PRIVACY POLICY – ZENOARIS
Last Updated:24 February 2026
1. Introduction
ZENOARIS ("we," "our," "us") is a digital financial application that provides credit line services, including credit assessment, identity verification, fund disbursement, and customer support.
This Privacy Policy explains in a clear and transparent manner how we collect, use, store, protect, and share your personal information when you use our services.
By downloading or using ZENOARIS, you consent to the processing of your personal data as described in this Policy. If you do not agree, you may discontinue use of the application at any time.
2. Regulatory Framework and Compliance
This Privacy Policy is governed by and complies with the following Nigerian laws and regulations:
2.1 Data Protection
Nigeria Data Protection Regulation (NDPR) 2019, issued by the National Information Technology Development Agency (NITDA)
Nigeria Data Protection Act 2023 (NDPA), establishing the Nigeria Data Protection Commission (NDPC)
Implementation Framework for the NDPR (as amended)
2.2 Anti-Money Laundering and Counter-Terrorism Financing (AML/CFT)
Money Laundering (Prohibition) Act 2011 (as amended 2022)
Central Bank of Nigeria (CBN) AML/CFT Regulations 2013
CBN Know Your Customer (KYC) Manual
Financial Action Task Force (FATF) Recommendations as adopted by Nigeria
3. Data Controller
Company: 773ONLINE LTD
Address: Summit Place 696 Ubiaja Crescent, Off Ladoke Akintola Boulevard, Garki II, Abuja-FCT, Nigeria
Email: privacy@zenovafinance.com
Phone: +234 812 265 1121
Data Protection Officer (DPO): dpo@zenovafinance.com
4. Legal Basis for Data Processing
In accordance with the NDPA 2023 (Part III) and NDPR 2019 (Article 2.2), we process your personal data on the following legal grounds:
Contractual Necessity – To execute the credit line agreement and provide our services to you
Legal Obligation – To comply with AML/CFT requirements under the Money Laundering (Prohibition) Act and CBN KYC obligations
Consent – For specific data processing activities where we have obtained your explicit consent
Legitimate Interest – For fraud prevention, security of services, and improvement of our products
5. Types of Data We Collect
We collect personal data only when strictly necessary to deliver our services, verify user identity, assess credit eligibility, and comply with applicable legal and regulatory obligations.
5.1 Personal Information Provided by the User
Basic Information (KYC Requirements): Full name, Gender, Date of birth, Nationality, Marital status, National Identification Number (NIN).
Employment Information: Employment type, Monthly income, Employer details.
Payment Information: Bank account details (account number, bank name), Bank Verification Number (BVN).
5.2 Emergency Contacts (Manual Selection ONLY)
ZENOARIS allows ONLY the user to manually select and enter specific emergency contacts.
WHAT WE DO NOT DO:
We do NOT access or upload your ENTIRE contact list from your device
We do NOT scan or collect contacts beyond those you manually enter
We do NOT use contact information for marketing or advertising
We do NOT contact your references for debt collection harassment
5.3 Identity Verification (KYC)
We collect: Photograph of a government-issued ID document and a selfie photograph for facial comparison.
Biometric data is processed automatically and DELETED within 24 hours after successful verification.
5.4 Device Information
We collect technical information to provide secure services and prevent fraud: Device model, Operating system version, Language, Network status, Unique device identifiers.
WHAT WE DO NOT COLLECT:
We do NOT collect your photos, videos, or media files
We do NOT access your browsing history
We do NOT read your SMS messages (except specific transaction-related messages with your explicit consent)
We do NOT record calls or access your call logs
We do NOT install background trackers or spyware
6. How We Use Your Information
We use your personal data to:
Verify your identity and assess creditworthiness
Provide, maintain, and improve the credit line service
Process credit drawdowns and repayments
Communicate with you about your account status, including repayment reminders
Comply with legal and regulatory obligations (AML/CFT, KYC, tax reporting)
Detect and prevent fraud or unauthorized access
Respond to your inquiries and provide customer support
7. Data Sharing
We may share personal data ONLY in the following limited circumstances:
Service Providers: Only to operate essential application functions (payment processing, identity verification, cloud hosting). These providers are contractually bound to protect your data.
Credit Bureaus: We may report your credit performance to licensed credit bureaus in Nigeria (e.g., CRC Credit Bureau, First Central Credit Bureau) to support the credit information system.
Regulatory Authorities: Central Bank of Nigeria (CBN), Nigeria Data Protection Commission (NDPC), Nigerian Financial Intelligence Unit (NFIU), Federal Inland Revenue Service (FIRS), and other authorities as required by law.
We Do NOT Share Data For: Third-party marketing, Sale of personal data, Targeted advertising, Debt collection harassment.
8. Data Storage Location
Your personal data is stored and processed on secure servers. Where data is transferred outside Nigeria, we ensure that adequate safeguards are in place in accordance with Part IV of the NDPA 2023 and the NDPR provisions on cross-border data transfer.
9. Data Retention Period
Account information: Duration of account + 6 years
Identity documents: 6 years after end of relationship (AML/CFT requirement)
Biometric data: Deleted within 24 hours of verification
Transaction records: 6 years
Device information: 12 months
Emergency contacts: Deleted upon account deletion
10. Your Rights
Under the NDPA 2023 (Part V) and the NDPR 2019, you have the following rights:
Right of Access – Request a copy of your personal data held by us
Right to Rectification – Correct inaccurate or incomplete data
Right to Deletion – Request deletion of your personal data (subject to legal retention requirements)
Right to Object – Object to processing for specific purposes including direct marketing
Right to Data Portability – Receive your data in a structured, machine-readable format
Right to Withdraw Consent – Withdraw consent at any time without affecting the lawfulness of prior processing
Right to Complaint – Lodge a complaint with the Nigeria Data Protection Commission (NDPC)
To exercise your rights, contact: privacy@zenovafinance.com or dpo@zenovafinance.com
11. Account Deletion
You may request the deletion of your ZENOARIS account and associated personal data through the "Delete Account" feature available on our website and within the application. The process includes identity verification and a confirmation period to prevent accidental deletion. Upon confirmed deletion, we will remove your personal data from our active systems, subject to any legal retention obligations outlined in Section 9. Any outstanding credit balance must be settled before account deletion can be completed.
12. Data Security
We implement appropriate technical and organisational security measures to protect your personal data:
Encryption of data in transit (TLS 1.3) and at rest (AES-256)
Role-based access controls and multi-factor authentication for internal systems
Regular security assessments, penetration testing, and vulnerability scanning
Employee training on data protection best practices
Incident response procedures for data breaches
While we implement rigorous measures, no system can guarantee absolute security. We encourage you to keep your account credentials confidential.
13. Children's Privacy
ZENOARIS is intended ONLY for users who are 18 years of age or older. We do NOT knowingly collect personal data from anyone under the age of 18. If we become aware that we have collected data from a minor, we will take immediate steps to delete such data. If you believe a minor has provided us with personal data, please contact us at privacy@zenovafinance.com.
14. Changes to This Policy
This Privacy Policy may be updated periodically. Material changes will be communicated through the application and/or by email. The "Last Updated" date at the top indicates the most recent revision. Continued use of the Service after changes constitutes acceptance of the updated policy.
15. Contact and Complaints
Company: 773ONLINE LTD
Address: Summit Place 696 Ubiaja Crescent, Off Ladoke Akintola Boulevard, Garki II, Abuja-FCT, Nigeria
Privacy Inquiries: privacy@zenovafinance.com
Customer Service: customerservices@zenovafinance.com
Data Protection Officer: dpo@zenovafinance.com
Phone: +234 812 265 1121
Regulatory Authority: Nigeria Data Protection Commission (NDPC) – https://ndpc.gov.ng