1. Legal
2. Privacy Policy
3. Version 1.0 · Effective date 10 November 2026 · KUDIKRED NIGERIA LIMITED · Federal Republic of Nigeria

1. 1. About This Privacy Policy
2. KUDIKRED provides digital credit and related financial services through its mobile application, official website and designated customer-support channels. In delivering these services, we process information relating to people who browse our website, register accounts, complete verification, request credit assessments, apply for or manage loans, make repayments, or contact our support team.
3. This Privacy Policy (the “Policy”) explains what information is handled, how it is obtained, why it is needed, the parties to whom it may be disclosed, how long it may be kept and what choices are available to individuals. It covers the KUDIKRED mobile application (“App”), www.kudikred.ng (“Website”), customer-support communications and technical services used to operate the App and Website (together, the “Platform”).
4. The information needed from you depends on the function you choose. Identity checks, account access, credit decisions, loan administration and lawful record-keeping require certain information; other features, permissions and promotional communications may be optional. We provide additional notices or obtain consent where a particular processing activity requires them.
5. Please read this Policy alongside our Terms of Use and the loan details presented in the App before you confirm a loan. The loan details page explains the financial conditions applicable to that transaction, while this Policy explains how personal information is processed and protected. If you do not accept processing necessary for a requested service, that service may not be available.
6. 2. Responsible Entity and Coverage
7. 2.1 Responsible entity
8. The operator responsible for the KUDIKRED Platform and for determining the purposes and means of the personal-data processing described in this Policy is KUDIKRED NIGERIA LIMITED (“KUDIKRED”, “we”, “us” or “our”), a Nigerian company. Our services under this Policy are directed to individuals in Nigeria. Contact information is set out in Section 21.
9. A bank, payment institution, licensed credit bureau or other independent provider may process certain information as a separate data controller for its own regulated activities. In other circumstances, a technology or support provider acts on our instructions as a data processor. The role and responsibility of each party depend on the particular service and applicable law.
10. 2.2 People and interactions covered
11. This Policy covers people who browse public information on the Website, create or use an App account, provide employment or contact details, complete BVN or other KYC steps, submit an application, use the loan or transaction wallet, receive a notification, seek customer assistance or exercise a privacy right. It also applies to information obtained lawfully through service providers or official sources in connection with those activities.
12. You can browse general product information on the public Website without registering an App account. To use account-dependent features, you must provide the registration and verification information requested for those features. Where an optional profile photograph is offered, providing it is a choice and is not required merely to view public Website content.
13. 3. Information Relating to Your Identity, Account and Contacts
14. 3.1 Registration and profile details
15. We may process your name, telephone number, email address, date of birth, residential or contact address where requested, registration records, account identifiers, account preferences, login or verification status and, if you choose to provide one through an available feature, a profile photograph. A Nigerian mobile number and/or email address is needed for account registration and service communications, as indicated in the registration flow.
16. Account credentials and security records may include encrypted or protected password/PIN information, OTP request and validation logs, login times, password-reset records and information used to determine whether an account action was authorised. You should not disclose an OTP, password or transaction PIN to another person.
17. 3.2 Identity verification and employment information
18. For identity and eligibility checks, we may request your Bank Verification Number (BVN), other identification details where permitted, employment status, occupation, employer or business information, position, monthly income or salary information, and your regular salary payment date (payday). Such information is used in connection with the identity verification, credit assessment, affordability checks, legal obligations and existing service purposes described in this Policy.
19. 3.3 Two manually provided emergency contacts
20. When applying for a loan, you are asked to manually enter the names and telephone numbers of two emergency or trusted contacts. KUDIKRED does not access, copy or upload the contact list or address book stored on your device to obtain these details. Please provide information you are authorised to share and keep it accurate where updates are available.
21. We may use the two nominated contacts for relevant verification, risk management, account-servicing or emergency purposes. If we cannot reach you using your registered contact details, we may, where appropriate and permitted by law, contact a nominated person to help re-establish communication with you. We do not use emergency-contact information to send unrelated marketing communications to those contacts.
