Privacy Policy
We, Eager Wings Nigeria Limited, are the Company that owns, develops, and operates the mobile software application Flash Loan and its associated financial and advertising services. We respect your privacy and ensure that all information that you enter in your Flash Loan account is treated confidentially and is processed in accordance with this Data Privacy Policy.
1. How to register, access and manage your Flash Loan account
1.1 Account registration
If you want to use the products/services on the Flash Loan platform, you first need to register a Flash Loan account. To create an account on the Flash Loan platform, we need to collect your mobile phone number and use it to mark your identity. If you refuse to provide your mobile phone number, we will not be able to create an account for you on Flash Loan or provide you with financial services. Under the same account, we may collect relevant information from your various devices and associate them to provide you with consistent, standardized services. If you refuse to provide the necessary information, you may not be able to use our services normally.
1.2 Account login
When you log in to the Flash Loan app for the first time using your mobile phone number, we will send you a verification code to verify your identity in order to comply with legal requirements and protect the security of your account.
1.3 User personal information authentication
In order to ensure that your information is true and provide you with better services, when using Flash Loan services, we need to authenticate your personal information (including application for services, payment, repayment, etc.). You need to provide and allow us to collect your identity information (including your name, date of birth, gender, marital status, work status, whether there are other loans, income, residential address, your phone number, email address, emergency contact information, etc.).This information is considered sensitive information.
1.4 Filling contact information
Before providing emergency contact information, users need to confirm that they have obtained the consent of the emergency contact. The information we collect includes the name and phone number of the emergency contact provided by the user and their relationship with you.
We will only contact the user's emergency contact in compliance with the requirements of relevant laws and regulations. For example, when the user is facing potential fraud risks, we will provide the user with the opportunity to understand the security of their funds through the emergency contact.
1.5 Customer service and dispute resolution
To protect the security of your account, our customer service will use your mobile phone number, name, related order information to verify your identity. When you need to know information related to the transaction, our customer service will also query your identity information, transaction information, browsing information and other information you provide when contacting customer service from the background. When you request customer service to assist in modifying information (such as personal information, contact information, etc.), you may need to provide more information. If you refuse to provide such information, you may not be able to use our services normally. When you contact us, we may retain your call records and related information. Such records will be automatically deleted after the legal retention period (30 days).
1.6 Loan and repayment processing
When using Flash Loan to borrow or repay, depending on the service, you need to provide bank card account or a mobile phone account information. If you refuse to provide the above information, you may not be able to use our services normally.
1.7 Products and information services
We may send you the latest information about products or services, such as Flash Loan loan product information, advertising promotions, etc., through in-app messages, text messages or phone calls.
1.8 Order management
When you use Flash Loan to handle business, the system will automatically generate an order. During the order management process, we may collect the following information:
Loan product related information
Emergency contact and phone number
Order information generated when using Flash Loan platform products and services, etc.
We collect this information to help you complete order transactions, payment settlement, order inquiry, order management and other related services. We may also use your order information to determine whether your transaction is normal and ensure the security of your transaction.The specific information will be displayed, prompted or authorized during the loan process. Please read carefully and complete the confirmation.
2. How we collect, process and use your personal information
The data we collect is mainly divided into two parts, the first part is the mobile phone data or system data authorized to us by the user, the second part is the data filled in by the customer when applying for the loan.
2.1 User-authorized data
2.1.1 Financial SMS
Collection type: We collect SMS data from users, but only SMS data related to users' financial transactions, including SMS content, sender number and other information.
Processing: We use filtering mechanisms ensure that only SMS data relevant to your financial transactions are collected and are processed securely using encryption technologies.
Use: We only access users' SMS data related to financial transactions, and it is used solely for credit risk assessment and fraud prevention analysis.Credit assessment helps us provide you with appropriate product limits and product interest rates. Risk management and fraud detection, including fraud, money laundering and other illegal activities, use financial-related SMS data as an important basis for assessing users' fraud risks and financial status, and help ensure that you can better use our products and services.
