PRIVACY POLICY
Last Updated: 1st August 2025
This Privacy Policy ("Policy") sets out the terms under which Sapphire Virtual Networks Limited ("Sapphire", "we", "us" or "our") collects, uses, stores, shares, and protects personal data obtained from you ("you", "User" or "Data Subject") when you access or use any of our websites, platforms, applications, or services (collectively, the "Services").
By accessing or using our Services, you confirm that you have read and understood this Policy, and you consent to the collection and use of your data as described herein. If you do not agree with any part of this Policy, you must immediately stop using the Services.
Sapphire is committed to handling your personal data in compliance with the Nigeria Data Protection Regulation (NDPR), and where applicable, other relevant data protection laws such as the General Data Protection Regulation (GDPR).
This Policy applies to all individuals whose data we may process, including customers, website visitors, loan applicants, service users, and representatives of partner institutions.
1. INTRODUCTION
1.1 Sapphire Virtual Networks Limited ("Sapphire", "we", "our", or "us") is committed to protecting your privacy and ensuring the security of your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our websites, applications, and services (collectively, the "Services").
1.2 We process your personal data in accordance with the Nigeria Data Protection Regulation (NDPR), and where applicable, the General Data Protection Regulation (GDPR), and other relevant data protection laws.
1.3 By accessing or using our Services, you acknowledge that you have read, understood, and agreed to the practices described in this Privacy Policy. If you do not agree with the terms herein, you should not use our Services.
1.4 This Policy applies to all users of our Services, including customers, website visitors, applicants, and individuals whose data we may process as part of delivering financial, insurance, or technology-enabled solutions.
2. WHAT PERSONAL DATA WE COLLECT
We collect personal data that you voluntarily provide or that we receive from third parties in connection with your use of our Services. This may include identifying information (such as name, phone number, and email), contact details, national identification and BVN, financial and employment information, technical data (such as IP address and device identifiers), as well as records related to your loan applications, device financing, or claims. We may also collect data about your usage of our websites or mobile applications, and any communications you have with us.
Where required, we collect this data to verify your identity, fulfil a contract, meet legal obligations, or protect our legitimate interests.
3. HOW WE COLLECT YOUR DATA
3.1 Direct interactions: When you apply for a service, fill out a form, contact us, submit a complaint, or create an account on our platform.
3.2 Automated technologies: When you interact with our website or mobile apps, we may collect technical and usage data through cookies, device logs, or similar tools.
3.3 Third-party sources: We may receive data from financial institutions, telecom partners, employers, device vendors, credit bureaus, identity verification providers, and insurance partners, as permitted by law and our agreements.
Where required by law, we will obtain your explicit consent before collecting certain categories of data or before processing it for specific purposes (such as marketing or cross-border transfers).
4. HOW WE USE YOUR DATA
4.1 Service Delivery
4.1.1 To provide you with access to device financing, solar credit, protection plans, payday loans, and other products
4.1.2 To process applications, verify your identity, assess eligibility, and administer billing or repayments
4.2 Customer Support and Communication
4.2.1 To respond to enquiries, requests, complaints, or feedback
4.2.2 To send transactional messages, service updates, or account notifications
4.2.3 To manage your profile, preferences, or user settings
4.3 Compliance and Risk Management
4.3.1 To comply with legal, regulatory, or contractual obligations
4.3.2 To enforce agreements and mitigate fraud, misuse, theft, or default
4.3.3 To conduct background checks, identity verification, and KYC/AML screening where applicable
4.4 Marketing and Engagement
4.4.1 To provide offers, surveys, promotions, or campaigns (with your consent, where required)
4.4.2 To personalise communications and recommend relevant products
4.4.3 To analyse usage trends, audience segments, and improve engagement
4.5 Analytics and Product Improvement
4.5.1 To assess platform performance and usage trends
4.5.2 To detect and fix bugs, security issues, or performance gaps
4.5.3 To develop, test, or refine new products, services, or platform features
We will not use your data for any purpose inconsistent with this Policy without notifying you and, where required, obtaining your explicit consent.
5. HOW WE SHARE YOUR DATA
5.1 Service Providers and Partners
5.1.1 Payment processors, banks, and financial institutions involved in loan disbursement or repayment
5.1.2 Credit bureaus, verification services, and risk assessment providers
5.1.3 Device vendors, telecom providers, and logistics partners for delivery or activation
5.1.4 Insurance companies and claims processors for protection plans
5.2 Regulatory Authorities
5.2.1 Government agencies, law enforcement bodies, courts, or regulators in accordance with legal or regulatory requirements
5.2.2 When responding to lawful requests, subpoenas, or court orders
5.3 Business Affiliates
5.3.1 Our authorised agents, subsidiaries, or affiliates that support the delivery of our Services
5.3.2 In the event of a merger, acquisition, restructuring, or sale of assets, where user data may be transferred as part of the transaction
5.4 Technology and Analytics Providers
5.4.1 Cloud hosting and IT infrastructure partners
5.4.2 Data analytics, marketing, and communications platforms (subject to applicable consent)
5.4.3 Fraud detection, security monitoring, or recovery service providers
We do not sell your personal data to third parties. All data sharing is subject to appropriate contractual safeguards, including data processing agreements where required, and we ensure that recipients uphold equivalent levels of privacy and security.
6. HOW WE STORE AND PROTECT YOUR DATA
6.1 Data Storage
6.1.1 Your data is stored securely on servers located within Nigeria or in jurisdictions that offer adequate data protection, subject to applicable legal safeguards. In some cases, we may use cloud-based infrastructure that complies with international security certifications and legal requirements for data transfer.
6.2 Security Measures
6.2.1 Access control and user authentication
6.2.2 Data encryption at rest and in transit
6.2.3 Firewall and intrusion detection systems
6.2.4 Regular system monitoring, vulnerability scanning, and auditing
6.2.5 Physical security for on-premise infrastructure and devices
6.3 Data Minimisation and Retention
6.3.1 We retain your personal data only for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying legal, regulatory, tax, accounting, or reporting requirements. In some circumstances, we may retain your data for longer periods if required by law or for the establishment, exercise, or defence of legal claims.
6.3.2 Where data is no longer needed, we securely delete or anonymise it in accordance with our data retention policy.
7. COOKIES AND TRACKING
7.1.1 Our Services use cookies and similar technologies (e.g. web beacons, device identifiers) to improve functionality, analyse traffic, personalise content, and enhance user experience.
7.2.1 Cookies may be placed by us or by authorised third parties (e.g. analytics providers). These may include:
7.2.2 Strictly necessary cookies -- for site security and functionality
7.2.3 Performance cookies -- for analytics and traffic monitoring
7.2.4 Functional cookies -- to remember preferences
7.2.5 Advertising cookies -- to deliver targeted content, where applicable
7.3.1 By using our Services, you consent to the placement and use of these cookies, subject to your preferences. You may control or delete cookies through your browser settings or by using opt-out tools where available.
8. CHANGES TO THIS PRIVACY POLICY
We may update or revise this Privacy Policy from time to time to reflect changes in legal requirements, business operations, or technology. When we make material changes, we will notify you by updating the "Last Updated" date at the top of this Policy, and, where appropriate, we may provide additional notice (e.g. via email or in-app notification). We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your personal data.
Your continued use of the Services after any updates constitutes your acceptance of the revised Policy.