22. 4. Financial, Credit and Transaction Information
23. To assess and administer loans, we may process a linked Nigerian bank account, account-holder name, bank verification results, requested and approved credit amounts, credit-limit information, interest and service fees, disbursement instructions, repayment dates, outstanding principal or other charges, payment confirmations, repayment history, loan extensions where offered, wallet or transfer records and records of accepted transaction terms.
24. Loan-related information may also include an application outcome, payment reference, transaction time, repayment instruction, status of a pending or failed transfer, a complaint about a transaction and statements or receipts produced in connection with the loan. We may use these records to reconcile transfers, resolve accounting differences, administer an authorised repayment and respond to enquiries or disputes.
25. Where lawful and necessary, information used in a credit assessment may be checked against records supplied by licensed credit bureaus and identity-verification providers. These checks may produce credit information, eligibility indicators, identity-matching results, fraud-screening outcomes or risk scores. A displayed credit limit or indicative eligibility result does not itself guarantee that a particular loan will be approved.
26. Before you confirm a loan, the App displays the loan details applicable to that transaction, including the relevant financial terms. We may retain a record of the loan details shown and accepted, together with related confirmation and authentication records, to administer the agreed loan amount, charges and repayment terms and to address future queries or disputes.
27. 5. Technical Data, App Activity and Device Signals
28. When the App or Website is used, relevant systems may record the device type, model, operating-system name and version, App version, language and time-zone settings, screen characteristics, network connection information, IP address, device identifiers and application or browser event logs. Depending on the device and lawful technical availability, identifiers or signals may include Android ID, advertising identifiers such as IDFA, OpenUDID or MAC-related network signals.
29. We may record screens viewed, feature use, session times, interaction sequences, server logs, error messages, crash diagnostics and technical measurements generated by integrated software development kits (SDKs). These records help operate the Platform, identify failed steps, troubleshoot errors, measure performance, prevent unauthorised activity and improve the reliability of existing functions.
30. We may also use proportionate device and usage signals to identify suspicious logins, device manipulation, repeated registration attempts or potential account takeover. KUDIKRED does not request, scan, collect or upload an inventory of applications installed on your device. Use of advertising identifiers for permitted attribution remains subject to applicable consent and operating-system controls.
31. 6. Camera, Location and Other Device Permissions
32. 6.1 Camera-based identity checks
33. The App may request camera access when a selfie, facial comparison, liveness check or permitted identity-document capture is necessary for registration, verification or a loan application. The information generated may include a photograph, video frame, liveness result or identity-matching result. Camera access is requested for the relevant function rather than being enabled for continuous monitoring.
34. Camera or biometric verification information is processed for identity and anti-fraud purposes and may be handled by an authorised verification provider acting within an appropriate lawful arrangement. You can manage the permission in your operating-system settings; withdrawing access may prevent completion of the relevant verification step. Such information is not authorised for unrelated advertising or public disclosure.
35. 6.2 Approximate location only
36. Where authorised and relevant to eligibility, fraud prevention or the availability of a service in an area, we may use approximate geographic or area-level indicators obtained from permitted network or device signals. These may include city or region-level indications inferred from available network information, nearby wireless networks or cellular networks, or broad residence-area and travel-pattern indicators where specifically authorised. The ordinary lending service is not designed to rely on continuous precise GPS tracking.
37. Declining a location permission does not authorise us to bypass your device choice. Depending on the purpose of the relevant check, we may use information you provide directly or other lawful verification methods where available. Any permission requested by the App should correspond to a feature actually in use.
38. 6.3 Contact-list access
39. KUDIKRED does not request access to, extract or upload the full contact list stored on your device to obtain the two contacts described in Section 3.3. You enter their names and numbers manually. This is separate from our processing of the phone number you submit for your own registration, verification or service communications.
40. 7. Where Information Comes From
41. Information reaches us through three principal routes: details you submit directly; data created through ordinary use of the App, Website or notification systems; and information obtained lawfully from organisations that help verify identity, process a payment, provide credit information or protect the Platform. The source may differ at different stages of your relationship with us.
42. Direct submissions include registration details, BVN and bank information, employment and income details, your regular salary payment date (payday), two manually nominated emergency contacts, loan or extension requests, and information sent to customer support or in a complaint. System-generated information includes session and device records, notifications, transaction history, App diagnostic events and user confirmations.
43. Third-party information may come, as relevant, from banks, payment service providers, verification agencies, licensed credit bureaus, communications providers or providers of security and anti-fraud services. We seek to use information received from such sources for the disclosed service purpose, lawful compatible purposes or a separate purpose for which any required consent or notice has been given.
44. 8. Purposes and Legal Grounds of Processing
45. 8.1 Operating accounts and verifying identity
46. We process registration information and account security data to open an account, deliver or verify an OTP, authenticate a login, recover access, maintain account settings and establish the origin of an account instruction. Verification data, including BVN and appropriate facial checks, may be used to confirm identity, reduce impersonation and satisfy applicable KYC and due-diligence requirements.
47. 8.2 Assessing credit eligibility and setting terms
48. We use relevant identity, employment, income and regular salary payment date information, affordability, banking, repayment, verification, credit-bureau, device and fraud-related information to evaluate an application, determine a possible credit limit, identify further verification requirements, support credit-risk decisions and present the transaction-specific amount and charges on the loan details page in the App. Decisions may differ across applicants or transactions according to available information and applicable product rules.
49. 8.3 Servicing disbursements, repayments and wallet functions
50. For an accepted transaction, we handle necessary information to initiate disbursement through a bank or authorised payment channel, reconcile transfers, record the loan, display repayment obligations, process user-initiated or authorised automatic repayments, administer extensions where provided, address failed transactions, issue receipts and maintain the wallet or transaction channel. This does not turn a transaction wallet into a deposit or savings account.
51. 8.4 Customer support and communications
52. Information from customer-support interactions, notifications and transaction records may be used to answer questions, identify errors, investigate complaints, respond to suspected unauthorised access and give service updates. We may use your registered contact channels to communicate security alerts, account activity, loan status, disbursement information, payment reminders and other necessary operational messages.
53. 8.5 Security, abuse prevention and lawful recovery
54. We may examine proportionate account, payment, device and activity signals to prevent fraud, detect suspicious access, identify falsified information or protect service availability. For an overdue loan, relevant account and transaction information may be processed to communicate with the borrower, manage repayment arrangements, support lawful debt recovery and record related complaints or disputes.
55. 8.6 Operating and improving existing services
56. We analyse service feedback, crash diagnostics, feature-use patterns and aggregated performance information to troubleshoot technical errors, improve existing registration and payment flows, review notification delivery, monitor reliability and support legitimate service administration. Where suitable, information is aggregated, masked or de-identified before broader analysis.
57. 8.7 Legal obligations and legitimate claims
58. Records may be processed and retained for applicable consumer-protection, credit-reporting, data-protection, accounting, anti-money-laundering, fraud-prevention, regulatory-reporting, audit, investigation and dispute-resolution purposes. We may also process information to establish, exercise or defend legal claims when permitted by law.
59. 8.8 Legal bases and separate choices
60. As appropriate to the activity, processing may rely on performance of a contract, steps requested before entering a contract, compliance with a legal obligation, legitimate interests that are not overridden by applicable individual rights, protection of vital interests where relevant, or informed consent. A single basis does not necessarily apply to every category of information. Where a feature requires a separate device permission or consent, it will be requested through the applicable interface.
61. Withdrawal of consent affects processing that depends on that consent from the time of withdrawal. It does not automatically prevent us from processing information necessary to administer an outstanding loan, comply with a legal duty, resolve a dispute or protect account security under another lawful basis. Optional marketing consent is separate from essential service messages.
62. 9. Notifications, Authentication Messages and Marketing
63. 9.1 OTP and service communications
64. For account access and requested verification steps, KUDIKRED may send an OTP or similar security message to the telephone number you provide. Where supported in the relevant registration flow, the code may be delivered through SMS or WhatsApp. A requested authentication message is used to verify a user action, not to subscribe the user to promotional communications.
65. Operational communications may include application progress, disbursement confirmation, repayment dates, repayment reminders, wallet changes, account-security notices, service interruptions and legally required notices. Depending on the function and contact information available, these may be delivered by SMS, email, an in-App message, WhatsApp where available or push notification.
66. 9.2 Push notifications
67. If push notifications are enabled, we may use a device push token, preference settings, delivery status and relevant interaction information to deliver and assess service notifications. Apple Push Notification service (APNs) may deliver messages to iOS devices and Firebase Cloud Messaging (FCM) may deliver messages to Android devices. The notification token and information required for delivery may be made available to the relevant platform provider.
68. You can disable push notifications in device settings without losing access to the core lending service. Disabling this channel does not remove contractual repayment obligations or prevent necessary account information from being provided through another lawful communication channel.
69. 9.3 Promotional messages
70. Where a lawful basis exists and consent is required, promotional messages about products, offers or campaigns will be sent only after the relevant permission is obtained. You may opt out using the unsubscribe method in a message, available App settings or customer support. Opting out of promotional messages does not stop authentication codes or necessary loan-service notices.
71. 10. Cookies and Integrated Technologies
72. The Website may use cookies and comparable browser technologies to maintain a session, remember preferences such as language settings, understand page use and protect against unusual activity. The App may use SDKs or similar software tools to support analytics, attribution, diagnostics, app stability, security, verification or notification delivery. Some tools are necessary for service operation; others may be subject to a separate choice.
73. Our integrated technologies include Tenjin for permitted advertising attribution and related measurement, Google Firebase Cloud Messaging (FCM) for push-notification delivery on Android, and Apple Push Notification service (APNs) for push-notification delivery on iOS. These services receive only information relevant to their stated functions, subject to the applicable settings, permissions and safeguards described in this Policy.
74. You may control cookies through browser settings and tracking or device permissions through the relevant operating-system controls. Restricting technologies used for essential security, session management or verification may affect those particular functions. We do not treat browser or SDK settings as permission to collect information prohibited by applicable app-store rules.
75. 11. Organisations That May Receive Information
76. 11.1 Financial and payment service providers
77. We may disclose the information needed to verify an account, arrange a disbursement, receive a transfer, process an authorised repayment, perform reconciliation or investigate a payment issue to banks and duly authorised payment service providers. Such disclosures may involve an account identifier, beneficiary details, loan or transfer references, payment status and amounts relevant to the service.
78. 11.2 Verification and credit-information providers
79. Verification partners may receive limited identity details needed to check BVN, documents, facial or liveness results and other permitted KYC factors. Licensed credit bureaus may receive information necessary for a lawful enquiry or loan-performance report and may provide credit-related records used in an assessment. Such exchanges are limited by the relevant service, laws and authorised purposes.
80. 11.3 Technology, infrastructure and communications providers
81. Cloud or hosting providers, fraud-prevention and security vendors, analytics and attribution providers, customer-support suppliers, messaging or telecommunications partners and notification delivery services may process information that is necessary to perform contracted or otherwise lawful functions. We seek to restrict access by role, purpose and relevant contractual obligations.
82. We describe identity-verification partners, licensed credit bureaus, banks, payment service companies, collection service providers, cloud or infrastructure providers and communications services by their service categories rather than publishing a full vendor list. For the specific integrations identified in this Policy, Tenjin supports permitted advertising attribution, while Apple APNs and Google Firebase Cloud Messaging support push notifications on the relevant devices. Not every provider receives every type of personal data.
83. 11.4 Loan servicing and authorised recovery
84. If a loan is overdue, we may make limited necessary information available to an authorised collection or servicing provider. This may include the borrower’s identity and direct contact details, loan amount and dates, sums outstanding, repayment history, relevant communication records and case-management details. The recipient must use the information for lawful recovery or servicing, not for harassment, indiscriminate third-party disclosure or unrelated promotional purposes.
