PRIVACY POLICY
TENN Microfinance Bank Limited ("we", "us", "our" or "TENN") is totally committed to maintaining the accuracy, confidentiality, and security of your personally identifiable information ("Personal Information"). As part of this commitment, our Privacy Policy (the "Policy") governs our actions as they relate to the collection, use and disclosure of Personal Information.
When you sign up and use our mobile application, TENN CREDIT(via our website or Google Play Store), you accept the terms described within this Policy.
In this Policy "information" refers to any confidential and/or personally identifiable or other information related to users of TENN CREDIT services ("Services").
Our Service
When you register for TENN CREDIT, we will create an account for you on the TENN CREDIT platform/app:
• TENN CREDIT account will be active and ready to use for payments
• TENN CREDIT account will be activated only when you sign the our Terms and Conditions
The service enables you to send and receive money with internal and external customers, purchase airtime, and pay bills.
Information Which May Be Collected From You
A - Customer Information
To use the Services, you must provide customer information via our registration, account upgrade, or profile forms. This information includes, but is not limited to:
• Full name, e-mail address, and phone number.
• For some services, we may also collect your National Identification Number (NIN) and proof of address (where applicable).
B - Identity Verification Data
To meet the Central Bank of Nigeria (CBN) KYC requirements, we also collect:
• Legal information: Bank Verification Number (BVN), NIN;
• Identification proof: Photos of government-issued identification documents (for authenticity verification); and
• Biometric data: Dynamic face scan (specifically for liveness detection and anti-fraud, with original data deleted within 72 hours).
C - Credit Assessment Data
To provide credit services, we will process:
• Bank statements: Obtain account transaction records in read-only mode (retained for 36 months after loan settlement); • Credit reports: Retrieve historical credit records from CBN-licensed credit bureaus such as CRC (retained for 7 years by law); and • Income proof: Payslips and employer verification information (retained until the loan is fully repaid).
D - Device Information
The following information may be collected from you automatically when you use the TENN CREDIT , but is not limited to:
• Details of your handset/device, unique device identifiers (IMEI or serial number), information about the SIM card, mobile network, operating system, and browser settings.
E - Location Information
Certain TENN CREDIT features may require location information from your device's GPS. With your consent, this information will be collected for these services. You will be required to grant consent.
F - Analytics
We may use in-app analytics technologies, like Google Analytics, to help improve and simplify the overall app, design, and service. These tools track aggregated information about in-app usage, provide performance measurements, and allow better reporting on application failures. We record when you install or uninstall TENN CREDIT to help us track who is using the Service.
G - Tracking and Cookies
A cookie is a small computer file or piece of information that may be stored in your computer's hard drive when you visit our website. We may use cookies to improve our website's functionality and, in some cases, to provide visitors with a customized online experience.
We use cookies to help identify and track visitors, their usage of our website, and access preferences. You may change your Internet browser settings to prevent your computer from accepting cookies or to notify you when you receive a cookie so that you may decline its acceptance. Please note, however, if you disable cookies, you may not experience optimal performance of our website.
H - Prohibited Data Collection
We will never collect:
• Mobile device contact lists and call records; or
• Social media account information without explicit authorization.
Third Parties
We integrate with some third parties to provide you with an end-to-end Service, and these providers follow the practices outlined in this Policy. Our service providers are used to:
• Validate information about you, including credit rating agencies, mobile network providers, BVN validation services, and ID verification services (triggered based on the financial services you access); and
• Process your payments, including banking, card, or merchant payments.
Where we work with service providers to process payments, we may share information with the provider, including:
• Contact information (mobile number, e-mail address);
• Account information (TENN CREDIT ID); and
• Payment details (amount, transaction type, rules, and authorisation information).
Mandatory Sharing
• Credit bureaus (such as CRC): Share loan terms and repayment records by law (non-refusable).
• CBN regulatory audit: Provide complete KYC documents (non-refusable).
Optional Sharing
• Licensed debt collection agencies: Only share name, contact information, and outstanding principal. You have the right to refuse non-judicial debt collection.
All third parties are subject to Nigeria Data Protection Commission (NDPC) compliance terms.
How Your Information May Be Used
Payment Information
To process payments on TENN CREDIT, we need to share some of your personal information with the person or company with whom you are transacting. This information may include:
• Contact information (mobile number, e-mail address, personal photo).
• Payment information (card details, banking information).
We will not expose your credit/debit card number or bank account number to anyone you have paid or who has paid you using the TENN CREDIT app/platform, except with your express permission or if required to do so to comply with a subpoena or other legal action.