Security: Users may revoke SMS access at any time via device settings. Financial SMS data will be encrypted and uploaded to our server (https://api-ng.eagerwingsng.com) via HTTPS protocol, and we promise never to share this data with third parties.
2.1.2 Phone State
Collection type: Including but not limited to SIM card information, network operator information, mobile data connection status, device name, model, operating system, system version and other hardware information.
Processing: We utilize encryption technologies to process your phone state data securely.
Use: We used to check SIM and network operator information, and to validate device and mobile connection details during account verification and security checks to prevent unauthorized access.
Security: Users may revoke Phone State access at any time via device settings. Phone State data will be encrypted and uploaded to our server (https://api-ng.eagerwingsng.com) via HTTPS protocol, and we promise never to share this data with third parties.
2.1.3 Emergency Contacts
Collection type: Two emergency contacts, either manually provided or selected from your device's address book.
Processing: We process only the emergency contacts you designate. No other data from your phone book will be accessed, collected, or used.
Use: The emergency contacts are collected solely for the purposes of identity verification and fraud prevention.
Security: Emergency contact data will be encrypted and uploaded to our server (https://api-ng.eagerwingsng.com) via HTTPS protocol, and we promise never to share this data with third parties.
2.1.4 Advertising ID
Collection type: Device advertising identifier (AD_ID).
Processing: We process the advertising identifier in compliance with applicable data protection standards, ensuring it is handled securely.
Use: The advertising identifier (AD_ID) is used to measure app performance, analyze user acquisition sources, and support relevant advertising services in order to improve advertising performance.
Security: This data may be shared with third-party service providers (e.g., analytics or advertising partners) solely for these purposes. You can manage or reset this identifier anytime in your device settings.
2.1.5 Application Interaction
Collection type: Information on your interactions with the application, including usage patterns, feedback, and related data.
Processing: Interaction data is processed securely to maintain confidentiality and integrity, in accordance with applicable data protection standards.
Use: Collected interaction data is used to improve service quality, enhance product functionality, and support security measures such as detecting abnormal activity and preventing fraud.
Security: Data is stored and transmitted securely and is not shared with unauthorized third parties.
2.1.6 Application List
Collection type: Limited information on apps installed on your device, such as app names, categories, installation or update dates, and versions.
Processing: Collected app data is processed securely, ensuring confidentiality and compliance with applicable data protection standards.
Use: This information is used to support security checks, detect abnormal patterns, and help prevent fraudulent or unauthorized activity. We never access your full app inventory.
Security: Application List data will be encrypted and uploaded to our server (https://api-ng.eagerwingsng.com) via HTTPS protocol, and we promise never to share this data with third parties.
2.1.7 Calendar
Collection type: Limited information from your calendar, including event titles, start/end dates, and descriptions.
Processing: Collected calendar data is processed securely, with personal or non-financial events excluded, in compliance with data protection standards.
Use: Calendar data is used to provide loan-related reminders, verify authorized access, and support security and fraud prevention measures. All reminders require your explicit consent.
Security: Users may revoke calendar access at any time via device settings. Calendar data will be encrypted and uploaded to our server (https://api-ng.eagerwingsng.com) via HTTPS protocol, and we promise never to share this data with third parties.
2.1.8 Approximate Location
Collection type: Approximate device location when location services are enabled.
Processing: Collected location data is processed securely and in compliance with applicable data protection standards.
Use: Location information is used to support account security, prevent unauthorized access, and ensure compliance with regional regulations.
Security: Users may revoke location access at any time via device settings. Location data will be encrypted and uploaded to our server (https://api-ng.eagerwingsng.com) via HTTPS protocol, and we promise never to share this data with third parties.
2.1.9 Application Screen Time
Collection type: Limited data on your application usage, including frequency and duration of financial app use.
Processing: Collected usage data is processed securely and in compliance with applicable data protection standards.
Use: Application usage data is used for credit assessment and detecting abnormal fraud activity. Access requires your explicit consent.
Security: Users may revoke application screen time access at any time via device settings. This data will be encrypted and uploaded to our server (https://api-ng.eagerwingsng.com) via HTTPS protocol, and we promise never to share this data with third parties.
2.2 User's personal filling data
Type of collection: When you register as our user to apply for our loan, you need to fill in your basic information so that we can understand your identity information, including your name, date of birth, gender, marital status, work status, whether there are other loans, income, residential address, your phone number, email address, emergency contact information, etc.
Processing: We process your personal filling information securely by encrypting the data
Use: Filling of your basic information helps us to understand your basic situation clearly and we will use this basic data for your credit rating.
Security: The basic information data will be encrypted and uploaded to our server https://api-ng.eagerwingsng.com via HTTPS protocol, and we promise that we will never share this data with third parties.
3. How we share, transfer and publicly disclose your personal information
3.1 Share
We will not share your personal information with any companies, organizations and individuals outside of us, except in the following scenarios:
1) Explicit consent: After obtaining your explicit consent, we will share your personal information with other parties;
2) We may share your personal information publicly in accordance with laws and regulations, or in accordance with the mandatory requirements of other governmental authorities;
3) Sharing with partners: only for the purpose stated in this policy statement, some of our services will be provided by our partners, in this case we will require that the partner must comply with our privacy policy and security requirements. We will only share your personal information for purposes that are lawful, legitimate, necessary, specific and clearly identified, and will only share personal information that is necessary to provide the respective service. Our partners are not authorized to use the personal information we share about you for any other purpose than that agreed:
We share your personal encrypted information with third parties including but not limited to, banks, mobile network providers, collection agencies, our agents, suppliers, contractors, our business partners, etc., for the purposes of, or in connection with, our participation in or our co-operation with such third parties, which may include permitting such third parties to introduce or provide you with products or services or to carry out other activities, including marketing research, analysis and product development
3.2 Transfer
We will not transfer your personal information to any companies, individuals or organizations, except in the following scenarios:
1) Full consent: We will transfer your personal information to other parties after obtaining your full consent.
2) In the event of a merge, demerge, dissolution, acquisition, transfer of assets or similar transaction involving the transfer or provision of personal information, we will inform you of the name or contact information of the recipient and request the new company or organization holding your personal information to seek authorized consent from you again;
3.3 Public disclosure
We will only publicly disclose your personal information in the following scenarios:
1) Your full consent;
2) Disclosure based on laws and regulations: we may publicly disclose your personal information in the case of mandatory requirements of laws and regulations, legal procedures or governmental authorities, regulatory authorities;
3.4 Exceptions to prior authorized consent for sharing, transferring and public disclosure of personal information
In accordance with relevant laws and regulations and national standards, we are not required to obtain your prior authorized consent for sharing, transferring, or publicly disclosing your personal information in the following scenarios:
1) Related to the fulfilment of our obligations under laws and regulations;
2) Directly related to national security and national defense security;
3) Directly related to public safety, public health, and significant public interests;
4) Directly related to crime investigation, prosecution, trial and judgement execution;
5) For the purpose of safeguarding your or other individuals' life, property and other significant legitimate rights and interests but it is difficult to obtain individual consent;
6) The personal information involved is disclosed by you to the public on your own;
7) Necessary for the conclusion and performance of a contract at your request;
8) Where your personal information is collected from lawful public disclosure, such as from lawful news reports, government information disclosure and other channels;
9) Necessary for maintaining the safe and stable operation of our products or services, such as detecting and disposing of product or service malfunctions;
10) Other cases stipulated by laws and regulations.
4. How we store and protect your personal information
1) We will adopt various encryption technologies to encrypt and store your personal information, and the corresponding de-identification and other security technology measures;
2) We provide you with browsing services through https technology, and safeguard user data security through corresponding login SMS verification security mechanism, database encryption and log encryption measures;
3) We have established a data grading and classification management system, encrypted with your sensitive personal information such as mobile phone number and ID card number throughout the process, and set up strict data access privileges and operating privileges for personal information processing to ensure the safety of your personal data;
4) The data we collect from you may be stored on the Financial Cloud and we will take all reasonably necessary measures to ensure that your data is handled securely and in accordance with this Privacy Policy.
5) Notwithstanding the above technical security measures taken by us, please forgive and understand that in the Internet industry, due to the limitations and rapid development of technology and the possible existence of a variety of malicious means of attack, even if we do our best to strengthen the security measures, it is not always possible to ensure that 100% of the information is safe, and if our physical, technical or managerial protection facilities have been damaged, resulting in unauthorized access to, public disclosure of, alteration of or damage of the information. If our physical, technical or management protection facilities are damaged, resulting in unauthorized access, public disclosure, tampering or destruction of information, resulting in damage to your legitimate rights and interests, we will strictly in accordance with the provisions of the law to bear the corresponding responsibility.
5. Your rights
You have the right to know what we do with your personal information. Through this policy, we explain to you how we handle your personal information by way of collection, use, preservation, provision, etc. The way we provide you with the means to enquire, update, delete and protect such personal information.
1) Enquiry Information: You have the right to access your personal business-related information, such as historical application information, transaction information, or other information that cannot be displayed in the app You can contact our customer service at any time at the customer service email (flashloan@eagerwingsng.com), and we will respond to your request within 5 business working days;
2) Updating information: When you find that there is an error in the personal information we process about you, you have the right to ask us to make corrections. You can contact our customer service at any time via email (flashloan@eagerwingsng.com), and we will respond to your request within 5 working days.
3) Deletion of your personal information: You have the right to request the cancellation of your personal account on your own initiative, you can complete the cancellation of your account through the mobile phone APP by entering the 'Me-More-Cancel Account', or contact us through the means provided in the 'How to Contact Us' section of this Policy. or by contacting us in the manner provided in the 'How to Contact Us' section of this Policy;
6. How we use cookies and other technologies
To ensure that our websites work properly, we store small data files called cookies on your computer or mobile device, which usually contain an identifier, the name of the site and some numbers and characters. Cookies enable websites to store data such as your preferences; we do not use cookies for any purpose other than those described in this policy. You can manage or delete cookies according to your preferences; you can clear all cookies saved on your computer and most web browsers have a function to block cookies; however, if you do so, you will need to change your user settings yourself each time you visit our website.
7. How we handle the personal information of minors
Our products and services are intended for adults over the age of 18, and we do not actively collect or process information from minors under the age of 18. If you are a minor under the age of 18, please stop using Flash Loan products and services immediately
If you are a parent or guardian and you find that your child is fraudulently using your personal information to make loan application, please contact us promptly and we will take steps to delete all relevant information in a timely manner.
8. How this policy is updated
We may revise this policy from time to time in accordance with laws and regulations, requirements of regulatory authorities or the needs of business operations. After the revision of this policy, we will remind you through a pop-up window reminder to read and choose whether to agree to the latest version of the privacy agreement policy;
Normally, we will not reduce your rights according to this policy without your full consent. We will post on this page or otherwise notify you of any changes we make to this policy;
For major changes, we will also provide a more prominent notice. In such cases, if you choose to continue.to use our services, you agree to be bound by this Policy, as amended, and by material changes this Policy includes, but is not limited to:
1) Significant changes to our service model, such as the purposes for which personal information is processed, the types of information processed, and how personal information is used;
2) Significant changes in our ownership structure, organizational framework, etc. such as business restructuring, change of ownership due to bankruptcy and mergers and acquisitions, etc.;
3) Changes in the primary recipients of personal information shared, transferred or disclosed;
4) A significant change in your right to participate in the handling of personal information and how it is exercised;
5) When the security impact assessment report of personal information indicates that there is a high risk.
9. How to contact us
If you have any questions about this Privacy Policy or wish to access and/or correct your personal information, please contact us.
You can also contact us at any time if you have any questions about our business
Customer Service Email: flashloan@eagerwingsng.com