Privacy Policy

2.What we collect

When you create an account

• Your name and email address, from your Google or Apple account
• Your phone number and date of birth
• Your address, or your shop address if you are a vendor
• The location of your shop, if you are a vendor
• A profile photo, if you add one

When you apply to be an agent

• A photo of your government ID document, and which ID it is: NIN slip, national ID card, voter's card, driver's licence or passport
• A photo of a document that proves your address
• A business certificate, if you give one
• Your location, if you allow it

When an agent visits your shop

• A photo of your shop
• A photo of your ID document, and its type: NIN slip, national ID card, voter's card, driver's licence, passport or BVN slip
• The most you can borrow, which your agent sets after the visit

When you borrow

• Your bank name, account number and account name
• What you tell us when you ask for a loan:
  • the amount and what the loan is for
  • your monthly sales, and any other loans you have
  • a guarantor's name, phone number and relationship to you, if you give them
• How your loan was paid to you: the bank reference of a transfer, or the agent who handed you cash
• Each repayment: the amount, the date, how you paid, the agent who recorded it and any bank reference or POS receipt number

When you save

• Each deposit and withdrawal, with the amount, the date and the agent who recorded it
• Your balance, and how many deposits you have made since your last withdrawal

When you use your payment code

• Each time your code confirms money changing hands: when, what for, how much and which agent entered it
• Any wrong codes entered for your account

When you ask for a loan on our website

The loan request form at www.chopmoni.com asks for your name, phone number and market. It also asks for the amount, your bank name and account number, and how you plan to repay. We record the internet address the request came from, to stop abuse.

When you call or send a message

• Who you called or messaged, when, and for how long
• The size of each message
• Technical details about each call, such as sound levels, whether you used the speaker and whether your microphone was muted
• The messages you send to ChopMoni Support

From your phone

• Your phone's notification token, model, operating system version and app version
• Your location, only if you allow it
• Photos, only the ones you choose to take or upload
• Sound from your microphone, only during a call

We do not use analytics, crash reporting or advertising tools.

3.Your location

• We store the location of your shop, or of an agent, with the account. We use it to find agents near you and to work out how far away they are by road.
• The location comes from the address you pick, or from your phone's location if you allow it.
• When you type an address, the app sends what you type to TomTom, which suggests matching addresses.
• To turn your phone's location into an address, the app uses your phone's own service. This is usually Google on Android and Apple on iPhone.
• You can refuse location access, or turn it off in your phone settings. You can still type your address instead.

4.How we use your data

• To create and run your account
• To record your loans, repayments, savings and withdrawals, and to work out fees
• To match you with an agent near you
• To check that a shop is real before we lend to its owner
• To decide whether to lend to you, and how much
• To pay out loans, by bank transfer or through your agent, and to follow up on repayments
• To connect calls and deliver messages between you and your agent
• To send you notifications and emails about your account
• To help you when you contact ChopMoni Support
• To keep ChopMoni secure and to prevent fraud
• To meet our legal duties

Our emails and notifications are about your account only, such as a loan paid out, a repayment recorded or a deposit made. We do not send marketing.

5.Why we are allowed to use your data

Nigerian law lets us use personal data only for a lawful reason. We rely on these reasons:

• Our agreement with you: we need your data to give you the loans, savings, calls and messages you signed up for.
• Our legal duties: we must keep financial records and answer lawful requests from the authorities.
• Our legitimate interests: we use data to prevent fraud, keep our systems secure and check shops before we lend.
• Your consent: we use your location, camera and microphone only when you allow it.

6.Who sees your data

Inside ChopMoni

• Your agent sees your name, phone number, email address, date of birth, shop address, photos and ID document. They also see your loan, your repayments and your savings. They need these to serve you.
• If you ask for a loan on our website, the agent we send sees your name, phone number, market and the amount. They contact you by ordinary phone call.
• Our staff see the data they need to run accounts and loans. They can reach our admin tools only through a private network, and we log what they do.
• Our support staff read the messages you send to ChopMoni Support.
• One sign-in service serves ChopMoni and other ChopBase Africa products. It keeps your email address and how you sign in.

Companies that work for us

These companies handle personal data for us. Each one receives only what it needs for the job described.

• Google provides:
  • Google Sign-In, if you sign in with Google
  • Firebase Cloud Messaging, which delivers our notifications on Android and iPhone
  • Gmail, which sends our emails
  • Google Fonts, which supplies the app's lettering. Google sees your phone's internet address when the app downloads it.
• Apple provides:
  • Apple Sign-In, if you sign in with Apple
  • Apple Push Notification service, which delivers notifications and incoming calls to iPhones
• TomTom suggests addresses as you type one.
• Our bank, Moniepoint Microfinance Bank, holds the ChopMoni account we pay loans from and you repay loans into. When we pay you by transfer, Moniepoint receives your bank details.
• YouTube shows the school feeding film on our website, when you press play.

Some of your data is handled outside Nigeria, including in the European Union and the United States. We send data abroad only where the Nigeria Data Protection Act allows it.

Anyone else

• We share data with the police, courts or regulators when the law requires it.
• We do not sell your data, and we do not share it with advertisers.

7.Messages and calls

• Messages and calls between agents and vendors are end-to-end encrypted. Only the people in the conversation can read or hear them. ChopMoni cannot.
• The keys that protect them are made on your phone. We delete a call's key from our servers when the call ends.
• You can compare security codes in the app to check that you are talking to the right person.
• Our servers still see who contacted whom, when, for how long and how much was sent.
• We never record calls.
• A notification about a new message does not contain the message. A notification about a call shows the caller's name.
• Messages with ChopMoni Support are not end-to-end encrypted. Our staff read them so they can help you.
• Your phone keeps your messages and the keys that protect them. Logging out removes them from the phone.

8.How long we keep your data

• Messages, including messages with ChopMoni Support: 30 days. Our servers then delete them. Your phone deletes its copy the next time you open the app.
• A call's encryption key: until the call ends.
• Copies of the emails we send: 30 days in our systems, then in our archive.
• Your details, photos and documents, including the photos taken at your shop: while you have an account. When you delete it, we delete them (see 'Deleting your account').
• Records of loans, repayments, savings and withdrawals, and of when calls happened and how long they lasted: as long as we need them to settle money owed, deal with disputes and meet our legal duties. This includes after you delete your account.

9.Deleting your account

• You can delete your account in the app: go to Profile, then Account information, then Delete account. You confirm it with your Google or Apple account.
• You must first repay any loan, cancel any loan request and take out your savings. The app shows anything still to do.

What we delete

• Your name, phone number, email address and date of birth
• Your addresses and the location of your shop
• Your photos and ID documents
• Your bank details
• Your messages, and the keys that protect them
• Your payment code and your sign-in

We delete most of this at once. Your sign-in, photos and documents are removed from our systems shortly afterwards, usually within minutes. The app deletes your messages and their keys from your phone.

What we keep

• Records of money you borrowed, repaid, saved or withdrew, because the law requires us to keep them. We remove your name and details from them.
• When calls happened and how long they lasted, never what was said.

If you cannot use the app, email support@chopmoni.com from the address on your account and ask us to delete it. We will delete what we can, and tell you what we must keep and why.

10.Your rights

Under the Nigeria Data Protection Act 2023, you can ask us to:

• give you a copy of your data
• correct data that is wrong
• delete your data, unless we must keep it
• stop using your data, or use it less
• send your data to you or another organisation in a common format

You can withdraw your consent for location, camera and microphone at any time in your phone settings. The features that need them will stop working. Your account, loans and savings are not affected.

To use any of these rights, contact us. If you are not happy with our answer, you can complain to the Nigeria Data Protection Commission.

11.How we protect your data

• Every connection between the app and our servers is encrypted.
• Messages and calls between agents and vendors are end-to-end encrypted.
• An agent can record money changing hands only with your payment code. The code changes every 30 seconds, and each code works only once.
• Our staff reach our admin tools only through a private network, with a second sign-in step. We log every action they take.
• Photos and documents are kept in private storage. The app shows them through links that stop working after 24 hours.

No system is completely safe. If a breach puts you at risk, we will tell you and the Nigeria Data Protection Commission.

12.Our website

• When you visit our website, we receive your internet address and browser details.
• Our website offers a film about our school feeding programme. Nothing is sent to YouTube until you press play. When you do, YouTube, which Google owns, receives your internet address.
• If you sign in, your browser remembers it so that you stay signed in.
• We do not set cookies ourselves, and we do not use analytics or advertising tools.

13.Changes to this policy

We will update this policy when our service changes. The date at the top shows when we last changed it. We will tell you about important changes by email or in the app.

14.Contact us

Contact us with any question about your data, or to use your rights.

• In the app: go to Profile, then Message support
• Email: support@chopmoni.com
• Post: ChopBase Africa Limited, No 5 Akai Street, Calabar 540281, Cross River State, Nigeria