85. 11.5 Authorities and legal processes
86. Where required or permitted by law, we may disclose relevant information to a court, law-enforcement agency, regulator or competent authority, including in response to a lawful request or investigation. We seek to verify the authority and scope of the request and to disclose only information reasonably connected with that authorised purpose.
87. 11.6 Corporate changes and protected disclosures
88. In connection with a lawful merger, acquisition, financing, reorganisation or transfer of a relevant business or asset, information may be disclosed or transferred to the extent necessary and permitted by law. We will require appropriate continuing protection and provide further notice or obtain consent where the change gives rise to that obligation.
89. 11.7 Controls governing sharing
90. We do not sell personal data as a standalone product. We seek to disclose only information relevant to a documented service or legal purpose, and require service providers processing personal data on our behalf to apply confidentiality, security and data-protection safeguards providing the same or equivalent protection described in this Policy, as applicable to their services. A third party may not use information for unrelated purposes merely because it has received it through an integration.
91. Consent is obtained where required. Other disclosures may be lawful without an additional consent request where necessary to perform a contract, comply with a legal obligation, protect vital interests, respond to lawful authorities or establish or defend legal claims, subject in each case to applicable Nigerian law. Information that is genuinely anonymised and cannot reasonably identify an individual may be used or shared outside the rules applicable to identifiable personal data.
92. 12. Credit Bureau Reporting and Automated Assessment
93. In evaluating applications and managing credit risk, KUDIKRED may query duly licensed credit bureaus and consider relevant verification results, repayment behaviour, previous account activity, financial information and proportionate fraud or device signals. Where lawful, we may report loan performance, overdue balances or default information to a licensed credit bureau or competent authority.
94. An assessment may be supported by automated rules, statistical methods or scoring models that determine eligibility, a proposed limit, an additional verification requirement or loan pricing within existing product rules. Outcomes may include approval, decline, a lower available limit or a request for further verification. Where an individual has a right under applicable law to obtain information, challenge a decision or seek human review, the request can be made through our support channels.
95. Neither credit-bureau enquiries nor automated analysis authorises a provider to collect an unrelated category of personal data. Information used in assessments remains subject to the stated purposes, access controls and legal bases in this Policy.
96. 13. Data Storage and Cross-Border Transfers
97. At present, personal data collected through KUDIKRED is stored and processed in Nigeria and is not transferred outside the country. If an international transfer becomes necessary in the future, KUDIKRED will comply with applicable Nigerian law and obtain users' consent where required.
98. 14. How Long Records Are Kept
99. 14.1 Purpose-based retention
100. We keep information for the period reasonably needed to provide the requested service and for any additional period necessary for lawful accounting, audit, financial reporting, credit reporting, security, fraud prevention, repayment administration, complaints, investigations or legal claims. Different record categories may have different retention periods because they serve different purposes or are subject to different obligations.
101. 14.2 Loan and regulated financial records
102. Loan files, payment records, identity checks and relevant financial records may be subject to minimum preservation requirements under applicable Nigerian financial, anti-money-laundering, credit, accounting or other laws. Certain records may therefore be kept for at least five years where that period is applicable, or for a different legally required period. We do not treat the end of a loan or closure of an account as automatic permission to erase records that law still requires us to retain.
103. 14.3 Account inactivity and service closure
104. When an account is no longer used or a service ceases, information no longer needed for a valid purpose will be scheduled for deletion or anonymisation within a reasonable period. Active loans, unsettled transfers, account-security cases, disputes, legal holds, investigations and other required records may continue to be retained until the relevant basis for keeping them ends.
105. 14.4 Backups and deletion controls
106. Copies in backup or disaster-recovery systems may remain temporarily after deletion from active systems because of technical restoration cycles and applicable legal duties. Access to those copies is restricted, and they should not be used for new unrelated purposes. Copies will be overwritten, securely deleted or anonymised when the relevant backup cycle and lawful preservation requirements permit.
