Privacy Policy & Data Notice

1. Introduction and Data Controller

Nelgro Financing Asset Management Limited ("Nelgro", "we", "our") is the Data Controller responsible for your personal information collected during equipment financing applications, underwriting evaluations, and lease agreements.

We are committed to safeguarding personal data in accordance with the Nigeria Data Protection Act (NDPA) 2023 and guidelines issued by the Nigeria Data Protection Commission (NDPC).

2. Categories of Information We Collect

• Government Identity Information: National Identification Number (NIN) matched against the National Identity Management Commission (NIMC) database, and Bank Verification Number (BVN) validated via NIBSS.
• Commercial & Business Data: CAC registration certificates, trade association membership IDs (e.g. Triple E ID, Garment Cluster ID), business address utility bills, and bank statements.
• Biometric & Liveness Verification: Facial photographs and real-time liveness selfies collected to prevent synthetic identity theft and impersonation.
• Guarantor Credentials: Full names, phone numbers, email addresses, and identity documents provided by two appointed guarantors.
• Telematics & Telemetry Data: For movable machinery and vehicles, GPS tracking coordinates, speed indicators, and engine telemetry captured via onboard IoT devices.

3. Lawful Basis and Purpose of Processing

We process your personal information strictly under the following lawful bases:

• Contractual Necessity: To assess equipment creditworthiness, approve lease facilities, disburse vendor payments, and administer monthly direct-debit mandates.
• Legal & Statutory Compliance: To comply with Anti-Money Laundering (AML) / Combating Financing of Terrorism (CFT) laws, Central Bank of Nigeria (CBN) regulations, and tax reporting.
• Legitimate Interests: To protect equipment assets against fraud, conduct asset recovery where necessary, and secure our financing platform.

4. Third-Party Sharing and Disclosures

Nelgro does not sell or rent personal information to advertisers. We share information only with authorized entities:

• Licensed Credit Bureaus (CRC, FirstCentral, CreditRegistry) for credit underwriting as mandated by CBN.
• NIMC, NIBSS, and licensed Identity Verification partners for identity validation.
• Partnering OEM vendors to verify equipment delivery locations.
• Law enforcement agencies and regulatory bodies pursuant to valid court orders or statutory subpoenas.

5. Data Security and Confidentiality

All applicant dossiers, biometric data, and financial records are encrypted in transit using TLS 1.3 and at rest using AES-256 encryption. Access within Nelgro is strictly role-gated with automated immutable audit logs recorded for every inspection of sensitive KYC documents.

6. Your Rights under NDPA 2023

Under the Nigeria Data Protection Act, you possess the right to:

• Request access to copies of personal data held by Nelgro.
• Request correction of inaccurate or incomplete personal records.
• Object to automated underwriting decisions and request human credit officer review.
• Request data erasure subject to mandatory statutory financial record-retention obligations (typically 6 years post-lease settlement).

7. Data Protection Officer (DPO) Contact

For privacy inquiries, data subject access requests, or regulatory questions, contact our dedicated Data Protection Officer: