Member Privacy Policy

1 Who We Are

When you use CoopSolve, two organizations are responsible for your data:

1.1 Firstlincoln Technologies Limited (Platform Provider)

We develop and maintain the CoopSolve platform. We are responsible for:

• Keeping the platform secure and operational
• Protecting the technical infrastructure that stores your data
• Ensuring the platform complies with Nigerian data protection laws
• Providing technical support and resolving platform issues

1.2 Your Cooperative Society (Data Controller)

Your cooperative is the primary custodian of your membership data. They are responsible for:

• Deciding what information to collect from you
• Managing your membership and financial records
• Setting policies for how your data is used within the cooperative
• Responding to your requests about your cooperative records

2 What Information We Collect

To provide you with cooperative services, we collect the following types of information:

2.1 Personal Information

• Identity Details: Full name, date of birth, gender, photograph, and nationality
• Contact Information: Phone number, email address, home address, and work address
• Identification Documents: National ID (NIN), Bank Verification Number (BVN), passport, driver's license, or voter's card
• Employment Details: Employer name, job title, and work contact (if required by your cooperative)
• Next of Kin: Emergency contact and beneficiary information

2.2 Financial Information

• Bank Details: Your bank account number and bank name for transactions
• Savings Records: Deposits, withdrawals, and contribution history
• Loan Information: Loan applications, amounts, repayment schedule, and payment history
• E-Wallet Data: Wallet balance, funding history, and transfer records
• Payment Records: Transaction dates, amounts, and references

2.3 Membership Information

• Membership ID and registration date
• Membership type and status (active, inactive, suspended)
• Monthly contributions and share capital
• Guarantor relationships (if you guarantee someone's loan or vice versa)

2.4 Technical Information (Collected Automatically)

• Device Information: Phone model, operating system, and app version
• Usage Data: When you log in, features you use, and how long you spend on the app
• Location: General location from your IP address (we don't track your precise GPS location unless you enable it)

3 Why We Collect Your Information

We only collect information that's necessary to provide you with cooperative services:

3.1 To Manage Your Membership

• Create and maintain your member account
• Track your membership status and contributions
• Keep records of your cooperative activities

3.2 To Process Your Financial Transactions

• Receive and record your savings deposits
• Process withdrawal requests
• Calculate interest on your savings
• Process loan applications and disbursements
• Track loan repayments
• Manage your e-wallet transactions

3.3 To Communicate With You

• Send transaction confirmations and receipts
• Remind you about loan repayments
• Notify you about cooperative meetings and announcements
• Alert you about account activity

3.4 To Keep Your Account Secure

• Verify your identity when you log in
• Detect and prevent fraud
• Protect against unauthorized access

3.5 To Comply With the Law

• Meet Central Bank of Nigeria (CBN) requirements
• Comply with anti-money laundering regulations
• Fulfill tax reporting obligations
• Respond to valid legal requests

4 Who Can See Your Data

We limit access to your personal information to those who need it:

4.1 Third-Party Service Providers

To provide certain services, we share limited data with trusted partners:

• Payment Processors (Paystack, Embedly, 9PSB, Banks): To process deposits, withdrawals, and transfers
• Identity Verification (NIBSS): To verify your BVN during registration
• SMS/Email Providers: To send you notifications and alerts
• VAS Providers: To process airtime, data, and bill payments

4.2 Legal Authorities

We may be required to share your information with government authorities when:

• Required by court order or legal process
• Requested by the Central Bank of Nigeria (CBN)
• Required for anti-money laundering investigations
• Necessary to prevent fraud or protect safety

5 How We Protect Your Data

We take the security of your information very seriously:

5.1 Technical Protection

• Encryption: Your data is encrypted when stored and when transmitted over the internet
• Secure Servers: Our servers are hosted in secure data centers with 24/7 monitoring
• Access Controls: Only authorized personnel can access your data, and access is logged
• Regular Updates: We regularly update our systems to protect against new threats

5.2 Financial Transaction Security

• PIN/Password Protection: All transactions require your secret PIN or password
• OTP Verification: High-value transactions require one-time passwords sent to your phone
• Fraud Detection: We monitor for suspicious activity and may block unusual transactions
• Session Timeout: You're automatically logged out after periods of inactivity