107. 15. Protecting Information and Responding to Incidents
108. 15.1 Technical and organisational safeguards
109. We use measures intended to protect personal information against unauthorised access, alteration, loss, disclosure or misuse. Depending on the systems involved, these include secure transmission, encryption at rest where appropriate, authentication controls, role-based access, logging, separation of sensitive data, masking or de-identification, security monitoring, supplier review and procedures for managing vulnerabilities or suspected incidents.
110. Personnel and contracted providers are expected to access personal information only to the extent required by their responsibilities and lawful service purposes. We assess suitable confidentiality and security obligations and review technical or operational controls as necessary. No internet-connected system can guarantee absolute security, so safeguards are reviewed as threats and systems change.
111. 15.2 Your part in account security
112. Keep your registered device, password, PIN and OTP secure; avoid sharing credentials with another person; and report suspected impersonation, SIM-swap, device loss or unauthorised account activity through customer support. KUDIKRED support staff should not request your OTP or secret transaction PIN for routine assistance.
113. 15.3 Personal-data incidents
114. When an incident involving personal information is identified, we assess its scope and likely impact, take reasonable containment and remediation steps, preserve relevant investigation records and notify competent authorities or affected individuals where required by law. Information provided in a notice may include the nature of the incident, affected information where known, possible consequences, steps taken and practical protective measures available to users.
115. Where a breach is likely to result in a risk to the rights and freedoms of individuals, notification to the Nigeria Data Protection Commission will be made within 72 hours of becoming aware of the breach, as required by the Nigeria Data Protection Act 2023. Where it is likely to result in a high risk to an individual, we will communicate with that person immediately as required by law, or use a legally permitted public notice when direct notice is not feasible.
116. 16. Rights and Choices Available to You
117. 16.1 Access, confirmation and copies
118. Subject to applicable law, you may ask whether we process personal information about you and request access to or a copy of relevant records. These may include account details, contact information, transaction and repayment records or other personal information held in connection with your account. We may need to verify your identity and may withhold information that would improperly reveal another person’s information or protected security controls. Where applicable, you may also object to certain processing, request that processing be restricted or request an eligible portable copy of your information, subject to legal conditions.
119. 16.2 Correction and completion
120. You may ask us to correct information that is inaccurate or incomplete. Because a loan account depends on verified identity, requests to change original BVN, identity or other material registration details may require additional checks before a correction can be completed. We may preserve an audit trail where a change is lawfully made.
121. 16.3 Deletion and limits on deletion
122. You may request deletion of information where it is no longer necessary, processing is unlawful, a valid withdrawal removes the only lawful basis for processing or another legally recognised ground applies. Deletion may be deferred or limited for outstanding loan obligations, unsettled payments, statutory retention, fraud investigations, disputes, legal claims or other purposes for which continued retention is legally permitted or required.
123. When we approve and carry out a valid erasure request, we will notify the service providers or other recipients to whom the relevant personal data was disclosed and request that they delete or de-identify it as appropriate, except where the recipient is legally required or otherwise lawfully entitled to retain the information. Where a recipient acts as an independent data controller, its own legal retention duties and applicable rights procedures may also apply.
124. 16.4 Withdrawing consent and permissions
125. You may withdraw an optional consent or change a device permission through the relevant App or device control, through the opt-out method in a promotional message or by contacting customer support. Withdrawal applies prospectively to processing that depends on the withdrawn consent and does not invalidate activities that were lawful before withdrawal.
126. 16.5 How requests are handled
127. Send a request through available App privacy or account settings or to contact@kudikred.ng. Include enough information for us to locate the account and understand the request, but do not send passwords or OTPs. We may seek identity verification, clarify the scope of the request, explain a legal reason for any limitation and give a response within the period required by applicable law.
128. 17. Account Closure and Deletion Requests
129. You can submit an account-deletion request directly in the KUDIKRED App using its account or privacy settings and, where the eligibility checks below are satisfied, complete the account closure within the App. We may use the App's authentication or identity-verification steps to confirm that the request is made by the account holder. Customer support remains available for enquiries, but contacting support is not a prerequisite to completing an eligible in-App deletion request.
