Privacy Policy
 

INTRODUCTION

Welcome to use TopChance App(hereinafter referred to as “TopChance” or the “Platform ”). As the operator of TopChance App and the provider of platform services, we will explain to you through the Privacy Policy (hereinafter referred to as the “Policy ”) how we collect, use, store and provide your personal information to the outside world and how we manage your personal information.

This Policy applies to all products and/or services provided to you by the platform (collectively, “TopChance Products and/or Services ”). However, it should be specially noted that this policy does not apply to products or services provided to you directly by TopChance affiliates or third party cooperative agencies. For such products or services, we recommend that you check their personal information protection policies before using them to understand how they handle your information so that you can make a prudent decision.

The security of your personal information is of Paramount importance to us. We respect and protect your personal information, and we have always been committed to providing you with a secure online environment. We will protect your personal information in accordance with the laws of the Federal Republic of Nigeria and the laws and regulations governing the protection of personal information in the financial industry, as well as recommended technical specifications. This Policy describes the purpose, method and scope of our collection, use, storage, sharing and transfer of your Personal Information in the products and/or services we provide to you, information security protection measures, and the methods we provide for you to access, update, delete and control your personal information. In order to facilitate your reading and understanding, we try to use simple and easy words for you to understand the statements.

You acknowledge and affirm that you have read all the contents of this Policy at the time of registration and agree that we will legally process your personal information in accordance with this Policy. Before you provide us with any sensitive personal Information, please clearly consider whether such provision is appropriate in light of the relevant provisions of this Policy and confirm whether you agree that we may process your sensitive personal information for the purposes and in the manner described in this Policy. We will collect and use your sensitive information with your consent to implement functions related to TopChance products and/or services. You may refuse to provide us with such sensitive information, but such refusal will affect your use of certain features under TopChance products and/or services.

If you do not agree with or understand part or all of this Policy, please immediately stop using our products and/or services. You can contact and consult us through our customer service phone number on matters related to this policy.

The products and/or services covered by this Policy are for adult use only. Please ensure that you are 18 years of age or older before using the products and/or services. If you are under the above age, please immediately terminate your use of TopChance products and/or services.

This policy will help you understand the following:

  1. How we collect and use your personal information.
  2. How do we use cookies and similar technologies.
  3. How do we share, transfer and publicly disclose your personal information.
  4. Minor (i.e person under 18) information protection.
  5. How we update and modify this policy.
  6. How to Contact us.
  7. How we collect and use your personal information.

TopChance will collect and use your personal information that you voluntarily provide in the process of using TopChance products and/or services, arising from your use of TopChance products and/or services, and obtained from third parties in accordance with the relevant laws and regulations mentioned in the introduction, in accordance with the principles of propriety, legality and necessity, and for the following purposes described in this Policy. Regardless of the collection and use of your personal information through the above methods, in principle, we will only do so with your consent, unless in some cases, based on legal obligations or the important interests that may require the protection of you or others, but we will not collect personal information that is prohibited by laws and regulations. You may choose not to provide one or more of the information. If you choose not to provide certain information, you may not be able to use or properly use some TopChance products and/or services, but this will not affect your use of other TopChance products and/or services.

Please understand that the functionality of TopChance products and/or services may also change and evolve due to changes in business strategy. If we want to use your personal information for other purposes not specified in this policy, or use the collected personal information for other purposes based on specific purposes, we will inform you in a reasonable manner (such as pop-up windows, etc.) through the TopChance app and platform, and obtain your consent again before use.

PERSONAL INFORMATION

1.1 Throughout this policy, we use the term “personal information” to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include anonymous information that does not refer to a specific user.

1.2 TopChance may collect and process the following types of personal information in order to provide you with a safe, personal and seamless access to our App and the Services:

personal data such as name, age, email address, phone number, physical contact information, personal description, photograph, username, password,other registration information and (depending on the service used) sometimes financial information, such as Bank Verification Number, credit card or bank account numbers;

  • SMS information: TopChance will collect your SMS information, but only some financial information will be screened out which helps us in identifying the various accounts that you are holding and the cash flow patterns that you have as a user to help us perform a credit risk assessment which enables us to determine your risk profile and to provide you with the appropriate credit analysis to enable you to take financial facilities from the regulated financial entities and other service providers available on the platform.Collection will only be conducted with your consent.We will upload the collected data to the server(https://app.topchance.club) in a secure network environment
  • Calendar information: To provide you with the best loan management service, we seek your permission to have write access to your calendar. This will allow us to notify you in advance of repayment dates, ensuring you never miss a payment deadline. We assure you that we will only use this access for loan-related notifications and will not alter or delete any of your calendar events.
  • Call Record: After you grant us call record rights, TopChance will talk to you by voice phone. The purpose of collecting call records is to be able to confirm that you are using your own phone to install our application and receive our dynamic password authentication on the same machine. Specifically, we will verify your device by making a phone call and check your call history to see if you received a call. This makes your credit more reliable and leads to faster loan service. TopChance do not monitor, read, store or share any private call data.We will upload the collected data to the server (https://app.topchance.club) in a secure network environment.
  • Contacts: TopChance will upload and transmit the contact data you have chosen to fill in the address book, including name and phone number. The names and phone numbers uploaded and transmitted will be used for risk management and anti fraud checks. TopChance will protect your data and will never share it with third parties without your permission.We will upload the collected data to the server (https://app.topchance.club) in a secure network environment.
  • Installed applications: opChance will collect a list of apps that have been installed on your device, including their installation time, update time, package name and APP name, which will be uploaded and saved to our system database for analyzing your credit. TopChance won’t give out your information.We will upload the collected data to the server (https://app.topchance.club) in a secure network environment.
  • transactional information based on your activities on the App (such as products or service purchased, content you generate or that relates to your account), billing, and other information you may have provided in connection with your orders.We will upload the collected data to the server(https://app.topchance.club) in a secure network environment.
  • personal information you provide to us through information pages,correspondence, chats,complaints, customer service channels, or provided to us from other social applications or services.We will upload the collected data to the server (https://app.topchance.club) in a secure network environment.
  • additional personal information we ask you to submit as part of our verification process (for example, we may ask you to send us an identification document or utility bill to verify your address, or to answer additional questions online to help us verify your identity).We will upload the collected data to the server (https://app.topchance.club) in a secure network environment.
  • Other supplementary information obtained from third parties, such as demographic and navigation data, credit check information, and additional information about you from a credit bureau, as permitted by law.We will upload the collected data to the server (https://app.topchance.club) in a secure network environment.
  • information from your interaction with our App, services,content and advertising, including, but not limited to, device lD, device type, unique device identifiers; geo-location information, computer, operating system and connection information, statistics on page views,IP address and standard weblog information.We will upload the collected data to the server (https://app.topchance.club) in a secure network environment.
  • details of any of your visits to the App,including, but not limited to, traffic data, location data, weblogs and other communication data.We will upload the collected data to the server (https://app.topchance.club) in a secure network environment.

1.3 This information may be provided or collected by:

  • filling in forms on the App;
  • corresponding with us (for example, by e-mail or chat);
  • registering to use the App;
  • subscribing to any of our Services;
  • sharing data via the App’s social media functions;
  • entering a competition, promotion or survey;
  • reporting an issue with the App or our Services.
  • To comply with the KYC policy (authenticity or effectiveness or completeness of any client’s identity materials), we may dial someone in your contact list, SMS, call list or other personal information you provide to us.During the verification，we will not disclose your personal information to others.

1.4 Rules for the use of your personal information

  • We will use your personal Information for the platform services in accordance with the provisions of this Policy. If we need to use your personal information for other purposes not specified in this Policy, we will seek your consent again in accordance with laws and regulations and relevant national standards.
  • We will only collect and use personal information necessary for the proper operation of certain business functions at the lowest reasonable frequency.
  • We will desensitize your personal information through technical means, and the desensitized information will not be able to identify specific individuals. Please understand and agree that we may analyze and process desensitization information or conduct statistics, and may share such statistics with third parties or the public, but such statistics do not include any of your personal information.
  • If you have any questions or objections about the way we use and process your information, you may give feedback to us through the contact information provided in Section 6 “How to Contact Us”. If we violate laws and regulations in this process and cause you losses, we will assume the corresponding responsibilities arising therefrom.

1.5 Exceptions with authorized consent

In accordance with relevant laws and regulations, we may collect and use necessary personal information without your authorization and consent under the following circumstances:

  • Relevant to our performance of obligations under laws and regulations;
  • Those directly related to state security and national defense security;
  • Those directly related to public security, public health or major public interests;
  • Those directly related to criminal investigation, prosecution, trial and execution of judgment;
  • For the protection of your or other personal life, property and other important legal rights and interests, but it is difficult to obtain the consent of the person;
  • The personal information involved is disclosed to the public by you;
  • Necessary to sign and perform the contract according to your requirements;
  • Collect your personal information from legally disclosed information, such as legal news reports, government information disclosure and other channels;
  • Necessary to maintain the safe and stable operation of our products and/or services, such as finding and disposing of faults of products or services;
  • Other circumstances stipulated by laws and regulations.
  1. How do we use cookies and similar technologies.

