Privacy Policy

Effective Date: September 24, 2025

1. Scope of this Privacy Policy

1.1 Summit Finance Limited (“9jiacashpool”) is a licensed Digital Money Lender in Nigeria, duly authorized by the Federal Competition and Consumer Protection Commission (FCCPC). Acting as the data controller, we are responsible for the collection and processing of your personal information whenever you download and use the 9jiacashpool mobile application, hosted on the Apple App Store, or when you access our services through other official channels.

1.2 In certain circumstances, 9jiacashpool may also act as a data processor on behalf of a data controller with whom you have a contractual relationship. In such cases, 9jiacashpool will process your personal information strictly in accordance with the instructions provided by that data controller.

1.3 If you have any questions or concerns regarding this Privacy Policy, you may contact us by email at admin@summit-fin.com

1.4 Please read this Privacy Policy carefully in order to understand how we handle your personal information in accordance with the National Information Technology Development Agency Act of 2007 and the Nigeria Data Protection Act of 2023. By indicating your acceptance of the terms of this Privacy Policy through the use of 9jiacashpool, you acknowledge and agree that your personal data will be processed in accordance with this Policy.

1.5 The services of 9jiacashpool are not intended for minors under the age of eighteen (18). We do not knowingly collect or process any personal data relating to individuals who are under this age threshold.

2. Definitions

2.1 “Privacy Policy” refers to the 9jiacashpool Privacy Policy, which is accessible through the 9jiacashpool App and the 9jiacashpool website. This Policy sets out the principles and procedures by which we store and process any personal information collected from you or provided by you.

2.2 “Channel” refers to any system or medium established by 9jiacashpool — including the 9jiacashpool mobile application and website, whether internet-based or mobile-based — that enables you to access and use one or more of our services.

2.3 “Child” or “Children” refers to any individual who is under the age of eighteen (18).

2.4 “Consent” refers to the indication of your wishes given by a statement or by a clear affirmative action, expressed in a manner that is explicit, unambiguous, voluntary, specific, and informed.

2.5 “Customer” or “User” refers to any natural person within the Federal Republic of Nigeria to whom 9jiacashpool provides services within the scope of its operations.

2.6 “Personal Data” refers to personally identifiable information, including but not limited to an individual’s name, address, telephone number, identification number, date of birth, gender, transaction records, online identifiers, or other details relating to physical, psychological, genetic, mental, economic, cultural, or social identity. It also encompasses any information associated with an identified or identifiable natural person, and shall include sensitive personal data.

2.7 “Sensitive Personal Data” refers to personal information relating to an individual’s race, state of health, ethnic or social origin, conscience, religious or other beliefs, genetic data, biometric data, property details, marital status, family information (including the names of a person’s children, parents, or spouse), or an individual’s gender or sexual orientation.

2.8 “Services” refers to the financial products and features made available to customers by 9jiacashpool through its mobile application, its partner channels, or any other authorized channels.

2.9 “We,” “Our,” or “Us” refers to Summit Finance Limited and 9jiacashpool.

2.10 “You” or “Your” refers to the Customer, including the Customer’s personal representatives.

3. Consent and Authorization

3.1 By downloading the 9jiacashpool application and selecting “Accept” on the permissions overview screen, you hereby:

• Accept the terms of this Privacy Policy;
• Authorize 9jiacashpool to access the device permissions described below in a more comprehensive manner;
• Grant 9jiacashpool the right to collect, use, share, or otherwise process your personal data — including personally identifiable information, personal information, or sensitive personal information as defined under applicable laws — in accordance with this Privacy Policy;
• Confirm that all personal information you have provided to 9jiacashpool, as well as any information you may provide in the future, is true and accurate to the best of your knowledge;
• Authorize 9jiacashpool to verify and ascertain the accuracy of your personal information;
• Acknowledge that 9jiacashpool may, pursuant to its legal obligations and in line with the principle of proportionality, be obliged to disclose your personal information to the Central Bank of Nigeria, the Federal Inland Revenue Service, credit information providers, credit bureaus, and/or any other competent governmental authority.

4.The Personal Information We Collect About You

4.1 With your consent, 9jiacashpool will collect your personal information when you make use of our services. This includes, but is not limited to, the following categories:

Identity Data

When using our application, we may collect your full name, date of birth, age, gender, religion, and identification number. This information is used to verify your identity, assess your eligibility for loans and other financial services, and fulfill legal and regulatory obligations.

Profile Data

We may collect your educational background, employment status, income details, and marital status, as well as any other information you provide in surveys conducted by 9jiacashpool. This data is used for credit assessment, service personalization, and to improve our risk management models.

Financial Data

We may collect your bank account number, the name of your bank, and your Bank Verification Number (BVN). This information is used to process loan applications, verify repayment capacity, and ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.

Camera Permission

With your authorization, we may access your device’s camera solely for the purpose of performing liveness detection and identity verification (for example, capturing a selfie or uploading an identification document) to confirm the authenticity of your identity when applying for our services. We do not use the camera function in the background, nor do we use the captured images for any other purposes or share them with third parties.

Emergency Contact Data

We may collect the name, relationship, and mobile phone number of your designated emergency contact. This information is used solely for identity verification and emergency communication. We do not access or collect your entire contact list.

Device Data

When using our application, we may collect the type of mobile device you use, device specifications (such as screen resolution and memory), IP address, Identifier for Advertisers (IDFA), Identifier for Vendors (IDFV), mobile network operator, and operating system version. This data is used for fraud prevention, account security, risk management, and to ensure service compatibility and performance.

Identifier for Advertisers (IDFA)

We may use your device’s Identifier for Advertisers (IDFA) only after you have explicitly consented by selecting “Allow App to Track.” The IDFA will be used strictly for risk management, fraud prevention, account security, and product optimization. It will not be used for third-party advertising or cross-app tracking. If you do not grant consent, we will not collect or use your IDFA. You may withdraw or adjust your authorization at any time through your device settings.

Usage Data

We may collect your account details, password, one-time passwords (OTP), and records of your interactions with the 9jiacashpool App or other channels. This information is used to manage and maintain your account, authenticate access, process transactions, and improve the overall user experience.

Third-Party Data

We may obtain information about you from partners, credit reference agencies, identity verification and sanctions screening service providers, and marketing partners. This information is used to validate the data you provide, perform credit scoring, comply with regulatory requirements, and prevent fraudulent activities.

4.2 We may also collect additional information about you, your device, and your use of the App or other channels in the manner described to you at the time such information is collected.

4.3 We process your personal information from the following sources:

4.3.1 Information You Provide.

This refers to information that you submit to us, or that you allow us to access by accepting within the 9jiacashpool platform, completing forms, contacting us directly, or interacting with our website or official social media accounts.

4.3.2 Information Collected from Your Device.

This refers to information that we obtain through certain device permissions you enable when installing and using the 9jiacashpool application.

4.3.3 Third-Party Data and Public Sources.

We may receive your personal information from various third parties, business partners, and publicly available sources, such as:

• Financial, profile, and transaction data obtained from technology providers and general financial service providers, such as money service businesses;
• Contact, financial, profile, and transaction data obtained from identity verification and sanctions screening service providers, as well as credit reference agencies;
• Identity, profile, and contact data obtained from business partners and publicly available sources;

4.4 9jiacashpool collects and processes your personal information for the purpose of delivering its services and complying with legal and regulatory requirements applicable to you and/or 9jiacashpool. Except in such circumstances, we will not collect or share personal information without your explicit prior consent.

4.5 If you fail to provide or maintain any or all of the personal information requested by 9jiacashpool, we may be unable to deliver our services to you.

4.6 With your consent and authorization, we access personal information which, during the use of the App, is encrypted and transmitted via https://api.summit-fin.com to the 9jiacashpool servers. No data is transmitted when the App is running in the background or is inactive.

4.7 We will never publicly disclose, sell, or use your personal information for any purpose other than those stated in this Privacy Policy.

5.The Purposes and Legal Basis for Which We Use Your Personal Data

5.1 We process your personal information only where there is a lawful basis for doing so. In most circumstances, we will rely on one of the following grounds to process your personal information:

• you have given your consent to the processing of your personal information;
• we need to enter into a contract with you, or take steps at your request prior to entering into such a contract;
• where we are required to comply with a legal obligation;
• where it is necessary for the purposes of our legitimate interests (or those of a third party), provided that your interests and fundamental rights do not override such interests;

5.2 If you fail to provide or maintain any or all of the personal information requested by 9jiacashpool, we may be unable to provide our services to you.

6.Use of Your Personal Information

6.1 We may, through the use of automated decision-making and profiling functionalities, make certain determinations in the provision of products and services to you without human involvement.

6.1.1 When you apply for credit, we may rely on automated processing to determine whether to grant you a loan and/or to make other decisions regarding your eligibility for our products and services, based on the personal information collected. Such automated processing enables us to provide fast, flexible, and tailored credit services to customers who may not have prior credit history, previous banking or financial records, or documented sources of income.

6.1.2 Our credit and underwriting models utilize data science and machine learning techniques to process your personal information and assess your creditworthiness. The processing of your personal data in this context is automated, with little to no human intervention. Using such automated processes to evaluate your creditworthiness may result in automated determinations that you are not eligible for our services, or that you do not qualify for credit of a specific amount or term. Our credit and underwriting models are tested periodically to ensure that they remain fair, accurate, and free from bias.

6.1.3 9jiacashpool employs automated processes to detect, combat, and prevent fraud. Our fraud detection models may automatically determine that an individual poses a risk of fraud or money laundering — for example, where the processing reveals information or behaviors consistent with money laundering or known fraudulent activities, where activity patterns deviate from prior activity on our platform, or where an individual appears to be concealing their true identity. If our fraud detection models determine that processing a transaction or approving an individual presents a fraud risk, that individual’s access may be suspended or denied.

6.2 Your Rights in Relation to Automated Decision-Making

6.2.1 If you apply for credit and are declined as a result of an automated credit, underwriting, or fraud decision (or are informed that you do not meet the eligibility criteria for other related products or services), you may request a review of that decision by our underwriters. You can contact us at: admin@summit-fin.com. You also have the right to object to the automated processing of your personal data; however, exercising this right will prevent us from being able to provide our services to you.

7.Disclosures of Your Personal Data

7.1 When you consent to provide us with your personal information, we will also require your agreement to share such personal information with the third parties listed below, for the purposes described in the table above.

7.2 External Third Parties such as:

7.2.1 Credit reference agencies and/or any other reputable sources from which we may obtain your personal data, as well as entities to whom we may provide your consumer credit information. Such information may include repayment history, default records, and details regarding the opening and closing of accounts;

7.2.2 Any local or international law enforcement authority, regulatory body, or governmental agency, upon official request, for the purpose of assisting in the prevention, detection, investigation, or prosecution of criminal activities or fraudulent conduct;

7.2.3 Service providers of 9jiacashpool, such as external debt collection agencies, acting as data processors under the instructions of 9jiacashpool;

7.2.4 Agents of 9jiacashpool, or any company that may become an affiliate of 9jiacashpool, for legitimate business purposes connected with the provision of services;

7.2.5 Professional advisers and consultants of 9jiacashpool, including lawyers and auditors, or any court or arbitral tribunal, in connection with any legal or audit proceedings;

7.3 We may choose to sell, assign, transfer, or merge part of our business or assets to a third party. Alternatively, we may seek to acquire or merge with other businesses. In the event of a change in our business ownership, the new owner may use your personal information in the manner set out in this Privacy Policy.

8.International Transfers

8.1 The personal information collected by 9jiacashpool may be stored and processed outside Nigeria, in locations where 9jiacashpool or its agents maintain facilities, including through the use of cloud storage and cloud computing technologies.

8.2 Whenever we transfer your personal information outside Nigeria, we ensure that it is afforded a comparable level of protection by implementing adequate safeguards. We achieve this by requiring all group companies, personnel, and agents to adhere to the same rules when processing your personal information.

9.Data Governance and Security

9.1 9jiacashpool implements an information security management system to preserve the confidentiality, integrity, and availability of its information assets, in line with our commitments, industry standards, and global best practices. For further details on the data governance and security measures we implement, please refer to our Privacy Policy.

9.2 If you choose, or are assigned, a password or one-time password (OTP) to access certain parts of the 9jiacashpool App or Channels portal, you are responsible for maintaining the confidentiality of such password or OTP. You must never share your password or OTP with anyone. 9jiacashpool will never request that you disclose your password or OTP.

9.3 We have established procedures to address any suspected personal data breach and, where required by law, will notify you and any relevant regulatory authority.

10.Data Retention

10.1 Your personal data will be retained by 9jiacashpool and its assignees only for as long as is necessary to fulfill the purposes set out in this Privacy Policy, and for a reasonable period thereafter in order to deliver our products and complete our services. In accordance with anti-money laundering and counter-terrorism financing regulations, we are required to retain your personal data for at least five (5) years, notwithstanding any deletion request. We may also retain your personal data (i) to comply with any legal obligation; (ii) where permitted by law; and (iii) for the establishment of legal defenses. Information that is no longer required for the purposes for which it was collected will be deleted or anonymized, unless its retention is necessary for compliance with legal obligations.

10.2 In certain circumstances, we will anonymize your information so that it no longer constitutes personal data. In such cases, we may use it for any lawful purpose without further notice to you.

11.Your Data Subject Rights

11.1 As a data subject, you have the following rights in relation to your personal information:

11.1.1 To be informed of the purposes for which your personal information is being processed;

11.1.2 To access your personal information held by us, as well as the following details:

• The purposes for which we process your personal information;
• The categories of personal information that we process;
• The individuals or categories of individuals to whom personal data has been or will be disclosed;
• Where possible, the period for which personal data may be stored, or the criteria used to determine the storage and retention period;
• Where the personal data is not collected directly from you as the data subject, any available information regarding its source;

11.1.3 To object to the processing of all or part of your personal data, unless we can demonstrate compelling legitimate grounds for continuing the processing, or where such processing is necessary for the establishment, exercise, or defense of legal claims;

11.1.4 To have incorrect, inaccurate, outdated, incomplete, or misleading data about you rectified or corrected (subject to verification, such as the review of supporting documentation);

11.1.5 To request the erasure or deletion of data that is incorrect, misleading, irrelevant, excessive, unlawfully obtained, or that we are no longer authorized to retain. Your right to erasure does not apply where the continued processing of your personal information is required for compliance with a legal obligation, or for the establishment, exercise, or defense of a legal claim.

11.1.6 To obtain a copy of your personal information, to migrate it, or to receive it in a structured, commonly used, and machine-readable format, or to have your personal information transferred to another data controller or data processor.

11.2 You have the right to request that we restrict the processing of your personal data under the following circumstances:

11.2.1 Where it is necessary to verify the accuracy of the personal data you have contested;

11.2.2 Where the processing of your personal data is unlawful, but you do not want us to erase it;

11.2.3 Where the purposes of processing have already been fulfilled, but we still need your personal data for the establishment, exercise, or defense of legal claims;

11.2.4 Where you object to our use of your personal data, but we need to determine whether we have overriding legitimate grounds to continue using it;

11.3 Where we rely on your consent as the lawful basis for processing your personal data, you may choose to withhold or withdraw your consent. Doing so may prevent us from being able to provide our services to you.

11.4 You, or your authorized representative, may contact us at any time by email at admin@summit-fin.com to exercise these rights, subject to our verification and review.

11.5 You may request the closure and deletion of your 9jiacashpool App account by submitting an in-app application or through an external application link. 9jiacashpool reserves the right to decline such a request where it cannot be verified, where your account has outstanding loan orders or is under investigation, or where we have other lawful grounds to retain your 9jiacashpool App account and its related customer data. In accordance with anti-money laundering regulations, 9jiacashpool is required to retain customer information for a minimum of five (5) years. Notwithstanding any request to delete a 9jiacashpool App account, we will continue to retain customer records (for example, customer due diligence and identity records, as well as transaction records) until the expiration of the regulatory retention period.

12.CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

12.1 We regularly review this Privacy Policy. Any changes to the Privacy Policy will be published on this page and, where appropriate, notified to you through the 9jiacashpool App or Channels, our website, email, or SMS.

12.2 The personal information we hold about you must be accurate and up to date. Please notify us promptly of any changes to your personal information during the course of your relationship with us.

13.GENERAL

13.1 If you have any questions regarding this Privacy Policy or your rights as a data subject, you may contact us at: admin@summit-fin.com.

Customer Service

admin@summit-fin.com

09133030067

Mondays to Fridays 9:00 AM-7:00 PM

Saturday 9:00 AM-3:00 PM

33, Odozie street, Ojodu Berger, Lagos