The ZapCash application is developed by CROWN TECK NIG LTD. Please read the following privacy policy carefully. Please note that this privacy policy applies only to instant loans. This privacy agreement is formulated by CROWN TECK NIG LTD (hereinafter referred to as "we" or the "Company") and applies to its digital financial services application ZapCash and related services. This policy aims to explain to you (hereinafter referred to as "User" or "you") our principles and methods for collecting, using, and protecting your personal information, as well as your rights, in order to protect your privacy and security.

We will provide you with personal loans and short-term loans, which you can apply for based on your creditworthiness to meet your daily needs.

Please read this Policy carefully before using ZapCash. If you do not agree to any terms, please stop using it immediately. Use constitutes full agreement to all contents of this Policy.

I. Definitions

* **Personal Information:** Information in electronic or non-electronic form that can identify or associate with a natural person (excluding anonymized information, defined in accordance with the Nigerian Data Protection Act (NDPA) and related regulations).

* **Data Processing:** Covers the collection, storage, use, transmission, and disclosure of data.

* **User:** A natural person who registers, logs in, or uses ZapCash services, including borrowers and potential users.

II. Scope of Personal Information Collection

**Core Service Required Information:**

**Basic Identity Information:** Name, Nigerian ID number (for real-name verification).

**Device Information:** Device model, operating system version, unique device identifier (IMEI/Android ID).

**Location Permission:** Approximate geographical location based on service needs (for localized loan recommendations and compliance verification).

All information is transmitted encrypted via HTTPS to a local Nigerian server (server address: [actual server link]).

Data is temporarily stored and anonymized and destroyed within 60 days after loan repayment.

III. Personal Information Usage Scenarios

Core Services: Loan application, credit assessment, fund transfer, repayment management.

Risk Management: Monitoring abnormal transactions (such as overdue payments, fraudulent transactions), cooperating with anti-money laundering investigations.

Service Optimization: Pushing personalized loan products, system maintenance notifications, user experience improvement analysis.

IV. Uses Rights

In accordance with NDPA and Nigerian law, you have the following rights:

Access and Correction: To query/copy your personal information and request correction of inaccurate data.

Right to Deletion: You may request deletion in the following situations: The service purpose is achieved or consent is withdrawn; The account is closed and there are no outstanding debts; Violations are discovered.

(This can be achieved through the "Cancel Account" function in the app; the data will be anonymized within 24 hours.)

Withdrawal of Consent: To close marketing push permissions at any time (without affecting historical services).

Restriction of Processing: To request suspension of processing of disputed data.

V. Child Privacy Protection

ZapCash only provides services to users aged 18 and above. If any information of minors is discovered, it will be immediately deleted and the service terminated.

VI. Policy Updates and Effectiveness

Policy revisions will be communicated via:

In-app pop-up notifications;

SMS/email notifications to registered accounts.

Continue use constitutes agreement to the updated content.

VIII. Contact Us

Privacy Affairs Manager

Company Name: CROWN TECK NIG LTD

Address: 5 AJIBODE STREET, UNITY ESTATE, SANGO-OTA, ADO-ODO/OTA, OGUN STATE, NIGERIA

Phone: +234 9126689149 (Nigeria local number, weekdays 9:00-17:00)

Email: contact@croteckltd.com (Official and only contact channel)