Smart Money for Modern Life

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.

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.

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

© 2026 773ONLINE LTD. All rights reserved.
This Privacy Policy complies with: Nigeria Data Protection Act 2023 (NDPA), Nigeria Data Protection Regulation 2019 (NDPR), Money Laundering (Prohibition) Act 2011 (as amended 2022).

1. Acceptance of Terms

By downloading, installing, or using the ZENOARIS mobile application or website (the "Service"), you agree to be bound by these Terms and Conditions ("Terms"). If you do not agree to these Terms, do not use the Service. These Terms constitute a legally binding agreement between you and 773ONLINE LTD ("we," "us," or "the Company").

2. Service Description

ZENOARIS provides a revolving credit line service that allows approved users to access funds up to their approved credit limit. Users may draw from their available credit, repay outstanding amounts, and draw again without submitting new applications. The credit line is provided through our mobile application and is subject to approval based on our assessment criteria.

3. Eligibility

To be eligible to use the Service, you must:

• Be at least 18 years of age
• Be a resident of Nigeria
• Possess a valid Nigerian phone number
• Have an active bank account in your name with a Nigerian bank
• Provide valid identification as required during registration
• Not have been previously suspended or removed from the Service for violations of these Terms

We reserve the right to verify your eligibility and to decline service at our discretion.

4. User Obligations

As a user of the Service, you agree to:

• Provide accurate, current, and complete information during registration and throughout your use of the Service
• Maintain the confidentiality of your account credentials and not share them with any third party
• Notify us immediately of any unauthorized access to your account
• Use the Service only for lawful purposes and in compliance with applicable laws
• Repay all amounts drawn from your credit line in accordance with the agreed repayment schedule
• Keep your contact information and bank details up to date
• Not use the Service to engage in fraud, money laundering, or any illegal activity

5. Credit Line Terms

Your credit line, if approved, will be subject to the following general terms:

• A credit limit will be assigned based on our assessment of your profile and creditworthiness
• You may draw funds up to your available credit limit at any time through the app
• Each drawdown will have a specified repayment period communicated at the time of the transaction
• Interest and/or service fees may apply to each drawdown, as disclosed before you confirm the transaction
• Repayments restore your available credit, allowing further drawdowns
• We may adjust your credit limit from time to time based on your usage and repayment history

6. Fees & Charges

ZENOARIS is committed to fee transparency. All applicable fees, charges, and interest rates will be clearly disclosed to you within the app before you confirm any credit drawdown. There are no hidden fees. The specific fee schedule is available within the application and may be updated from time to time with prior notice. You are responsible for reviewing the applicable charges before each transaction.

7. Default and Collections

If you fail to make timely repayments:

• Late fees may be applied as disclosed in the app
• We may suspend your access to further credit drawdowns
• We may report your default to licensed credit bureaus in Nigeria, which may affect your credit score
• We may engage third-party collection agencies to recover outstanding amounts
• We reserve the right to pursue legal remedies to recover unpaid amounts

We will communicate with you regarding any outstanding obligations and make reasonable efforts to resolve issues before escalation.

8. Intellectual Property

All content, trademarks, logos, software, designs, and other intellectual property related to ZENOARIS and the Service are owned by or licensed to 773ONLINE LTD. You may not copy, modify, distribute, sell, or exploit any part of the Service without our prior written consent. Your use of the Service does not grant you any ownership rights in any intellectual property.

9. Disclaimers and Limitations

The Service is provided on an "as is" and "as available" basis. While we strive to maintain reliable operations, we do not warrant that the Service will be uninterrupted, error-free, or free from security vulnerabilities. To the maximum extent permitted by law:

• We disclaim all implied warranties, including fitness for a particular purpose
• We shall not be liable for any indirect, incidental, special, or consequential damages arising from your use of the Service
• Our total liability to you shall not exceed the total fees paid by you in the 12 months preceding the claim

10. Dispute Resolution

These Terms shall be governed by and construed in accordance with the laws of the Federal Republic of Nigeria. Any dispute arising from or relating to these Terms or the Service shall be subject to the exclusive jurisdiction of the courts located in Abuja, Federal Capital Territory, Nigeria. Before initiating legal proceedings, both parties agree to attempt in good faith to resolve any dispute through direct negotiation or mediation.

11. Termination

You may terminate your use of the Service at any time by deleting your account, provided that all outstanding balances have been settled. We may suspend or terminate your access to the Service at any time if:

• You breach any provision of these Terms
• We are required to do so by law or regulatory order
• We reasonably suspect fraudulent or illegal activity on your account
• You fail to repay outstanding amounts as agreed

Upon termination, your obligation to repay any outstanding balance remains in effect.

12. Contact Information

For questions or concerns about these Terms, please contact us:

• Company: 773ONLINE LTD
• Address: Summit Place 696 Ubiaja Crescent, Off Ladoke Akintola Boulevard, Garki II, Abuja-FCT, Nigeria
• Customer Service: customerservices@zenovafinance.com
• Privacy Inquiries: privacy@zenovafinance.com
• Phone: +234 812 265 1121