When you use our services, we store a small data file named Cookie on your computer or mobile device to ensure the normal operation of the website. Cookies typically contain identifiers, site names, and some numbers and characters. The main function of cookies is to facilitate your use of the platform products and/or services, and to help the website count the number of unique visitors, etc. Using Cookie technology, we can provide you with more thoughtful personalized service and allow you to set your specific service options.

When you use platform products and/or services, cookies are sent to your device. When you interact with services we provide to our partners (such as advertising and/or promotional services, and service features provided by TopChance company that may be displayed on other websites), we allow cookies (or other anonymous identifiers) to be sent to our servers.

We do not use cookies for any purpose other than those stated in this Policy. You can manage or delete cookies according to your preference. You can erase all cookies saved on your computer, and most Web browsers have a Cookie blocking feature.However, if you do so, you will need to personally change the user Settings each time you visit our site, and you may not be able to log in or use the services or features provided by Duoman Comany that depend on cookies because of such changes.

In addition to cookies, we may use web beacons and other similar technologies on our website to access your data. Please understand that when you access web pages created by third parties through the platform, these third parties may collect your information through their cookies and Web beacons. Such actions are not governed by our control and this Policy, but by the third party’s personal Information protection Policy. We recommend that you carefully read the personal information protection policies of third parties before using the services provided by such third parties. We will also fulfill necessary audit obligations and strive to require third parties to take measures to protect your personal information.

  1. How do we share, transfer and publicly disclose your personal information.

(1)SHARING

We will not share your personal information with any company, organization or individual, except in the following cases:

1.1 Obtain your explicit authorization or consent in advance: After obtaining your explicit consent, we will share your personal information with relevant parties. The scope and purpose of sharing your personal information will be shown when obtaining your authorization or consent;

1.2 Sharing under statutory circumstances: Sharing of your personal Information is required in accordance with applicable laws and regulations, legal procedures, judicial rulings, mandatory orders of the government or self-regulatory requirements of the industry. The scope of sharing of personal Information will be determined by laws and regulations and requirements of relevant administrative or judicial departments;

1.3 To the extent required or permitted by law, it is necessary to provide your personal information to third parties in order to protect the interests, property or safety of us, you or the public from damage, except where the provision of your personal information is expressly prohibited by laws and regulations;

1.4 In accordance with the provisions of law and reasonable business practices, in the event that TopChance’s operating entity merges with or is acquired by another company or conducts other capital market activities, and in other circumstances when TopChance receives due diligence from another entity, you agree that we can provide your information to the necessary subjects (such as external professional intermediary agencies such as auditing and legal agencies) according to the needs of our business. However, we will require them to take the same confidentiality measures as this Policy for such information by signing confidentiality agreements with such subjects and require them to delete your information within a reasonable time after completing necessary work;

1.5 Sharing with our Affiliates: Your personal information may be shared with our affiliates. We will only share your personal Information with our affiliates to the extent necessary and subject to the purposes described in this Policy:

  • Some products or services may be provided by affiliated companies or jointly provided by us and affiliated companies (such as account login, payment services, etc.). Therefore, products or services you require can only be provided if your personal information is shared;

  • With your express consent, we will share your personal information with affiliated companies according to your authorization to the extent permitted by laws and regulations and consistent with public order and good customs.

We will require affiliated companies that share your personal Information with us to store and process your personal information in accordance with this Policy. Before sharing information, we will conduct a reasonable commercial review to evaluate the legality, legitimacy and necessity of sharing your personal information, and urge relevant parties to process your information in accordance with legal provisions and regulatory requirements. Our affiliates will again seek your express consent when they change the purpose of processing personal information.

1.6 Sharing with the Public: We may also conduct statistics and analysis of product usage in order to improve our products and/or services and those of our affiliates and third party partners. At the same time, we may share these statistics with the public to show overall usage trends of our services, but these statistics will not contain any identifying information about you.

1.7 Sharing by Third Party Partners: Certain products and/or services of the Platform will be provided by our suppliers and partners (collectively, “Third Party Partners ”), and for this purpose, we may share your personal information with third Party partners to provide you with specific products or services.

