ECL Thrift, hereinafter called [“We” or “Our” or “Us” or “ECLT”], is a service operated by E-Consociates Limited, a properly registered company in Nigeria. We have developed this Data and Privacy Policy to clarify how we collect, use, disclose, and protect your Personal Data, along with any other information you provide while using our Platform.

This document is prepared as per the provisions of the Nigeria Data Protection Act, 2023 and the Nigeria Data Protection Regulation [NDPR]. It outlines how ECL Thrift applies and complies with the principles of the Act and Regulation in processing the personal data of individuals, clients, vendors, and third parties that interact with us.

This Privacy Policy, effective this 1st day of August 2025, applies to our website [“the site”] and its associated subdomains alongside our application and its interface. When you sign up with ECL Thrift, you provide details such as your name, date of birth, gender, email, phone number, photograph, address, valid identification document [international passport, permanent voter’s card, driver’s license, national identity card], bank details and beneficiary details, you signify that you have read, understood, and agreed to our collection, storage, use, and disclosure of your personal information as described in this Data and Privacy Policy and our Terms of Service. We will only use these information in strict accordance with the law.

Please note that we cannot serve you appropriately if we do not receive your data as requested.

This Privacy Policy is subject to change from time to time as we are keen on committing to protecting your privacy. We assure you that we will notify you of any such change by revising the date accordingly, sending you an email notification to this effect, and updating this information on all our platforms. We encourage you to review our Privacy Policy periodically to stay informed about our information practices and the steps you can take to protect your privacy. If you have any questions or concerns regarding this Policy, you should contact us on enquire@eclthrift.com.

By using our site and services, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, you should not engage with us, or use our services. Be aware that continued use of the website, direct engagement with us, or following the posting of changes to this Privacy Policy that do not significantly affect the use or disclosure of your personal information will mean that you accept those changes.

WHO WE ARE

ECL Thrift is a hybrid and corporate savings platform that encourages regular savings culture in communities, combining this with protection and preservation of family well-being using multilevel marketing approach to encourage wider and faster penetration of the insurance solution whilst rewarding members with incentives via the affiliate network.

Our goal is to preserve the dignity of human life, deliver peace of mind, and create wealth for our members. We use simple regular savings and protection insurance to cater for the happiness of our members.

ELIGIBILITY

Our products and services are intended solely for persons who, if they are a natural person, are persons between the ages of eighteen [18] and sixty four [64], being their last birthday and age next birthday, respectively. Any registration, use, or access to our Services by a natural person outside this bracket is unauthorized, unlicensed, and in violation of this Policy.

To help explain things as clearly as possible in this Date and Privacy Policy, every time any of these terms are referenced to, they are strictly defined as:

We need to collect your personal data in order for us to provide you with a safe, trusted, efficient, and good user experience whilst using our platform. In any event, we are committed to ensure that the information we collect and use is appropriate for this purpose(s) only, and will in no way invade your privacy. If there is a need to use your data for marketing purposes, ECL Thrift will seek additional consent from you. We shall not collect or process more data than is reasonably required for a particular processing activity, and every processing purpose is to safeguard the rights of the data subjects, to register you as a new user on our site, you allow you access our products, to communicate with you, to provide support and necessary training.

The personal data we collect and process, depending on the specific processing purpose, are gathered when you subscribe to our newsletters or participate in any interactive features of our services. Additionally, note that we keep a record of our communications when you contact our customer support by phone, email, or chat. We may also collect other personal information that you choose to share with us. The information we collect directly from you includes:

ECL Thrift will collect and use your personal data for relationship management, profiling, business analytics/development, communication, registration, cookies, and all-round efficient service delivery.

We will process (collect, use and store) the information you provide in a manner that complies with the EU's General Data Protection Regulation (GDPR) and the Nigeria Data Protection Regulation/Act (NDPR/NDPA). We will endeavor to keep your information accurate and up to date and not keep it for longer than is necessary.

We continually strive to improve our app offerings based on the information and feedback we receive from you and to improve customer service, your information helps us to more effectively respond to your customer service requests and support needs.

ECL Thrift requires your explicit consent to process collected personal data. And by consenting to this privacy policy, you are giving us the permission to use and process your personal data specifically for the purpose identified before collection.

If, for any reason, ECL Thrift is requesting sensitive personal data from you, you will be rightly notified why and how the information will be used.

You may withdraw consent at any time by requesting for Withdrawal of Consent form, following the ECL Thrift Withdrawal of Consent Procedure.

ECL Thrift is conferred with the obligation of privacy and discretion due to the existing regulations in the country and those of third parties that we do business with. That is why we cannot disclose user information in ways not otherwise described in this policy.

Where there is a need for a third party to process the personal data of data subjects, ECL Thrift will enter into a Data Processing Agreement with the third party and be satisfied that the third party has adequate measures in place to protect the data against accidental or unauthorized access, use, disclosure, loss, or destruction.

However, we cannot ensure full non-disclosure as we may be forced to disclose information to the government, law enforcement agencies, and third party service providers and the reason is for the performance of a task carried out in the interest of the public, for the purpose of protecting your vital interest, for the performance of a contract to which you are a party to and also where you have expressly given us consent to disclose the same. And, they also are under obligation to secure your details and use them only to fulfil the service for which they were contracted.

ECL Thrift is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. The retention period for certain kinds of personal data may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

We will hold your Personal Data on our system for as long as it is necessary to fulfill the purpose for which it was collected and will retain it for minimum of seven (7) years after the end of the customer relationship, or as required by applicable laws and regulations. This retention period has been established to enable us use the personal data for the necessary legitimate purposes identified, in full compliance with the legal and regulatory requirements.

This is also the case for anyone that we share your information with and who carries out services on our behalf. When we no longer need to use your information and there is no need for us to keep it to comply with our legal or regulatory obligations, we’ll either remove it from our system or depersonalize it so that we can't identify you.

An individual has the ‘right to erasure’ also known as the ‘right to be forgotten’. The principle supporting this right is to enable an individual to request the deletion or removal of personal data where there is no compelling reason for its continued processing.

Kindly note that ECL Thrift processes or stores all personal data in fully vetted, DPA compliant vendors. When your account is inactive, we store all conversations and personal data for up to 7 years. In cases where your account is deleted, ECL Thrift doesn’t hold your data for longer than 60 days.

However, the Company can refuse to delete your data for legal and governmental reasons.

According to the provision of the GDPR/NDPR/NDPA, data subject has certain rights at any point while ECL Thrift is in possession of or processing your personal data. You, the data subject, have the right to:

All of the above requests will be transmitted onward should there be a third party involved in the processing of your personal data.

At ECL Thrift, we implement appropriate, generally accepted technical and organizational measures to protect your personal data against unauthorized access, unlawful processing, alteration, or disclosure, and accidental loss, destruction, or damage. We ensure that your information is secured against all foreseeable hazards and breaches such as theft, cyber-attack, viral attack, dissemination, and manipulations of any kind.

However, being aware that the transmission of information via the Internet is not completely secure, people, encrypted data and security systems are fallible, while we make reasonable efforts to protect your personal information, we cannot guarantee its absolute security. If applicable law imposes any non-disclaim able duty to protect your personal information, you agree that intentional misconduct will be the standards used to measure our compliance with that duty. We will do our best to protect your personal information, but we cannot guarantee 100% security of your data transmitted to our servers using the internet and any transmission is at your own risk.

ECL Thrift or our Agents shall not ask to obtain your personal data except only during account creation. We shall not request your passwords. However, as a user, you have an obligation also to help us to keep your information secure by ensuring that any user name or password in relation to our online services is kept strictly confidential to you and not be made available to any other person. When a foul play is noticed on your account you should stop using the account and notify us immediately.

As an ECL Thrift user, we collect information you voluntarily provide to us and use them for Human Resources purposes in order to administer benefits to you.

You may contact us in order to update or correct your information, change your preferences with respect to communications and other information you receive from us, or receive a record of the information we have relating to you. Such updates, corrections, changes and deletions will have no effect on other information that we maintain, or information that we have provided to third parties in accordance with this Privacy Policy prior to such update, correction, change or deletion.

Also, if you communicate with us using a non-secure mechanism, and you assume the risks that such communications between us are intercepted, not received, delayed, corrupted or are received by persons other than the intended recipient, you may immediately contact us for appropriate data update.

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data, ECL Thrift shall within 24 [Twenty-Four] hours of having knowledge of such breach report the details of the breach to NITDA and other appropriate authorities.

Furthermore, where we ascertain that such breach is detrimental to your rights and freedoms in relation to your Personal Data, we shall within 5 [Five] days of having knowledge of the occurrence of such breach take steps to inform you of the breach incident, the risk to your rights and freedoms resulting from such breach and any course of action to remedy same.

We may display, include or make available third-party content [including data, information, applications and other products and services] or provide links to third-party websites or services ["Third-Party Services"].

You acknowledge and agree that ECL Thrift shall not be responsible for any Third-Party Services, including their accuracy, completeness, timeliness, validity, copyright compliance, legality, decency, quality or any other aspect thereof. ECL Thrift does not assume and shall not have any liability or responsibility to you or any other person or entity for any Third-Party Services.  Third-Party Services and links thereto are provided solely as a convenience to you and you access and use them entirely at your own risk and subject to such third parties' terms and conditions.

If for any reason you wish to make a complaint about how ECL Thrift, our Agents or any of our third parties processes your personal data, or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and the Data Protection Officer of ECL Thrift.

Below are the details for each of these contacts: