Last updated 15th Feb, 2022
Flickwheel is a Non-Banking Financial Institution that provides sub-finance for Automobile services. As the data collector, Flickwheel ("we" “us” “our”) are committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting "https://flickwheel.com" or using Flickwheel mobile application hosted on the Google Play Store or Apple Play Store (collectively “our site”) you are accepting and consenting to the practices described in this policy.
You may give us information about you by filling in forms on our site https://flickwheel.com and by allowing us to access your information on social media sites (including but not limited to Facebook, Twitter and LinkedIn) or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site, apply for a loan, search for a feature (for example but not limited to, loan amounts, currency, loan duration), your activity levels on boards or other social media functions on the applicable social media sites, the applications you use on social media sites, and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, login information for social networking sites, financial and credit card information, personal description, current and former places of employment, education, names of colleagues, contacts and friends, photographs, and lists of family members.
With regard to each of your visits to our site, we may automatically collect the following information:
We may receive information about you if you use any of the other websites we operate, the other services we provide and/or the social media sites which you login to via our site. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, social media sites, advertising networks, analytics providers, search information providers, credit bureaus, and financial services and credit providers) and may receive information about you from them.
We use information held about you in the following ways:
We will use your information in the following ways and in each case, we note the lawful basis under the Nigerian Data Protection Regulations which we rely on to use your information.
Lawful basis- Contract performance, consent, legal obligation
b. To investigate or resolve any complaint and issues you may have.Lawful basis- Contract performance, consent
c. To exercise our rights under contracts we have entered into with you like recovering any payments due to us and where necessary to enforcing recovery through debt collection agencies or taking other legal action, including instituting an action in the courts of law.Lawful basis- Contract performance
d. To fulfill our legal, compliance, regulatory and risk management obligations.Lawful basis- Legal obligation
e. To establish a credit rating based on your information and provide that rating to third parties who may be interested in offering you financial products and services and this information is provided only to third parties selected by you or where you have agreed that we may share your score and information with;Lawful basis: Consent
f. To provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about; anonymized repayment data.Lawful basis: Consent
Lawful basis- Contract performance
Lawful basis- Contract performance
We will use this information:
When you use our services, we collect location data which allows us to determine your precise or approximate location. This information is collected during the auto service loan application process, and we use this data to enhance our credit risk and underwriting framework, as well as to prevent fraud.
We also collect the following information saved on your smartphone:
We collect this information through your mobile device operating system, by requesting your express consent to your device's permissions on the App. The collection of this information may take place in the background even when you aren't using our service, if the permission you gave us expressly permits such collection.
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries. We may share your information with selected third parties including:
Information that we collect may be stored, processed in, and transferred between any of the countries in which we operate, in order to enable us to use the information in accordance with this policy. Any such information transferred to other countries shall be in compliance with the Act and the Regulations.
Our website and services are not directed to children under 18. We do not knowingly provide auto services to children under 18.
Information that we collect may be stored, processed in, and transferred between any of the countries in which we operate, in order to enable us to use the information in accordance with this policy. Any such information transferred to other countries shall be in compliance with the Act and the Regulations. By ticking the "I agree to the Terms and Conditions", which you hereby adopt as your electronic signature, you consent and agree that: We can provide materials and other information about your legal rights and duties to you electronically. We are authorised to share, receive and use data/information collected from your transaction with other affiliated third parties including but not limited to switching companies, mobile network operators, electricity companies, aggregators, credit bureaus, other financial institutions, e-commerce platforms etc.
Individuals who have Personal Information held by Flickwheel are entitled to reach out to Flickwheel to exercise the following rights:
The data that we collect from you is stored on our secure servers using JWT. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
Unless a longer retention period is required or permitted by law, we will only hold your data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy. Even if we delete your data, it may persist on backup or archival media for legal, tax or regulatory purposes.
You have the right to ask us not to process your personal data for marketing purposes and to withdraw your consent at any time. Please note that the withdrawal of your consent will not affect the lawful processing of data which we have obtained based on your previous consent. We will usually inform you (before collecting your data) if we intend to use your data for the aforementioned purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us using in-app support feature on the mobile application or using the chat button on the web portal at www.flickwheel.com. Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Each of the parties will be entitled to enforce its rights in the event of a breach of the terms of this privacy policy, to recover damages caused by any breach of the provisions herein and to exercise all other rights existing under law. Any claim or dispute arising in relation to this privacy policy shall be subject to the jurisdiction of the courts of the Federal Republic of Nigeria. We shall not be liable for any breach where a claim in respect of such breach is not brought within one month of the date that such breach arose.
Notwithstanding any other provision in this privacy policy, neither Flickwheel, its affiliates, officers, directors, employees, attorneys or agents shall have any liability with respect to, and you hereby waive, release and agree not to sue any of them upon, any claim for any special, indirect, incidental, consequential damages suffered or incurred by you in connection with, arising out of, or in any way related to, a breach of this privacy policy.
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee in providing you with details of the information we hold about you. We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you understand any changes to this policy.
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to our Customer Support via the in-app Help & Support feature on the mobile application or using the Live Chat on the website at flickwheel.com