Privacy Policy

Edge Funds ("we", "us", "our") is committed to protecting your personal information in accordance with the Nigeria Data Protection Act 2023 (NDPA), the Nigeria Data Protection Regulation (NDPR), and all applicable laws. This Privacy Policy explains what data we collect, why we collect it, how we use and protect it, and your rights as a data subject.

By using our website or submitting a loan application, you consent to the practices described in this Policy.

Trading Name: Edge Funds

Registered Entity: The Edge EdTech Solutions (registered in Nigeria with the Corporate Affairs Commission)

Address: 3, Oladosu Oladipo Close, Ashi Area, New Bodija, Ibadan, Oyo State, Nigeria

Email: hello@edgefunds.com

Phone: 08063412267

Data Protection Officer: Contactable at dpo@edgefunds.com for all data protection matters, access requests, and complaints.

NDPC Registration: Our registration as a data controller with the Nigeria Data Protection Commission is in progress. Our registration number will be published here once issued.

We collect the following categories of personal data:

• Identity Data: Full name, date of birth, gender, nationality, state of origin, marital status
• Government Identifiers: Bank Verification Number (BVN), National Identity Number (NIN)
• Contact Data: Phone number, email address, residential and business address
• Financial Data: Bank account details for disbursement, loan amount requested, collateral details
• Documentary Data: Passport photographs, utility bills, signature specimens, NIN slips, CAC documents, blank cheques
• Next of Kin & Guarantor Data: Personal and contact details of your nominated next of kin and loan guarantor
• Technical Data: IP address, browser type, and usage data collected when you visit our website

What we never collect: We do not request, access, upload, or store your phone contacts, photo gallery, call logs, SMS messages, or device location. We do not require any device permissions in order to assess or administer your loan.

Data minimisation: Your BVN and NIN are requested at the verification stage, after your application has passed initial review, rather than at first enquiry. We do not collect security-question data such as your mother's maiden name.

• Performance of a contract: To assess, process, and administer your loan application and disburse funds
• Legal obligation: To comply with anti-money laundering (AML), Know Your Customer (KYC), and CBN/FCCPC regulatory requirements
• Legitimate interest: To detect fraud, manage credit risk, and improve our services
• Consent: To send you promotional information (you may withdraw consent at any time)

• Credit assessment and loan decisioning
• Identity verification and KYC compliance
• Loan disbursement and repayment management
• Communicating application status and updates
• Fraud prevention and risk management
• Regulatory reporting to FCCPC, CBN, and other relevant authorities
• Internal record-keeping and audit purposes

Your Bank Verification Number (BVN) and National Identity Number (NIN) are collected solely for the purpose of identity verification and credit assessment, in accordance with the CBN/NIBSS BVN framework and the Nigeria Data Protection Act 2023. These are never sold, shared with third parties for commercial purposes, or used for any purpose beyond those stated in this Policy. We do not use your BVN to access your bank accounts or initiate transactions.

We may share your data with:

• Credit bureaus (e.g. CRC Credit Bureau, FirstCentral) for credit scoring
• Banks and payment processors for loan disbursement
• Regulatory authorities (FCCPC, CBN, FIRS) as required by law
• IT and cloud service providers who process data on our behalf under strict data processing agreements

We do not sell your personal data to any third party.

Cross-border transfers: Some of our IT and cloud service providers process data on servers located outside Nigeria. Where this occurs, we transfer data only under the conditions permitted by section 41 of the NDPA 2023, which require an adequate level of protection in the destination country or binding contractual safeguards with the processor.

Part of our initial credit assessment is automated. We use the information you provide, together with credit bureau data, to generate an automated risk score which informs whether your application proceeds, is referred for manual review, or is declined, and on what terms.

Under the NDPA 2023 you have the right not to be subject to a decision based solely on automated processing where that decision significantly affects you. You may request that a member of our credit team review any automated outcome, and you may contest the outcome and provide additional context. To exercise this right, email dpo@edgefunds.com or hello@edgefunds.com.

We retain your personal data for a minimum of 6 years from the date of last transaction, in compliance with Nigerian financial records regulations. Data will be securely deleted or anonymised after the retention period expires unless a longer period is required by law.

Under the NDPA 2023, you have the following rights:

• Right to access your personal data
• Right to rectify inaccurate data
• Right to erasure ("right to be forgotten") where lawfully applicable
• Right to object to processing
• Right to data portability
• Right to withdraw consent at any time

You also have the right not to be subject to a decision based solely on automated processing, as described in section 7b above.

To exercise any of these rights, contact our Data Protection Officer at dpo@edgefunds.com with the subject line "Data Rights Request". We will respond within 30 days.

We implement appropriate technical and organisational security measures to protect your data against unauthorised access, alteration, disclosure, or destruction. These include encryption of sensitive data at rest and in transit, access controls, and regular security reviews.

Data breach notification: In the event of a personal data breach likely to result in a risk to your rights and freedoms, we will notify the Nigeria Data Protection Commission within 72 hours of becoming aware of it, and will notify affected individuals without undue delay, describing what happened, what data was involved, and what steps you should take.

Our website uses essential cookies to ensure basic functionality. No third-party advertising cookies are used. You can disable cookies in your browser settings, though this may affect some website features.

We may update this Privacy Policy from time to time. Any material changes will be communicated via email or a prominent notice on our website. Continued use of our services after changes constitutes acceptance of the updated Policy.

If you have concerns about how we handle your data, contact our Data Protection Officer at dpo@edgefunds.com.

You also have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) at ndpc.gov.ng.