Privacy Policy

1. Who We Are

Data Controller: Life-at-Ease Port-Harcourt Multi-purpose Co-operative Society Limited

Trading as: EESCREDIT

Address: 21 Emekuku Street, DLine, Port Harcourt, Rivers State, Nigeria

Email: support@eescredit.com

Platform: https://user.eescredit.com

2. What Data We Collect

2.1 Registration Data

• Full name, email address, phone number
• Date of birth, gender, residential address
• Membership tier and account type
• Profile photograph (optional)
• Credit source and business name (collected during onboarding)

2.2 Identity Verification Data Sensitive

• National Identification Number (NIN)
• Bank account number and bank name (for KYC Level 2 and withdrawal verification)
• Government-issued identity data returned by the verification provider

2.3 Financial Data

• Savings account balances and transaction history
• Loan applications, repayment schedules and payment history
• Cooperative Rotation (Esusu) group membership, contribution records and payout history
• Group-Guaranteed Loan applications and guarantee records
• Deposit and withdrawal requests
• Voucher issuance and redemption records

2.4 Technical Data

• IP address, browser type, device type
• Session tokens and cookies
• Login timestamps and activity logs
• OTP request and verification logs

2.5 Agent Data

• Agent application details including NIN and guarantor references
• Transaction records processed by the agent
• Commission earnings and impress account activity

2.6 Communications

• Messages sent via our contact form
• SMS and email correspondence with support

3. NIN & Identity Data

3.1 Why We Collect NIN

Your National Identification Number is required under cooperative regulatory guidelines to verify your identity before you can access transfers, loan applications and withdrawals. NIN verification is processed through Prembly IdentityPass, a licensed identity verification provider in Nigeria. A fuzzy name-match check is applied — your registered name must match the NIMC record to a sufficient degree. If a match cannot be confirmed automatically, you will be directed to an agent for assisted verification.

3.2 Why We Collect Bank Account Details

Bank account details are collected to verify your identity at KYC Level 2 and to process approved withdrawals to your verified account. Account resolution is performed via Flutterwave's secure API.

3.3 How Identity Data is Protected

• NIN is never displayed in full on screen after submission
• Identity verification calls are made over encrypted HTTPS connections
• Access to identity records is restricted to authorised administrators only
• NIN uniqueness is enforced — the same NIN cannot be registered by two members or by both a member and a Rotation Admin
• On successful NIN verification, your registered name is updated to match the NIMC record as the authoritative source

3.4 Third-Party Identity Processors

Provider	Purpose	Data Shared
Prembly IdentityPass	NIN verification	NIN, name, date of birth
Flutterwave	Bank account resolution and payment processing	Bank account number, bank code

4. How We Use Your Data

Purpose	Legal Basis
Create and manage your cooperative account	Contract performance
Guide you through the onboarding process	Contract performance
Verify your identity (KYC)	Legal obligation / Contract
Process savings, loans, transfers and withdrawals	Contract performance
Send SMS and email transaction alerts	Contract performance
Manage Cooperative Rotation contributions and payouts	Contract performance
Process Group-Guaranteed Loan applications and guarantees	Contract performance
Process agent applications and manage agent activity	Contract performance
Detect fraud and prevent unauthorised access	Legitimate interest
Comply with regulatory requirements	Legal obligation
Respond to your support enquiries	Legitimate interest
Send service announcements and policy updates	Legitimate interest

We do not use your data for third-party advertising, data brokering or automated profiling that produces legal effects without human review.

5. Who We Share Data With

We share your data only where necessary for the operation of our services:

• Prembly IdentityPass — NIN verification (licensed Nigerian provider)
• Flutterwave — Payment processing and bank account resolution
• Paystack, Stripe, PayPal, Razorpay, Mollie — Online payment processing where selected by the member
• Sendchamp — SMS delivery for OTP codes, transaction alerts and reminders
• Our hosting provider — Server infrastructure (Ubuntu 24.04, managed via HestiaCP)
• Regulatory authorities — Where required by Nigerian law or court order

We do not sell, rent or trade your personal data to any third party for their own marketing or commercial purposes.

Within the cooperative, limited member data (name and account number) may be visible to other members where the platform feature requires it — for example, a guarantor can see the name of the member they are guaranteeing, and a Rotation Admin can see the names of members in their group.

6. Data Retention

• Active account data — retained for the life of your membership plus 6 years after account closure (regulatory requirement)
• Transaction records — 7 years minimum (CBN guidelines)
• KYC and identity records — 5 years after account closure
• Contact form messages — 12 months
• Server and activity logs — 90 days
• OTP logs — 30 days

7. Security

We implement the following measures to protect your data:

• All data transmitted between your device and our servers is encrypted using TLS 1.2+
• Passwords are hashed using bcrypt — never stored in plaintext
• Two-factor authentication (2FA) is available on all accounts
• OTP verification is required for withdrawals and sensitive actions
• Role-based access controls restrict staff access to member data
• Regular database backups with secure storage
• Production servers are managed with restricted access controls

Despite these measures, no system is entirely secure. If you suspect unauthorised access to your account, contact us immediately at support@eescredit.com or change your password immediately.

8. Your Rights

Under the Nigeria Data Protection Act 2023, you have the right to:

• Access — request a copy of the personal data we hold about you
• Correction — request correction of inaccurate or incomplete data
• Deletion — request deletion of your data where we have no legal obligation to retain it
• Objection — object to processing based on legitimate interest
• Portability — receive your data in a structured, machine-readable format
• Withdraw consent — where processing is based on consent

To exercise any of these rights, email support@eescredit.com with the subject line "Data Rights Request". We will respond within 30 days. Note that some requests may be limited where we have a legal obligation to retain data (for example, transaction records).

9. Cookies

Our public website (eescredit.com) uses only essential cookies required for the contact form and session management. We do not use advertising or tracking cookies. See our Cookie Policy for full details.

The member portal (user.eescredit.com) uses session cookies necessary for authentication and security. These cannot be disabled without breaking platform functionality.

10. Children's Privacy

EESCREDIT services are not directed at persons under the age of 18. We do not knowingly collect personal data from minors. If you believe a minor has registered an account, please contact us immediately and we will delete the account and associated data promptly.

11. Changes to This Policy

We may update this Privacy Policy from time to time. When we make significant changes, we will notify active members via email and post a notice on the platform. The "Last updated" date at the top of this page always reflects the most recent revision. Continued use of EESCREDIT services after changes are notified constitutes acceptance of the updated policy.

12. Contact Us

For privacy-related questions, data requests or complaints:

• Email: support@eescredit.com
• Address: 21 Emekuku Street, DLine, Port Harcourt, Rivers State, Nigeria
• Hours: Monday–Friday 8:00 AM–6:00 PM | Saturday 9:00 AM–4:00 PM

If you are not satisfied with our response, you may lodge a complaint with the Nigeria Data Protection Commission (NDPC) at ndpc.gov.ng.