked, you can unsubscribe or adjust your browser settings. We are committed to using these technologies only within the scope of this policy and respecting your privacy rights.

4. How We Retain, Share, Transfer, and Disclose Your Personal Information

4.1 Sharing

Despite our stringent confidentiality measures, there are certain circumstances where we may share your personal information without violating legal requirements. However, we guarantee that your information will not be shared with any company, organization, or individual without your consent. Additionally, we ensure that any third parties receiving your personal information will adhere to strict confidentiality requirements and implement appropriate security measures. For sensitive personal data, we require all partners and third parties to use data desensitization, encryption, and other techniques to protect your information adequately.

  1. With Your Explicit Consent: We may share necessary personal information with other data processors if you provide explicit consent in advance. The information shared will be limited to what is necessary for a specific purpose, and we will ensure that third parties also follow confidentiality measures to protect your data.
  2. Legal and Regulatory Requirements: If required by laws, regulations, or judicial processes, we may be compelled to share your personal information with relevant authorities. In such cases, we will disclose your personal data only as mandated by law and within the scope required.
  3. Industry Association Disclosure: With your prior consent, we may share your personal information with legally established industry associations for lawful inquiries or use by relevant entities. This may include details such as your name, ID number, loan status, and performance. Additionally, within the legal limits, we may disclose information to protect the life, health, and property safety of you or other users.
  4. Credit Services: If you choose to use our credit services, we may share your personal information with our affiliates, cooperating loan institutions, credit enhancement institutions, and third-party service providers for data verification, credit assessment, and determining the feasibility and terms of the service. Only the necessary personal information will be shared, and all parties involved must handle your data according to this privacy policy. If the purpose or manner of processing your information changes, we will seek your renewed consent.
  5. Fulfilling Contractual Obligations: We may share your personal information to fulfill obligations under agreements between you and us, or between you and our partners (including online agreements or platform rules). The sharing will be limited to what is necessary for the fulfillment of contractual terms.
  6. Public Interest: In specific situations, based on legal requirements, we may share your personal information for the public interest. For example, in cases concerning national security, public health, or other significant public interest matters, we may disclose your information as required by law to assist relevant authorities in investigations or handling such matters.
  7. Other Authorized Sharing: In addition to the above scenarios, we may share your personal information in other ways as authorized by this privacy policy or other agreements. Any sharing will follow your privacy rights and comply with applicable laws to ensure your information is not misused or disclosed improperly.

Through these measures, we ensure that your personal information is used and protected responsibly, in alignment with legal requirements and in a manner that respects your privacy expectations. Our goal is to provide you with secure and efficient services while ensuring the highest standards of privacy protection.

4.2 Transfer

We may transfer your personal information only in the following specific circumstances:

  1. With Your Explicit Consent:

    • Upon obtaining your explicit consent, we may transfer your personal information to other personal information processors. These processors will use your information in accordance with the purposes you have authorized.

  2. Legal and Regulatory Requirements:

    • If required by laws, regulations, legal procedures, or mandatory administrative or judicial requests, we may share your personal information. In such cases, we will provide your information in the manner and to the extent required by the relevant laws or authorities.

  3. Corporate Transactions:

    • In the event of mergers, splits, acquisitions, asset or business transfers, or bankruptcy liquidation, your personal information may be transferred. We will:
      • Provide the recipient’s name and contact information;
      • Require the recipient to continue adhering to this privacy policy;
      • If the recipient changes the original purpose or method of processing your information, they must obtain your renewed authorization and consent;
      • If no recipient exists due to bankruptcy, we will delete your personal information.

4.3 Public Disclosure

We will only publicly disclose your personal information under the following circumstances: Firstly, with your explicit consent, we will disclose your specified personal information in the manner you have agreed upon; secondly, when required by law, legal procedures, litigation, or mandatory requests from government authorities, we may publicly disclose your personal information, but such disclosure will be limited to the data legally entitled to be obtained by law enforcement for specific investigative purposes, and we will require the requester to provide corresponding legal documents to ensure the request is legally justified.

4.4 Detailed Description of Situations Where Prior Authorization for Sharing, Transferring, or Publicly Disclosing Personal Information is Not Required Under Relevant Laws and Regulations:

  1. Fulfilling Legal Obligations: When related to fulfilling statutory obligations, prior consent is not required. For example, providing information to relevant government authorities for tax reporting, auditing, or other legal requirements.
  2. Ensuring National Security and Defense: Sharing or disclosing information directly related to national security or defense does not require prior authorization. For instance, providing data for national defense purposes during significant security threats.
  3. Protecting Public Safety and Major Public Interests: Situations involving public safety, public health, or significant public interests do not require prior consent. This includes responding to public health emergencies, natural disasters, or other crises to safeguard societal well-being.
  4. Assisting Criminal Investigations and Legal Enforcement: Information shared with public security authorities, judicial institutions, or other enforcement agencies for criminal investigations, prosecutions, trials, and the execution of judgments is exempt from requiring prior approval. For instance, providing evidence to support the identification of suspects or protect victims’ rights.
  5. Protecting Life, Health, and Property: In emergencies where it is challenging to obtain your explicit consent, sharing information necessary to protect your or others’ life, health, or property is permitted. Examples include contacting your family in the event of an accident or providing essential information during a medical emergency.
  6. Publicly Disclosed Information: Information you have voluntarily disclosed to the public, such as on social media or in news articles, can be shared or disclosed without additional authorization.
  7. Legally Disclosed Information: Personal information collected from legally disclosed sources, such as lawful news reports, corporate announcements, or government information disclosure platforms, does not require further consent for processing.

Regulations and Clarifications on Anonymized Personal Information:

  1. Definition of Anonymization: Anonymization refers to the process of using technical means to process personal information so that it cannot be directly linked to a specific individual and cannot be restored to its original form. For example, removing identifiable details from transaction records while retaining overall transaction trends for analysis.

  2. Usage Scenarios for Anonymized Data:

    • Data Analysis: Conducting market research or user behavior analysis while preserving user privacy.
    • Machine Learning and Technology Development: Training algorithms using anonymized data without compromising user confidentiality.

  3. Legal Protections for Anonymized Data: According to relevant laws, anonymized personal information is no longer considered personal information. Sharing, transferring, or publicly disclosing such data does not require additional notification or consent. Furthermore, data recipients are prohibited from attempting to re-identify anonymized information, and any violation will result in legal consequences.

Key Principles for Handling Personal Information Outside the Above Scenarios:

  • Legitimacy and Transparency: Any collection or use of personal information must comply with legal regulations, with clear disclosure of processing purposes to users.
  • Data Minimization: Only the minimum information necessary to achieve specific purposes should be collected, avoiding excessive data collection or misuse.
  • Security Measures: Necessary technical measures must be taken to protect all personal information from leakage, tampering, or unauthorized access.

5. How We Protect Your Personal Information

5.1 Data Security Measures

We place the utmost importance on the security of your personal information, making its protection our top priority. Through a variety of advanced technologies and comprehensive management measures, we ensure the safety of your information during storage, transmission, and usage:

Encrypted Storage and Protection

We utilize industry-leading encryption algorithms to encrypt your personal information during storage, ensuring that unauthorized access is prevented. Our security management system encompasses the development of security policies, optimization of data storage processes, and comprehensive design of network architecture to guarantee the highest level of data protection at the storage level.

Secure Transmission Technologies

To safeguard your personal information during network transmission, we employ advanced encryption technologies, such as Transport Layer Security (TLS). These measures ensure that your data cannot be intercepted or tampered with during transmission. Additionally, our browsing services support HTTPS, ensuring that you are always operating in a secure network environment.

Multi-Layered Data De-Identification

When using your personal information, we strictly adhere to the principle of data minimization and employ various de-identification techniques, including content replacement, hashing, and other anonymization methods. These measures ensure that even when data is used for analysis, display, or calculations, it remains secure and inaccessible to unauthorized parties.

Rigorous Security Testing and Defense Systems

We conduct regular, multi-level security checks to identify and mitigate potential risks:

  • White-Box Security Testing: Examining source code to identify and resolve vulnerabilities during system development.
  • Black-Box Security Testing: Simulating external attacks to evaluate the system’s defense capabilities and enhance its overall risk resistance.
  • Intrusion Detection and Prevention: Combining intelligent detection technologies with manual monitoring to identify and prevent potential attacks in real time, effectively protecting against malicious code intrusions.

Continuous Improvement and Monitoring Mechanisms

Our dedicated security team continuously optimizes security strategies and incorporates the latest technologies and tools to maintain the effectiveness of our protection systems. We also undergo regular third-party security certifications and audits to verify the reliability and robustness of our data protection capabilities.

With these multi-dimensional security measures, we are committed to providing you with a highly secure service environment. Your personal information will always be subject to comprehensive and rigorous protection. Safeguarding your privacy is not only our responsibility but also a core pursuit we strive to achieve.

5.2 Other Security Measures to Protect Personal Information

To better manage and standardize the storage and usage of personal information, we have implemented a comprehensive security framework that ensures data safety and compliance throughout the handling process:

Access Control

We strictly enforce data access permissions to ensure that only authorized personnel can access personal information.

  • Multi-factor authentication technologies (e.g., passwords, fingerprints, dynamic verification codes) are employed to enhance data access security.
  • All personnel with access to personal information are required to sign strict confidentiality agreements to prevent misuse or leakage of data.
  • Monitoring and auditing mechanisms are in place to track and review data access in real time, preventing unauthorized access and mitigating potential risks.

Security Audits

We conduct regular, multi-dimensional security audits to proactively identify and address potential threats:

  • Code security checks: Static and dynamic analysis technologies are used to thoroughly examine system source code, identifying and resolving vulnerabilities.
  • Data access log analysis: Access records are analyzed to identify anomalies and ensure the legality and traceability of data usage.
  • The results of these audits are used to continuously optimize security strategies, enhancing the overall protective capabilities of our systems.

Information Security Committee

To strengthen the management of personal information security, we have established a dedicated Information Security Committee and related sub-committees:

  • The committee is responsible for formulating, evaluating, and optimizing information security strategies and implementation plans.
  • Regular meetings are held to discuss emerging security risks and regulatory requirements, with timely measures adopted to address them.
  • The committee also oversees the execution of data protection mechanisms to ensure all measures comply strictly with laws and regulations.

Training and Awareness Enhancement

We emphasize the importance of building a security culture involving all employees by conducting systematic training to enhance awareness of personal information protection:

  • Regular security and privacy protection training sessions are conducted to inform employees about the latest security threats and countermeasures.
  • Practical case studies are analyzed to help employees understand the severe consequences of personal information leaks, raising vigilance and a sense of responsibility.
  • Customized security education courses are provided based on the roles and responsibilities of employees, ensuring that everyone incorporates data protection principles into their daily work.

Continuous Improvement and Technological Upgrades

In addition to the above measures, we continuously adopt advanced technologies and tools to enhance our existing security framework:

  • AI and big data analytics are leveraged to improve our ability to predict and mitigate potential risks.
  • We collaborate with third-party security organizations for regular external security evaluations, ensuring our measures comply with international standards and best practices.

Through these multi-layered measures, we are committed to creating a secure, transparent, and trustworthy personal information management system. This not only safeguards user data but also reflects our unwavering commitment to protecting the privacy and trust of our users.

5.3 Security Incident Response

Notification of Security Incidents

In the event of a personal information security incident, we will promptly notify you of the basic details of the incident, its potential impact, the measures we have taken or will take to address it, suggestions for mitigating risks, and the remedial actions available to you, as required by laws and regulations. Notifications will be sent through your registered contact methods, such as in-app notifications, SMS, phone calls, or emails. If it is difficult to notify each individual, we will use reasonable and effective methods to issue an announcement.

Response to Security Vulnerabilities and Network Attacks

We will promptly address system vulnerabilities, network attacks, virus infections, and network intrusion security risks. In the event of a network security incident, we will take appropriate remedial measures according to the emergency security plan and report to the relevant authorities as required.

Information Protection Responsibility

If our physical, technical, or managerial safeguards are compromised, leading to unauthorized access, public disclosure, alteration, or destruction of your information and resulting in damage to your legitimate rights and interests, we will strictly comply with the law and bear the corresponding responsibilities.

Communication Security Recommendations

The internet is not an absolutely secure environment, and communication methods such as email, instant messaging, and interactions with other users are not encrypted. We strongly recommend that you do not send personal information through these means and advise you to use complex passwords to help ensure the security of your account.

Limitations of Information Security

Despite our best efforts to implement technical security measures, due to technological limitations, the rapid development of the internet, and potential malicious attack methods, we cannot guarantee absolute information security at all times. Please be aware that the systems and communication networks you use to access our products and/or services may face security issues beyond our control. If you discover that your personal information, especially your account or password, has been compromised, you should contact us immediately.

5.4 Storage and Retention of Your Personal Information

We will retain your personal information only for the time necessary to fulfill the purposes outlined in this policy or as required by law. After your account is canceled, we will retain your information for one month, after which it will be deleted or anonymized. Upon termination of our services, we will cease collecting and using your information, except as required by law. If we terminate services or operations, we will notify you at least thirty days in advance and delete or anonymize your personal information after termination.

6. Your Rights

Best Cash places great importance on your concerns regarding personal information and, in accordance with relevant laws, regulations, and standards in Nigeria, strives to ensure your exercise of the following rights:

6.1 Right to Access and Review

Unless otherwise provided by laws and regulations, we strive to ensure that you can easily access and review your personal information when using our services. You can view and manage your account information in the following ways:

  1. Online Customer Service: In the Best Cash app, you can access the “Online Customer Service” feature through the “My -> My Customer Service” section. Here, you can query, modify, or manage your personal information. This feature allows you to view account details, contact customer service, and address any related issues.
  2. Bank Card Management: You can view and manage your bank card information, such as card number and bank name, through the “My -> Bank Card Management” section. This feature allows you to update your bank card details or remove any cards you no longer use.

If you are unable to access or review your information through the above methods, you can also contact Best Cash’s customer service hotline 2342018885167 for assistance on how to access and manage your personal information.

6.2 Right to Rectification

If you need to update your personal information or notice any errors in how we handle your personal information, you have the right to request corrections. You can contact customer service through the Online Customer Service feature in the Best Cash app, or reach out to Best Cash’s customer service hotline 2342018885167. Additionally, you may submit your rectification request via feedback or error reporting forms available within the app.

To ensure the security and accuracy of your personal information, before processing your request, we may ask you to verify your identity. This verification process helps us confirm that the request is made by you or someone authorized to act on your behalf. Once your identity is verified, we will promptly proceed with making the necessary corrections to your personal data. If there are any complications or further steps required, our customer service team will guide you through the process.

6.3 Right to Deletion

You have the right to request the deletion of your personal information under the following circumstances. Unless otherwise provided by laws and regulations, you can submit a deletion request by contacting Best Cash customer service 2342018885167, and we will respond within the time frame stipulated in Section VI, Article (VIII).

Circumstances for Deletion Requests:

  1. Purpose Achieved or No Longer Necessary: If the purpose for processing your information has been achieved, cannot be achieved, or is no longer necessary for achieving the processing purpose;
  2. Violation of Laws and Regulations: If we have collected or used your personal information in violation of laws and regulations;
  3. Violation of Agreement: If we have collected or used your personal information in violation of our agreement with you;
  4. No Outstanding Loans or Debts: If you have no outstanding loans or debts in Best Cash and withdraw your consent for the use of your information;
  5. Violation in Sharing or Transferring Information: If we have shared or transferred your personal information with third parties in violation of laws, regulations, or our agreement with you, and the data subject requests deletion, we will immediately stop sharing or transferring the information and notify the third party to delete it promptly;
  6. Violation in Disclosing Information: If we have disclosed your personal information in violation of laws, regulations, or our agreement with you, we will immediately stop disclosing the information and issue a notice requesting the relevant recipients to delete the corresponding information;
  7. No Longer Using Services or Account Cancellation: If you no longer use our products or services, or have canceled your account, or if we have terminated services and operations, or if the retention period has expired.

Deletion Process and Notifications

If we decide to comply with your deletion request, we will notify entities that have obtained your personal information from us to delete it promptly, unless otherwise provided by laws and regulations or those entities have obtained your independent authorization.

Deletion from Backup Systems

Please note that when you delete information from our services, it may not be immediately removed from our backup systems. However, it will be deleted during the next backup update.

To ensure the smooth operation of our services, each business function typically requires specific permissions and the collection of necessary personal information. We respect your privacy and make sure that you can manage your personal information and authorizations flexibly while using Best Cash services. You can always change the scope of your authorization, modify your consent, or withdraw your consent by contacting Best Cash customer service 2342018885167 or using the “Online Customer Service” feature.

  1. Stopping Relevant Services: When you withdraw authorization or consent, we will no longer be able to provide services related to the withdrawn authorization or consent. For example, if you withdraw consent to the Privacy Policy, you will no longer be able to access credit-related functions on the platform, such as applying for, increasing, or borrowing credit limits.
  2. Ceasing Processing of Relevant Personal Information: After withdrawing consent, we will stop processing the personal information related to the withdrawn authorization. However, your decision to withdraw consent will not affect the personal information processing activities that were carried out based on your prior consent.

Specific Scenarios:

  • Withdrawing Consent to the Privacy Policy: If you withdraw consent to the Privacy Policy, you will be logged out of the system and only able to access browsing pages. Since credit-related features rely on the authorization provided in the Privacy Policy, you will not be able to apply for new credit limits, increase existing ones, or borrow additional credit.
  • Outstanding Loans: If you have any outstanding loans, please note that to avoid overdue payments and potential negative impacts on your personal credit and life, withdrawal of consent to the Privacy Policy will not be supported until your debts are fully settled. Please ensure that your debts are cleared before proceeding.
  • Information and Credit Qualifications: Even if you withdraw consent to the Privacy Policy, the information you have already provided, as well as the credit service qualifications and benefits you have obtained, will not be affected. These will remain intact and continue to apply.

Withdrawing consent or changing the scope of authorization is your legitimate right based on personal needs. However, please understand that doing so may lead to the inability to continue receiving certain services or features. If you decide to withdraw consent, we advise you to fully understand all possible consequences, especially when there are outstanding loans or credit functions involved. We will make every effort to protect your personal information and process your data according to your preferences.

6.5 Right to Account Cancellation

You have the right to cancel your Best Cash account at any time to terminate all services we provide to you. After your account is canceled, we will stop collecting, using, or sharing personal information related to that account. You can cancel your account through the following methods:

  1. Through the App: In the Best Cash app, go to “My -> Account Settings -> Cancel Account” to proceed.
  2. Through Customer Service: Call the Best Cash customer service hotline 2342018885167 or contact us via Online Customer Service to request account cancellation.

After your account is canceled, we will no longer provide any services related to that account, and we will cease the collection and use of personal information associated with that account. However, please note that personal information you provided or generated during your use of Best Cash services must still be retained as required by laws, regulations, and regulatory requirements. During the retention period, we will comply with inquiries from authorized authorities.

Account Cancellation Processing:

  1. Identity Verification: To ensure the security of your account and prevent malicious actions, we will need to verify your identity. You may be asked to provide identity verification information to confirm your cancellation request.

  2. Eligibility for Cancellation: We will evaluate whether your cancellation request can be supported, especially in the following cases:

    • Outstanding Loans: If your account has outstanding loans, the cancellation may be restricted. You will need to settle any debts first to avoid negative impacts on your credit score.
    • Unresolved Disputes: If there are any unresolved disputes or issues with your account, we will assess whether the cancellation request can be processed, ensuring all related matters are properly handled.

  3. Processing Time: After submitting the cancellation request online, we will process your request and complete the account cancellation process within 15 business days.

Exceptions:

Although you have the right to request account cancellation, we may not be able to respond to your request immediately in the following situations:

  1. Legal and Regulatory Obligations: If the cancellation request involves legal obligations (e.g., data retention requirements), we may not be able to process it immediately.
  2. National Security and Public Interest: If the cancellation request involves national security, public safety, public health, or other significant public interests, legal or regulatory requirements may prevent us from processing it.
  3. Criminal Investigations and Judicial Procedures: If the account cancellation is related to an ongoing criminal investigation, prosecution, trial, or enforcement of judgments, we will suspend the cancellation until the legal procedures are completed.
  4. Malicious Intent: If we have sufficient evidence that you or others have malicious intent or are abusing rights in requesting account cancellation, we may refuse the request.
  5. Protection of Legal Rights: If the cancellation of your account harms your own or others’ major legitimate rights and interests, and it is difficult to obtain your consent, we may not process the cancellation request.
  6. Trade Secrets Protection: If your request involves the protection of trade secrets or other sensitive information, we may refuse to process the cancellation request to safeguard such information.

6.6 Other Personal Information Rights

Under the relevant Nigerian regulations, you may also have the following personal information rights under certain conditions: the right to copy and transfer your personal information, and the right to request an explanation of our personal information processing rules.

6.7 Responding to Your Requests

If you are unable to access, modify, delete your personal information, or change the scope of your authorization, or if you have any questions about how we collect, use, or protect your personal information, you can contact Best Cash customer service. To ensure security, we may require identity verification and other necessary evidence, and we will process your request within 15 working days.

We will make every effort to meet your reasonable requests, but we may refuse requests that are unfounded, require excessive technical means, or may affect the legitimate rights of others. For reasonable requests, we do not charge fees, but may charge for frequent or excessive requests.

According to laws and regulations, we cannot respond to requests in the following situations:

  1. When it is related to fulfilling legal obligations, national security, public safety, or significant public interest;
  2. When it is related to criminal investigations, prosecutions, trials, or legal proceedings;
  3. When there is evidence of malicious intent or abuse of rights that may harm others’ legitimate interests;
  4. When it involves trade secrets.

If we are unable to respond to your request, we will provide reasons within the specified timeframe.

7. How We Handle Minors’ Personal Information

Our products, website, and services are primarily aimed at adults, and we explicitly require that minors are not allowed to create user accounts without the consent of a parent or guardian. Minors are defined as individuals under the age of 18. To protect the privacy and safety of minors, we have implemented strict measures to ensure that personal information is collected from minors only with explicit parental or guardian consent.

When we collect personal information from minors with parental or guardian consent, we will only use the information within the legal boundaries and ensure that it is processed in compliance with relevant laws. We are committed to not using minors’ personal information for inappropriate purposes, such as advertising or unauthorized commercial activities. We will also not share minors’ information with third parties without explicit parental or guardian consent.

In any case, if we discover that personal information has been collected from minors without verifiable parental or guardian consent, we will take immediate action to delete the relevant information. We regularly monitor and review our data collection practices for minors to ensure compliance with laws and regulations, and take necessary steps to protect minors’ privacy and information security.

To further enhance protection for minors, we encourage parents or guardians to regularly review their minor children’s account activity to ensure their personal information is safe in the online environment. Additionally, we provide easy ways for parents or guardians to view, modify, or delete their minor children’s personal information, giving parents better control and management over their children’s data.

We understand that minors may lack sufficient judgment and protection while engaging online, so we remain committed to providing a safe and compliant online environment to safeguard minors’ rights and prevent any infringement of their privacy.

8. How This Policy Is Updated

(1) This Privacy Policy will be updated as our business evolves to provide you with better services. We will not reduce your rights under this Privacy Policy without your explicit consent. If there are updates to this Privacy Policy, we will give prior notice on the Best Cash platform and notify you of the changes through announcements, in-app messages, notifications, or other appropriate means. Please visit the platform in a timely manner to stay informed about the latest Privacy Policy.

(2) For significant changes to this Privacy Policy, we will also provide prominent notice, such as through a pop-up window or in-app message at the time of software updates or when you log in again.

Significant changes referred to in this policy include, but are not limited to, the following: a. Significant changes in our service model, such as changes in the purpose of processing personal information, the types of personal information processed, or the way personal information is used; b. Major changes in our ownership, such as changes due to mergers, acquisitions, or restructuring; c. Major changes in the primary recipients of personal information for sharing, transfer, or public disclosure; d. Significant changes in your rights to participate in the processing of personal information and how those rights can be exercised; e. Changes to the department responsible for handling personal information security, contact information, or complaint channels; f. When a personal information security impact assessment report indicates a high risk.

9. How to Contact Us

Contact Information: We have established a dedicated department and appointed a personal information protection officer. If you have any questions, comments, or suggestions regarding this policy or your personal information, please contact us using the following methods:

Our customer service department, along with the personal information protection department, will respond to your inquiry promptly.

Response Time: Generally, we will complete our response and verification process within 15 working days. If you are dissatisfied with our response, especially if our processing of personal information has harmed your legitimate rights and interests, you can seek a solution through the following external channels:

  • File a lawsuit with the competent court.
  • File a complaint or report to the relevant regulatory authorities.

Our team is committed to providing you with timely and efficient support and ensuring that your rights are fully protected.

10. Definitions of Key Terms in This Policy

For the purposes of this Privacy Policy, we have provided detailed definitions of relevant terms to ensure that you clearly understand how we handle your personal data and provide our services. Below is an expanded description of each term:

  • Account: Refers to the unique identity created for you on our platform, which allows you to access and use various services provided by Best Cash. Each account is associated with your personal information, usage records, and activity history, serving as the foundation for all your actions on the platform.
  • Affiliated Companies: These are entities that have common control with our company or are controlled by us. “Control” means owning at least 50% of the shares or other interests that influence the decisions of the company. Affiliated companies may include our partners, suppliers, or other entities with shared business objectives.
  • Application (App): Refers to the Best Cash App, developed by Maywoood Lending Ltd., which allows users to access our services through smartphones or tablets. The app provides features such as personal loans, credit services, and account management, enabling users to apply for loans and manage their accounts.
  • Company (We): Refers to the entity that provides all the services described in this Privacy Policy. We operate through Maywoood Lending Ltd., focusing on providing online lending services, financial solutions, and customer support. We are legally responsible for the collection, use, and protection of your personal data.
  • Cookies: We use cookies to enhance your user experience. These small files are stored on your device by the website, helping us understand your browsing habits, personalize your experience, improve service quality, and maintain login sessions. Cookies also help us analyze traffic, monitor advertising effectiveness, and achieve other business objectives.
  • Country: The primary geographical region where we provide services is Nigeria. The scope of data processing and privacy policies is primarily based on this region. We process and protect personal information according to Nigerian laws and regulations.
  • Device: Refers to any hardware device you use to access Best Cash services, such as smartphones, tablets, or personal computers. We collect information related to the device, such as its model, operating system, IP address, etc., to ensure compatibility and security of the service.
  • Personal Data: Refers to any information that relates to an identified or identifiable natural person. This includes but is not limited to your name, phone number, address, bank account information, etc. We are committed to protecting your personal data in accordance with privacy protection principles.
  • Services: Refers to all services provided by Best Cash, whether through the app, website, or other means. Our services include loan applications, credit management, customer support, and more, aimed at providing convenient financial services.
  • Service Providers: Refers to third-party companies or individuals authorized by us to assist in providing services or processing data. These service providers may include companies in technical support, payment processing, data analytics, and other specialized areas. We maintain strict partnerships with these third parties to ensure that your data is appropriately protected.
  • Usage Data: Refers to information automatically generated during your use of our services. This may include your browsing history, visit duration, device type, IP address, etc. This data helps us analyze user behavior and improve service quality and user experience.
  • Website: Refers to the official Best Cash website that can be accessed through the website. Through this website, you can obtain information about the company, products, and services, as well as apply for loans online. The website is also one of the primary channels for communication and support.
  • You: Refers to any individual or organization that accesses or uses Best Cash services. Whether you use our services via the mobile app, website, or other means, you are the subject of this definition.