Effective date: 3 October 2026
This notice is provided in a clear and accessible format as required by the NDPA. Acknowledging this policy is not itself consent to process your personal data.
1. Introduction and legal framework
Irorunde Global Investments Limited ("IGIL", "we", "our", or "us") is committed to protecting your personal data in line with the Nigeria Data Protection Act, 2023 (NDPA), the Nigeria Data Protection Act — General Application and Implementation Directive, 2025 (GAID), and guidance issued by the Nigeria Data Protection Commission (NDPC).
This Privacy Policy explains how we collect, use, store, share, and protect personal data when you visit our website, register as a member, apply for loans or EasyOwn financing, use our investment or thrift services, or otherwise interact with our platforms and staff.
Reading or acknowledging this Privacy Policy is not the same as giving consent to process your personal data. Where the law requires consent, we will ask for it separately in a clear and specific way.
2. Data controller identity and contact details
The data controller responsible for your personal data is:
- Name: Irorunde Global Investments Limited (IGIL)
- Place of business / address: 13, Akarigbo Street Isale Oko Sagamu
- Email: i.globalnvestments@gmail.com
- Phone: +2347047049835, +2348102854141
- Privacy / data protection requests: i.globalnvestments@gmail.com (mark the subject “Data Protection Request”)
3. Personal data we collect
Depending on the service you use, we may collect the following categories of personal data:
- Identity and contact data — full name, membership ID, email address, phone number, gender, age, marital status, and profile photograph.
- Address and business data — home and business addresses, business name, nature of business, and related KYC information.
- Financial and identification data — bank name, account number, BVN, means of identification and ID numbers, loan and investment balances, repayment history, and payment references.
- Guarantor and related-person data — information you or your guarantors provide for credit assessment.
- Transaction and service data — deposits, withdrawals, loan applications, EasyOwn records, thrifts, expenditures linked to member accounts, and communication history.
- Technical and usage data — IP address, browser type, device information, pages visited, login session data, and similar information needed to secure and improve our platforms.
- Staff / employment data (where you are staff) — role, branch, payslip, and staff-request information processed for employment administration.
4. Sources of personal data
We mainly collect personal data directly from you through registration forms, KYC, loan or investment applications, payments, and support channels.
We may also receive personal data from credit officers, guarantors, payment processors (such as Paystack), regulators, or other lawful sources where necessary to provide our services or meet legal duties. Where we obtain data from a third party, we will provide privacy information as required by the NDPA, unless an exemption applies.
5. Purposes of processing
We process personal data for the following purposes:
- To register and verify members, and to manage member accounts.
- To assess, approve, disburse, and service loans, EasyOwn financing, investments, thrifts, and related products.
- To process payments, receipts, withdrawals, and accounting records.
- To communicate about applications, repayments, statements, and service updates.
- To detect, prevent, and investigate fraud, abuse, or security incidents.
- To meet legal, regulatory, tax, audit, and record-keeping obligations in Nigeria.
- To improve our website, member portal, and internal operations.
- To handle complaints, staff requests, and data-subject rights requests.
6. Lawful bases for processing (NDPA)
We process personal data only where at least one lawful basis under the NDPA applies, including:
- Consent — where you have given clear, informed, and specific consent (for example, certain optional communications or cookies beyond strictly necessary ones). You may withdraw consent at any time without affecting processing that occurred before withdrawal.
- Contract — where processing is necessary to enter into or perform a contract with you (membership, loan, investment, EasyOwn, or similar).
- Legal obligation — where we must process data to comply with Nigerian law, court orders, or regulatory requirements.
- Vital interests — where processing is necessary to protect life or vital interests in exceptional circumstances.
- Public interest / public task — where applicable under Nigerian law.
- Legitimate interests — where processing is necessary for our legitimate interests (such as securing our systems, preventing fraud, or improving services), provided those interests are not overridden by your rights and freedoms.
Sensitive personal data (such as certain identification and financial identifiers used for KYC and lending) is processed only under the stricter conditions allowed by the NDPA and with appropriate safeguards.
7. Recipients and third-party access
We do not sell your personal data. We may share personal data with the following categories of recipients, only as needed for the stated purposes:
- Payment processors and banking partners (for example, Paystack) — to process payments and verify transactions.
- IT hosting, SMS, email, and security service providers — to operate and protect our platforms.
- Regulators, courts, law-enforcement, or other public authorities — where required by law.
- Auditors, professional advisers, and authorised staff — under confidentiality obligations.
- Credit assessment or recovery partners — where necessary and lawful for lending operations.