Purpose of Data Processing
Your data will be used in the following core scenarios:
• Real-time credit scoring: Integrate bank statements, income proof, and credit bureau data to generate dynamic credit scores
• Automated decision-making:
Loan approval → Generate a customized repayment plan.
Loan rejection → Activate the manual review channel and provide specific reasons (e.g., "Existing liabilities exceed 65% of income").
• Anti-fraud monitoring: Intercept suspicious transactions through device behavior analysis.
How Information May Be Disclosed
Your information may be shared in the following cases:
• To fulfil a request from the regulator or government entity with sufficient authority.
• To fulfil other legal obligations such as a request from a court.
• For regulatory reporting purposes.
Business Transfer
In the unlikely event that TENN CREDIT goes into administration or is acquired, a business transfer may occur. You consent to the successor company having access to the information maintained by TENN CREDIT, including customer account information, and such successor company
would continue to be bound by this Policy unless and until it is amended.
Cross-border Data Transfer
When necessary, data will be transferred with the following security safeguards:
• Implement NDPC Standard Contractual Clauses (SCCs).
• Apply GDPR-equivalent encryption for data storage
You can restrict specific cross-border transfers in the App settings.
Securing Your Personal Data
TENN CREDIT is entirely committed to protecting any information we collect from you. We maintain appropriate administrative, technical, and physical safeguards (i.e., firewalls, data encryption, competent security guards, etc.). These processes are in place to prevent accidental, unlawful,
or unauthorized destruction, loss, alteration, access, disclosure, or use of your information.
We are required to retain the details of transactions or payments you make via TENN CREDIT after the transaction is completed. We will store these
transactions for the required period under the financial regulations of the jurisdiction.
In the event of a data breach:
• Report to the NDPC within 72 hours
• Notify affected users via registered SMS/email
Your Responsibilities
You are responsible for the protection of your password or PIN in its entirety as communicated in our Terms and Conditions. You must not share your TENN CREDIT password or PIN with anyone.
We will never request your passwords via email, SMS, or any other means. In the event you receive such communication, please disregard and forward to [email protected].
If you share your password with a third-party, you will be held responsible for the consequences. If you believe your password or PIN has been compromised, please change it immediately and contact us.
We will use your data for the purposes of collecting statistics relating to our user base and may disclose such information to any third-party for such purposes, provided that such information will always be anonymous. Should we wish to use your information for marketing purposes, we will inform you prior to such use.
Your Rights
Under the Nigeria Data Protection Act, you have the following rights:
i.
Right to access your personal information – this enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
ii.
Right to correction of your personal information – this enables you to have any incomplete, outdated, or inaccurate data we hold about you corrected.
iii.
Right to erasure of your personal information – this enables you to ask us to delete or remove your personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercise your right to object to processing (see below), where we may have processed your personal information unlawfully or where we are required to erase your personal information to comply with applicable laws. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
iv.
Right to object to processing of your personal information – this enables you to object to the processing of your personal information in certain situations, such as for direct marketing purposes or where you feel it impacts on your fundamental rights and freedoms.
v.
Right to withdraw consent – where we rely on your consent to process data, you can withdraw it any time without affecting prior processing.
vi.
Right to lodge a complaint – you have the right to file a complaint with the NDPC if you believe your rights have been violated.
To exercise any of these rights, please do not hesitate to contact us at _ [email protected]
Privacy Control Center
Manage the following settings through App > Profile > Privacy Control:
• Biometric switch: Turn off face scanning (switch to OTP verification)
• Income analysis permission: Prohibit salary data verification
• Behavior tracking restriction: Stop collecting device usage data
Data Retention Period
• Loan records: Retained for 7 years after repayment is completed (required by tax law)
• Rejected applications: Automatically deleted after 180 days
• Device logs: Regularly cleared every 12 months
• Fraud alerts: Archived for 5 years
• After account cancellation: Complete full data erasure within 90 days (except for legally retained data)
Changes to This Privacy Policy
We may change this Policy from time to time, at our sole discretion. We will notify you when changes have been made. By continuing to use our mobile application or website after the change, you agree to accept the new Policy.
Contact Us
• Email: [email protected]
Regulatory Complaint Channels
• National Data Protection Commission: complaints.ndpc.gov.ng
• Central Bank of Nigeria: cbn.gov.ng/consumercomplaints
NDPC Registration Number: DPR/TENNCREDIT/2024/0871
CBN Consumer Notice: This service complies with the CBN's 2023 Mobile Money Operations Guidelines. Report illegal charges to [email protected]