130. An account may be deleted through the App when there is no outstanding loan principal, interest, fee or other amount owed to KUDIKRED; the wallet or transaction balance is zero; and no disbursement, repayment, transfer or other transaction remains pending. An unresolved payment dispute, chargeback, legal hold, ongoing investigation or another lawful restriction may also prevent completion until resolved. When these checks are passed, the App will complete the account closure and confirm the result to you.
131. Completed account closure ends access to the deleted account. Personal information no longer needed for a lawful purpose will be erased or de-identified, while records required for financial, accounting, anti-money-laundering, regulatory, security or legal purposes will be securely retained for the applicable period and then deleted or de-identified. Where a valid erasure request extends to information given to service providers, the notification and deletion procedure in Section 16.3 applies. If you later return to KUDIKRED, you may need to register again and complete the verification requirements then in force.
132. 18. Age Eligibility and Underage Applicants
133. KUDIKRED lending services are available only to applicants who are 20 years of age or older and otherwise meet the applicable eligibility requirements. We may use information provided during registration or identity verification to confirm age. We do not intentionally offer loans to persons under 20 or knowingly request information from them for the purpose of extending credit. If we identify an applicant or account holder below the required age, we may decline the application or restrict or close the account and handle any information already collected in accordance with applicable law and lawful record-retention obligations.
134. 19. Updates to This Policy
135. We may revise this Policy when existing services, operating processes, technology providers, legal requirements or security practices change. Material revisions will be communicated by an appropriate method such as an in-App notice, Website posting, email or SMS, and the version or effective date will be updated when the revision takes effect.
136. Where a change introduces a processing activity for which fresh consent is legally required, we will seek that consent rather than rely solely on continued use. Where permitted by law, continuing to use the affected service after receiving an effective notice may indicate acceptance of the updated Policy. If you do not agree with an essential change, you may need to stop using the relevant function while satisfying any existing obligations.
137. 20. Applicable Framework and Complaints
138. We process personal information with regard to the Nigeria Data Protection Act 2023 and applicable instruments and guidance administered by the Nigeria Data Protection Commission (NDPC), as well as relevant obligations under Nigerian consumer-protection, financial-services, credit, anti-money-laundering and other laws. The Federal Competition and Consumer Protection Commission (FCCPC) may be an appropriate authority for consumer-protection complaints connected with digital lending.
139. For account, privacy or transaction concerns, please first contact KUDIKRED through the Help Center or contact@kudikred.ng. State the problem and provide the information reasonably required to identify the account or transaction. We aim to investigate fairly, keep appropriate complaint records and explain the outcome or available next steps in a reasonable time or any period required by applicable rules.
140. If an issue remains unresolved, you may refer a privacy matter to the NDPC or an appropriate consumer-protection matter to the FCCPC in accordance with their applicable procedures. Nothing in this Policy removes any mandatory right to complain to an appropriate authority or seek a remedy provided by law.
141. 21. Contact and General Provisions
142. Brand: KUDIKRED
143. Platform operator and responsible entity: KUDIKRED NIGERIA LIMITED
144. Website: www.kudikred.ng
145. Privacy and customer-support email: contact@kudikred.ng
146. Applicable territory: Federal Republic of Nigeria
147. In this Policy, “Personal Data” means information relating to an identified or identifiable individual; “Processing” includes collecting, recording, using, storing, analysing, disclosing, transferring, restricting, deleting or anonymising such data; and “Service Provider” means a party providing a relevant function under a lawful arrangement. Headings are for navigation and do not limit the meaning of a clause.
148. If any provision is found unenforceable, the remaining provisions continue to apply to the extent permitted by law. If versions in more than one language are published and they differ, the English version intended for use in Nigeria prevails unless mandatory law requires otherwise. No part of this Policy excludes a right, protection or remedy that cannot lawfully be waived.

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