Where a third party accesses your data, the purpose is limited to delivering the service or meeting a legal duty. If you have concerns about third-party access, contact us at i.globalnvestments@gmail.com for internal redress.
8. Cross-border transfers
Some of our service providers may process data on systems located outside Nigeria. Where personal data is transferred outside Nigeria, we will ensure that an adequate level of protection is in place as required by the NDPA (for example, through appropriate contractual or other lawful transfer mechanisms) and that your rights remain protected.
9. Retention of personal data
We keep personal data only for as long as necessary for the purposes described in this policy, or as required by law and regulatory record-keeping rules for financial services.
- Member account and KYC data — retained for the life of the membership relationship and for a further period required by applicable financial and tax record rules (typically up to seven (7) years after the relationship ends, unless a longer period is required by law or an ongoing dispute).
- Loan, investment, thrift, and transaction records — retained for the duration of the product and thereafter for the statutory / regulatory retention period.
- Website technical logs and security logs — retained for a limited period needed for security, troubleshooting, and fraud prevention.
- Marketing preferences (where consent-based) — until you withdraw consent or unsubscribe.
When retention ends, we will delete, anonymise, or securely archive the data in line with our retention practices.
10. Your rights as a data subject
Under the NDPA, you have rights in relation to your personal data, subject to lawful exceptions. These include the right to:
- Be informed about how your personal data is processed (this Privacy Policy).
- Request access to your personal data.
- Request correction (rectification) of inaccurate or incomplete personal data.
- Request deletion (erasure) of personal data where applicable.
- Request restriction of processing in certain circumstances.
- Object to processing based on legitimate interests or for direct marketing.
- Withdraw consent where processing is based on consent.
- Data portability, where technically feasible and legally applicable.
- Object to and challenge decisions based solely on automated processing that significantly affect you, where such processing is used.
- Lodge a complaint with the Nigeria Data Protection Commission (NDPC).
To exercise any of these rights, email i.globalnvestments@gmail.com with the subject “Data Protection Request”, and include your full name, membership ID (if any), and a clear description of your request. We may need to verify your identity before responding. We aim to respond within the timeframes required by the NDPA.
11. Complaints to the NDPC
If you believe your data protection rights have been infringed, you may lodge a complaint with the Nigeria Data Protection Commission (NDPC) after contacting us, or as otherwise permitted by law.
NDPC website: https://ndpc.gov.ng — please refer to the Commission’s published contact channels for the most current complaint procedure.
12. Automated decision-making and profiling
We may use automated tools and risk checks (for example, fraud monitoring on online payments, eligibility checks, or internal scoring support) to help assess applications and protect our services.
Where a decision that produces legal or similarly significant effects is based solely on automated processing, you have the right to be informed, to obtain human intervention, and to contest the decision, as provided under the NDPA. Credit and lending decisions that materially affect you are subject to human review by authorised staff.
13. Data security
We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse, or alteration. These measures include access controls by role, authentication, encryption of sensitive identifiers where used, activity logging for sensitive actions, staff confidentiality obligations, and secure hosting practices.
No method of transmission or storage is completely secure. If we become aware of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the NDPC and affected data subjects as required by the NDPA.
14. Cookies and similar technologies
Our website uses cookies and similar technologies that are necessary to operate the site (for example, login/session security and remembering essential preferences). We may also use analytics cookies to understand how the site is used.
Where cookies are not strictly necessary, we will seek your consent through a cookie notice that allows you to accept or decline. You can also control cookies through your browser settings. Declining non-essential cookies may limit some features but will not prevent you from reading this policy or contacting us.
15. Children
Our membership and financial services are intended for adults who can lawfully enter into contracts under Nigerian law. We do not knowingly collect personal data from children for membership products. If you believe a child has provided us with personal data, please contact us so we can take appropriate action.
16. Changes to this Privacy Policy
We may update this Privacy Policy to reflect changes in our practices, products, or legal requirements under the NDPA and NDPC directives. The updated version will be published on this page with a revised effective date. Material changes may also be communicated through our website, member portal, email, or other appropriate channels.
We encourage you to review this page periodically. Continued use of our services after an update means you have been informed of the revised policy; where fresh consent is legally required for a new processing purpose, we will request it separately.
17. Contact and internal redress
For privacy questions, data-subject requests, or complaints about how we handle your personal data, contact:
- Email: i.globalnvestments@gmail.com
- Phone: +2347047049835, +2348102854141
- Postal / office address: 13, Akarigbo Street Isale Oko Sagamu
We will acknowledge and handle requests in good faith and in accordance with the NDPA. If you remain unsatisfied, you may escalate to the NDPC as described in section 11.