Privacy Policy

We collect the following categories of personal data: (a) Identity Information: Full name, date of birth, gender, and government-issued ID number; (b) Contact Information: Email address, phone number, and residential address; (c) Financial Information: Bank account name and number (for peer transfer purposes — we do not store card details); (d) KYC Documents: Scanned copies of government-issued ID and selfie photographs; (e) Technical Data: IP addresses, device identifiers, browser type, and usage logs; (f) Transaction Data: Contribution history, settlement records, and reliability scores; (g) Communications: Support messages and dispute communications.

We use your personal data for the following purposes: (a) Platform Registration & Identity Verification: To create and manage your member account; (b) KYC Compliance: To verify your identity and comply with anti-money laundering requirements; (c) Peer Matching: To intelligently match you with compatible contribution peers; (d) Communication: To send transaction alerts, notifications, and platform updates; (e) Dispute Resolution: To review evidence and mediate peer disputes; (f) Security: To detect, prevent, and investigate fraud or suspicious activity; (g) Platform Improvement: To analyze usage patterns and improve our services; (h) Legal Compliance: To comply with applicable Nigerian laws and regulations.

We do NOT sell your personal data. We may share your data only in the following limited circumstances: (a) Matched Peers: Your display name and bank details are shared with your matched peer solely to facilitate the direct bank transfer; (b) KYC Verification Partners: Identity documents may be shared with licensed KYC verification providers; (c) Legal Authorities: We may disclose data when required by law, court order, or regulatory authority; (d) Service Providers: We use trusted third-party services (hosting, email, SMS) who are contractually bound to protect your data; (e) Business Transfer: In the event of a merger or acquisition, your data may be transferred with advance notice.

We retain your personal data for as long as your account is active. Upon account closure: (a) Identity and KYC data is retained for 7 years as required by Nigerian anti-money laundering regulations; (b) Transaction records are retained for 5 years; (c) Communication logs are retained for 3 years; (d) Technical logs are retained for 90 days. You may request deletion of non-legally-required data by contacting our support team.

As a data subject under the NDPR, you have the following rights: (a) Right of Access: Request a copy of the personal data we hold about you; (b) Right to Rectification: Request correction of inaccurate personal data; (c) Right to Erasure: Request deletion of personal data not required by law; (d) Right to Object: Object to processing of your data for specific purposes; (e) Right to Portability: Receive your data in a structured, machine-readable format; (f) Right to Withdraw Consent: Withdraw consent for non-essential processing at any time. To exercise any of these rights, contact us at privacy@gnl.ng.

GNL uses the following types of cookies: (a) Essential Cookies: Required for platform functionality, authentication, and security — these cannot be disabled; (b) Analytics Cookies: Help us understand how members use the platform (with your consent); (c) Preference Cookies: Remember your settings and preferences (with your consent). You can manage non-essential cookies via the cookie consent banner. Note that disabling essential cookies will impair platform functionality.

We implement robust technical and organizational security measures including: (a) TLS/SSL encryption for all data in transit; (b) AES-256 encryption for sensitive data at rest; (c) Regular security audits and penetration testing; (d) Role-based access control for platform staff; (e) SHA-256 audit logging of all administrative actions; (f) Automatic session timeouts; (g) IP-based suspicious activity detection. Despite these measures, no system is 100% secure. We encourage you to use a strong password and report any suspicious activity immediately.

We may update this Privacy Policy from time to time. We will notify you of material changes via email or platform notification at least 7 days before the changes take effect. Your continued use of GNL after policy changes constitutes acceptance of the updated policy. The current version and effective date are always displayed at the top of this page.

For privacy-related inquiries, requests, or complaints, contact: Email: privacy@gnl.ng | Alternatively, use the support desk within your member portal. We aim to respond to all privacy requests within 10 business days. You also have the right to lodge a complaint with the Nigeria Data Protection Bureau (NDPB) if you believe your data rights have been violated.