We will only share your personal information for lawful, legitimate, necessary, specific and explicit purposes and will only share such personal information as is necessary to provide the services. At the same time, we will sign strict confidentiality agreements and data processing agreements with third party partners, requiring them to handle your personal information in strict accordance with our instructions, this policy and any other relevant confidentiality and security measures. We will also ensure that the collection and use of their personal information comply with laws, regulations and agreed requirements by means of technical testing and security audit. We will require our third party partners not to share your personal information for any purpose other than the purpose of this policy.

We may obtain your authorization through pop-ups, etc. Pop-ups will form an effective part of this policy. If you refuse to share your personal information necessary for us to provide services with third party cooperation agencies, you may not be able to use the services provided by such third party cooperation agencies, but it does not affect your use of other TopChance products and/or services.

(2) TRANSFER

We will not transfer your personal information to the outside world, except in the following circumstances:

2.1 Obtain your express prior authorization or consent;

2.2 It is required to be provided in accordance with applicable laws and regulations, business regulations, legal procedural requirements, mandatory administrative or judicial requirements;

2.3 If we or our affiliates are involved in mergers, separation, liquidations, acquisitions or sales of assets or businesses, your personal information may be transferred as part of such transactions, We will ensure the confidentiality of such information when it is transferred and require the new company or organization that holds your personal Information to continue to be bound by this Policy, otherwise we will require the company or organization to re-seek authorization from you.

(3) PUBLIC DISCLOSURE

We will not publicly disclose your personal information unless we obtain your express consent.

We may disclose your personal information to competent authorities based on laws, legal procedures, lawsuits or mandatory requirements of competent government authorities. However, we guarantee that in the event of the above, we will require the disclosure requesting party to issue valid legal documents corresponding to it, and take security measures that comply with legal and business standards for the disclosed information.

4．Minor (i.e person under 18) information protection.

We take the protection of minors’ information very seriously. You understand and agree that we only provide TopChance products and/or services to adults who are registered under their real names and have full capacity for civil rights and civil conduct as stipulated by law and are able to independently bear civil liabilities. If you are under 18 years of age, we will not provide services to you (except for limited browsing without registration).

If you are the guardian of a minor, when you notice that the minor under your guardianship uses the products and/or services on the Platform or the personal information provided to us by yourself, please contact us in time.

5.How we update and modify this policy.

We reserve the right to update this policy in due course in order to provide you with better services and business development needs. We will not reduce your rights under this Policy without your express consent. If this policy is updated, we will update it in a timely manner on the TopChance App and notify you in a reasonable manner (including but not limited to pop-up prompts, prominent positions on the page, App push notifications, emails/sms messages, etc.) so that you can keep abreast of any changes made to this policy.

For major changes, depending on specific circumstances, we may also provide more prominent notices stating specific changes to this policy. Please note that we will only collect, use, share and store your personal information in accordance with our updated Personal Information Protection policy after you reauthorize it. Important changes include, but are not limited to:

(1) Our service model and business form have changed significantly. Such as the purpose of processing personal information, the type of personal information processed, the use of personal information, etc.;

(2) We have undergone major changes in ownership structure, organizational structure and so on. Such as business adjustment, bankruptcy merger and acquisition caused by the owner change;

(3) The main object of personal information sharing, transfer or public disclosure changes;

(4) Significant changes in your rights to participate in the processing of your personal information and the manner in which they are exercised;

(5) Changes in the contact information and complaint channels we are responsible for handling the security of personal information;

(6) Personal information security impact assessment report indicates that there is a high risk.

If you do not agree to the revised Personal Information Protection Policy, you have the right and should immediately stop using TopChance products and/or services. If you continue to use TopChance products and/or services after this Policy is updated, you will be deemed to accept the modification of the relevant terms of this Policy. In case of any inconsistency or conflict between the terms of this Policy and the terms of protection and authorization of personal information protection stipulated in any service agreement adopted by the Platform, the relevant terms of this policy shall prevail. You can check this policy in TopChance App [Me → Privacy Policy]. We encourage you to check the personal Information protection policy every time you use TopChance products/services.

6． How to Contact us.

We will use your data for the purposes of compiling statistics relating to our user base or loan portfolio and may disclose such information to any third party for such purposes, provided that such information will always be anonymous.

If we wish to use your information for marketing purposes, we will inform you prior to such use. You shall be entitled to prevent such usage by informing us, within 10 days of being informed of the proposed use, that you do not wish to disclose such information. You can also exercise the right at any time by contacting us at help service@topchance.club

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