Privacy Policy
1. Introduction
Zillion Cooperative Society is committed to protecting the personal data of our Members, whether resident in Nigeria or in the diaspora. This Privacy Policy explains what personal data we collect, why we collect it, how we use and protect it, and your rights, in accordance with the Nigeria Data Protection Act, 2023 ("NDPA") and, where applicable, other relevant data protection laws (such as the UK GDPR or EU GDPR for diaspora Members resident in those regions).
By using the Platform, you consent to the practices described in this Policy.
2. Who We Are
Zillion Cooperative Society is the data controller for personal data collected through zillion.ng/coop. Our Data Protection Officer (DPO) / privacy contact can be reached at support@zillion.ng.
3. Personal Data We Collect
We may collect the following categories of personal data:
3.1 Identity and Contact Data
- Full name, date of birth, gender, phone number, email address, residential/postal address, nationality;
- Government-issued identification (e.g., National Identification Number (NIN), international passport, driver's license, BVN where required for KYC).
3.2 Membership Data
- Membership number, membership class (local/diaspora), next of kin details, employment/occupation information.
3.3 Financial Data
- Contribution history, savings balances, loan applications and repayment records, bank account details (for disbursements), and transaction references from our Payment Gateway.
Note: We do not collect or store your full card numbers, CVV, or online banking passwords — these are captured directly and securely by our licensed Payment Gateway partner(s), not by Zillion.
3.4 Technical and Usage Data
- IP address, browser type, device information, log-in timestamps, and cookies (see Section 9).
3.5 Diaspora-Specific Data
- Country/region of residence, foreign bank details or remittance information where relevant to your contributions.
4. How We Collect Personal Data
- Directly from you, when you register, complete KYC, make a contribution, apply for a loan, or contact us;
- Automatically, through your use of the Platform (cookies, analytics);
- From our Payment Gateway partner(s), who share transaction confirmation data (such as amount, status, and reference) with us — but not your full card or bank credentials;
- From identity verification services, where used for KYC/AML compliance.
5. Why We Use Your Personal Data (Legal Basis)
We process your personal data on the following legal bases under the NDPA:
| Purpose | Legal Basis |
|---|---|
| Creating and managing your membership | Performance of a contract (membership agreement) |
| Processing contributions, loans, and benefits | Performance of a contract |
| KYC, AML, and fraud prevention checks | Compliance with legal obligation |
| Sending membership updates, statements, notices | Performance of a contract / legitimate interest |
| Marketing communications (e.g., new schemes) | Consent (you may opt out at any time) |
| Improving the Platform (analytics) | Legitimate interest |
| Responding to regulatory or law enforcement requests | Compliance with legal obligation |
6. Sharing Your Personal Data
We may share your personal data with:
- Payment Gateway providers, to process and settle your contributions;
- Regulatory and government bodies, including the Nigeria Data Protection Commission (NDPC), Cooperative Societies registrars, EFCC, or NFIU, where legally required;
- Professional advisers, such as auditors and legal counsel, under confidentiality obligations;
- IT and hosting service providers, who process data on our behalf under data processing agreements;
- Successors, in the event of a restructuring, merger, or transfer of Society operations, subject to equivalent data protection safeguards.
We do not sell your personal data to third parties.
7. International and Diaspora Data Transfers
7.1 As we serve Nigerian diaspora Members, your personal data may be processed or stored on servers located outside Nigeria (e.g., by our cloud hosting or Payment Gateway providers).
7.2 Where personal data is transferred outside Nigeria, we ensure such transfers comply with the NDPA's cross-border data transfer requirements — including verifying that the receiving country has an adequate level of data protection, or that appropriate safeguards (such as standard contractual clauses or your explicit consent) are in place.
8. Data Retention
We retain your personal data for as long as you remain a Member, and thereafter for a period necessary to comply with legal, regulatory, tax, accounting, or dispute-resolution requirements (typically up to [insert period, e.g., 6 years] after membership ends), after which it is securely deleted or anonymized.
9. Cookies and Tracking Technologies
We use cookies and similar technologies to operate the Platform, remember your preferences, and analyze usage. You can control cookies through your browser settings; disabling certain cookies may affect Platform functionality. See our [Cookie Notice] for details, where applicable.
10. Data Security
We implement appropriate technical and organizational measures — including encryption in transit, access controls, and staff confidentiality obligations — to protect your personal data against unauthorized access, loss, or misuse. However, no system is completely secure, and we cannot guarantee absolute security.
11. Your Rights
Subject to the NDPA and applicable law, you have the right to:
- Access the personal data we hold about you;
- Request correction of inaccurate or incomplete data;
- Request deletion of your data, subject to our legal and regulatory retention obligations;
- Object to or restrict certain processing (e.g., marketing);
- Withdraw consent at any time, where processing is based on consent;
- Request data portability, where technically feasible;
- Lodge a complaint with the Nigeria Data Protection Commission (NDPC), or the relevant data protection authority in your country of residence if you are a diaspora Member.
To exercise these rights, contact us at support@zillion.ng. We will respond within the timeframe required by the NDPA.
12. Children's Privacy
The Platform is not intended for individuals under 18 years of age, and we do not knowingly collect personal data from minors.
13. Changes to This Policy
We may update this Privacy Policy periodically. Material changes will be communicated via the Platform or by email/SMS. The "Last updated" date at the top reflects the most recent revision.
14. Contact Us
Zillion Cooperative Society — Data Protection Officer
Email: support@zillion.ng
Address: [insert registered address]
Phone: [insert phone]