5.3 What You Can Do to Stay Safe

• Never share your password, PIN, or OTP with anyone—not even cooperative officials or CoopSolve staff
• Use a strong, unique password for your account
• Enable biometric login (fingerprint/face) if available
• Log out when using shared devices
• Report suspicious activity immediately
• Keep your phone and email secure—we send sensitive notifications there

6 Your Privacy Rights Your Rights

Under Nigerian data protection law (NDPR/NDPA), you have the following rights:

6.1 Right to Access

You can request a copy of all personal data we hold about you. We'll provide this within 30 days.

6.2 Right to Correction

If any of your information is incorrect or outdated, you can ask us to correct it. You can also update most information directly in the app.

6.3 Right to Deletion

You can request that we delete your personal data. However, we may need to keep some information for legal or regulatory reasons (like financial records for tax purposes).

6.4 Right to Data Portability

You can request your data in a format that allows you to transfer it to another service.

6.5 Right to Object

You can object to certain uses of your data, like marketing communications.

6.6 Right to Withdraw Consent

Where we process your data based on your consent, you can withdraw that consent at any time.

6.7 Complaints

If you're not satisfied with how we handle your data, you can lodge a complaint via email to legal@coopsolve.com.

7 Your Financial Data

Given the sensitive nature of financial information, we apply extra protections:

7.1 What Financial Data We Collect

• Savings deposits and withdrawals
• Loan applications, approvals, and repayments
• E-wallet transactions
• Bill payments and VAS purchases
• Bank account details for transfers

7.2 Special Protections for Financial Data

• All financial data is encrypted using bank-grade encryption
• We don't store your complete bank card numbers or CVV
• Transaction PINs are never stored in plain text
• Sensitive operations require multi-factor authentication

7.3 Credit Bureau Reporting

If you have an outstanding loan, your repayment history may be shared with licensed credit bureaus. This helps build your credit score for future loans but also means late payments may affect your credit record.

8 Mobile App Permissions

The CoopSolve mobile app requests certain permissions on your device:

You can manage these permissions in your phone's settings at any time. Denying certain permissions may limit some features.

9 Cookies and Tracking

When you use our website or web app, we use cookies (small files stored on your device):

9.1 Essential Cookies

These are necessary for the platform to work. They keep you logged in and remember your preferences. You cannot disable these.

9.2 Analytics Cookies

These help us understand how people use the platform so we can improve it. They don't identify you personally.

9.3 Managing Cookies

You can control cookies through your browser settings. Note that disabling cookies may affect how the platform works.

10 How Long We Keep Your Data

We keep your data for as long as necessary to provide services and comply with legal requirements:

When data is no longer needed, we securely delete or anonymize it.

11 Third-Party Services

We work with trusted partners to provide you with full service:

• Paystack, Embedly and 9 Payment Service Bank (9PSB): Handles e-wallet, payment processing and Verifies your Bank Verification Number (BVN)
• Banks: Process fund transfers to and from your bank accounts
• 9 PSB : Deliver airtime and data purchases
• Utility Companies: Process bill payments

These partners have their own privacy policies. When you use their services through CoopSolve, their policies also apply to how they handle your data.

12 Children's Privacy

CoopSolve is designed for adults (18 years and above). We do not knowingly collect information from children under 18.

If your cooperative/Fintech offers youth savings programs for members under 18, a parent or guardian must:

• Provide consent for the minor's registration
• Manage the account on behalf of the minor
• Be responsible for the minor's use of the platform

If you believe a child under 18 has created an account without parental consent, please contact us immediately.

13 Changes to This Policy

We may update this Privacy Policy from time to time. When we make significant changes:

• We'll update the date at the top of this policy
• We'll notify you through the app or by email
• For major changes, we may ask you to review and accept the new policy

We encourage you to review this policy periodically. Continuing to use CoopSolve after changes means you accept the updated policy.

14 Contact Us

If you have questions about this Privacy Policy or how your data is handled: