Privacy notice

SWM FINANCE runs rotating savings (Ajo) groups. We decide how and why your personal data is used, which makes us the data controller for it.

• Business name: SWM FINANCE
• Email: info@swmfinance.com
• Phone: +234 816 708 1067

When you contact us or apply to join:

• your name, phone number and email address;
• the savings plan you are interested in, and anything you write to us;
• the internet address and browser your form came from, and the time you agreed to this notice.

When you become a member, also:

• your date of birth, gender, home address, city, state and occupation;
• the name, phone number and relationship of your next of kin;
• your photo and any identity or other documents you give us;
• the bank account your payouts are paid into;
• your SWM member code, your groups and your payout position;
• every contribution, payment, receipt, proof of payment, charge and payout on your account, and any transfer you report to us;
• your sign-in details: email, phone, when you signed in, and your two-step sign-in setting. Your password is stored only in a scrambled form that nobody at SWM can read;
• the messages we send you, and any request you make to us.

We do not collect your BVN, your card details, or your online banking details, and we will never ask for your bank PIN or password.

• To run your membership. Recording what you pay, what you owe and when you will be paid is the service you join for. The legal basis is our contract with you, and the steps you ask us to take before it (your application).
• To keep financial records. A savings business must keep accurate records of money received and paid out. The legal basis is the legal obligations that apply to us.
• To keep the system and your money safe. We record who did what and from where, to stop fraud, misuse and mistakes. The legal basis is our legitimate interest, and yours, in a system nobody can quietly change.
• To answer your questions and requests. The legal basis is our legitimate interest in replying to you, or our contract with you if you are a member.

Inside SWM, staff see members only in the groups they manage, and only staff with a specific permission can see full bank account numbers. Every change to your record is logged with who made it.

Other members of your group see the group’s progress, not your name, your balance or your bank details.

We use a small number of service providers to run the system:

• an email delivery provider, which sends our emails to you;
• a cloud hosting provider, which runs our system and stores its database;
• a website and file storage provider, which serves this website and stores uploaded documents and proofs.

They process your data only on our instructions. We do not sell your personal data, and we do not share it for anybody else’s marketing. We will share it with the police, a court or a regulator only when the law requires us to.

Our hosting, storage and email providers keep data in data centres in Europe and the United States. The Nigeria Data Protection Act allows this where the data stays protected, and we use providers that commit by contract to keeping it secure and confidential.

• Members: for as long as you are a member, and afterwards for as long as the law requires a business to keep its financial records.
• Refused applications: the personal details are removed one year after the decision.
• Questions sent through this website: the personal details are removed one year after we close them.
• Internet addresses recorded with a form are removed after 90 days.
• Uploaded files that are never attached to a record are deleted after one day.

Everything travels over an encrypted connection. Staff sign in with their own account and, where required, a second step on their phone. Staff see only what their job needs, a recorded payment is never edited or deleted, and every change is logged. If something goes wrong that puts your data at risk, we will tell the Nigeria Data Protection Commission within 72 hours, and tell you if you are affected.

Under the Nigeria Data Protection Act you have the right to:

• be told how your data is used (this notice);
• get a copy of your personal data, in a form you can take elsewhere;
• have wrong or incomplete details corrected;
• have your personal details removed when we no longer need them;
• object to, or ask us to limit, how we use them;
• withdraw any consent you gave, at any time.

Members can download a copy of their data, and ask for a correction or for their details to be removed, from their account under Your data. Anyone can also ask us directly: info@swmfinance.com or +234 816 708 1067.

Removal has one limit. We must keep the record of money you paid and received, so when your details are removed those records stay, under your member code only. We cannot remove your details while you still have a place in a group, or while money is owed either way; we will tell you what needs settling first.

If you are unhappy with how we have handled your data, tell us first: info@swmfinance.com or +234 816 708 1067. We will look into it and reply.

You also have the right to complain to the Nigeria Data Protection Commission (NDPC), at ndpc.gov.ng.

When we change this notice, we change the date at the top. If a change affects how we use your data in a way you would care about, we will tell members before it takes effect. You can always read the current version on this page, and the member terms that go with it.