This Privacy Policy applies to all services offered by Cool Financials Services Limited.
Introduction & Who We Are
Cool Financials Services Limited ("Cool Financials", "we", "us", or "our") is a lending and investment services company incorporated in Nigeria, operating from C60-61 Road 2 Ikota Shopping Complex, VGC, Lagos. We are committed to protecting and respecting your privacy.
This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our services, visit our website, or engage with our team. Please read it carefully. By using our services, you agree to the terms of this Policy.
Information We Collect
We collect information you provide directly to us, information collected automatically through your use of our services, and information from third parties where permitted by law.
Information you provide to us:
- Full name, date of birth, and government-issued identification details (National ID, Driver's Licence, International Passport)
- Bank Verification Number (BVN) and Tax Identification Number (TIN)
- Contact information including phone number, email address, and residential or business address
- Financial information including bank account details, income, employment details, and credit history
- Business information including CAC registration details, business address, and financial statements
- Documents you submit as part of a loan or investment application
- Communications you send to us by email, phone, or in writing
Information collected automatically:
- IP address, browser type, device information, and operating system
- Pages visited on our website, time spent, and clickstream data
- Cookies and similar tracking technologies (see our Cookie section below)
How We Use Your Information
We use your personal information only for the purposes for which it was collected and for purposes directly related to the provision of our services. These include:
- Loan Processing: To assess your creditworthiness, verify your identity, process your loan application, and disburse funds
- Investment Services: To onboard you as an investor, manage your investment, and process returns
- KYC & Compliance: To meet our Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations under Nigerian law
- Communication: To contact you about your account, respond to enquiries, and provide customer service
- Service Improvement: To understand how our services are used and improve them over time
- Legal Obligations: To comply with applicable laws, regulations, and court orders
- Security: To detect, investigate and prevent fraud, money laundering, and other illegal activities
- Sell or share your information with third-party marketers
- Send unsolicited marketing communications without your consent
- Make fully automated decisions about you without human oversight
Legal Basis for Processing
We process your personal data under the following legal bases as provided by the Nigeria Data Protection Regulation (NDPR) and the Nigeria Data Protection Act (NDPA) 2023:
| Purpose | Legal Basis |
|---|---|
| Loan application & processing | Performance of a contract |
| KYC and AML verification | Legal obligation |
| Investment management | Performance of a contract |
| Fraud prevention | Legitimate interests |
| Marketing communications | Consent (you may withdraw at any time) |
| Credit bureau reporting | Legal obligation / Legitimate interests |
| Website analytics | Legitimate interests |
Sharing Your Information
We do not sell your personal data. We may share it only in the following limited circumstances:
- Credit Bureaus: We may share your loan performance data with licensed Nigerian credit bureaus (e.g., CRC, FirstCentral) as required by law
- Regulatory Bodies: We share information with the CBN, FIRS, EFCC, or other authorities when legally required
- Service Providers: We engage trusted third-party service providers (e.g., IT systems, identity verification, payment processors) who process data strictly on our instructions and under binding confidentiality agreements
- Legal Requirements: We may disclose your information if required to do so by law, court order, or lawful government request
- Business Transfer: In the event of a merger, acquisition or sale of assets, your data may be transferred — you will be notified before any such transfer occurs
All third parties with whom we share data are required to maintain the confidentiality and security of your personal information and may not use it for any other purpose.
Data Retention
We retain your personal information for as long as is necessary for the purposes for which it was collected, or as required by applicable law. In general:
- Loan records and related documentation: 7 years after the loan is fully repaid or closed
- Investment records: 7 years after the investment matures or is closed
- KYC/AML records: 5 years after the end of the business relationship
- Enquiry and communication records: 3 years from the date of enquiry
- Website usage data: 12 months
After retention periods expire, your data is securely deleted or anonymised.
Your Rights
Under the Nigeria Data Protection Act (NDPA) 2023, you have the following rights regarding your personal data:
- Right of Access: You may request a copy of the personal data we hold about you
- Right to Rectification: You may ask us to correct inaccurate or incomplete information
- Right to Erasure: You may request that we delete your data, subject to legal and regulatory retention obligations
- Right to Restrict Processing: You may ask us to limit how we use your data in certain circumstances
- Right to Data Portability: You may request your data in a structured, machine-readable format
- Right to Object: You may object to processing based on legitimate interests or for direct marketing
- Right to Withdraw Consent: Where processing is based on consent, you may withdraw it at any time
To exercise any of these rights, contact us at info@coolfinancials.org or call 07032247860. We will respond within 30 days.
Data Security
We implement appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These include:
- Encryption of data in transit and at rest
- Access controls and role-based permissions for staff
- Regular security assessments and staff data protection training
- Secure, access-controlled physical premises
- Incident response procedures for data breaches
In the unlikely event of a data breach that poses a risk to your rights, we will notify you and the Nigeria Data Protection Commission (NDPC) within 72 hours of becoming aware.
Cookies
Our website uses cookies and similar technologies to improve your experience. Cookies are small text files stored on your device. We use:
- Essential cookies: Necessary for the website to function. Cannot be disabled.
- Analytics cookies: Help us understand how visitors use our site (e.g., Google Analytics). Anonymous and aggregated only.
- Preference cookies: Remember your settings and preferences for return visits.
You can manage cookie preferences in your browser settings. Disabling certain cookies may affect your experience on our website.
Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. When we make material changes, we will notify you by email (if we hold your address) and update the "Last updated" date at the top of this page. We encourage you to review this Policy periodically.
Your continued use of our services after any changes are posted constitutes your acceptance of the updated Policy.
Contact & Complaints
For any questions, concerns, or requests related to this Privacy Policy or your personal data, please contact our Data Protection Officer:
Data Protection Officer
Cool Financials Services Limited
If you are not satisfied with how we handle your complaint, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) at ndpc.gov.ng.
These Terms & Conditions govern your use of Cool Financials Services Limited.
Agreement to Terms
These Terms and Conditions ("Terms") constitute a legally binding agreement between you ("Client", "you", or "your") and Cool Financials Services Limited ("Cool Financials", "we", "us", or "our"), governing your access to and use of our lending, investment, and consultancy services.
By submitting an application, signing a loan or investment agreement, or otherwise using our services, you confirm that you have read, understood, and agreed to be bound by these Terms in full.
Eligibility
To be eligible for Cool Financials services, you must meet all of the following criteria:
- Be a Nigerian citizen or a legal resident of Nigeria with a valid means of identification
- Be at least 18 years of age at the time of application
- Hold an active bank account with a Nigerian financial institution
- Have a valid Bank Verification Number (BVN)
- For business services: be the registered owner or duly authorised representative of a CAC-registered business
- Not be subject to any insolvency proceedings, bankruptcy order, or unresolved court judgement related to debt
Cool Financials reserves the right to verify eligibility criteria at any time and to decline or withdraw services where eligibility cannot be confirmed.
Our Services
Cool Financials offers the following categories of financial services, each governed by a separate product agreement signed at the time of engagement:
| Service | Description | Min. Amount |
|---|---|---|
| Contract Finance | Term loans for SME growth and operations | ₦10,000,000 |
| Asset Finance | Loans secured against assets | ₦10,000,000 |
| Local Purchase Order | Advances against verified outstanding invoices | ₦5,000,000 |
| Car Buy-Backed Loan | Short-term loans using vehicle as collateral | ₦1,000,000 |
| Property Buy-Backed Loan | Revenue-based funding for high-volume merchants | ₦10,000,000 |
The specific terms, interest rates, tenors, fees, and conditions applicable to each service are contained in the relevant product agreement, which forms part of these Terms once signed.
Application Process & Approval
All applications are subject to a credit and suitability assessment. Submitting an application does not constitute an offer or guarantee of credit or investment placement.
- You must provide complete, accurate, and truthful information in your application. Submitting false or misleading information is a serious breach of these Terms and may constitute fraud under Nigerian law
- We may decline any application without being obliged to give reasons
- Approval is subject to satisfactory credit assessment, identity verification, and document review
- We reserve the right to request additional documentation at any point during the assessment process
- Upon approval, you will receive a formal offer letter setting out the terms of the facility. You must sign and return this offer within the stated validity period
Loan Repayment Obligations
If you are approved for a loan, the following obligations apply:
- You must repay the loan in full, including all accrued interest and applicable fees, in accordance with the repayment schedule set out in your loan agreement
- Repayments must be made on or before the due date each month. A grace period of 3 days may apply at our discretion — this is not a right
- Late payment fees will be applied for payments received after the due date. The applicable rate is stated in your loan agreement
- Early repayment is permitted and no early repayment penalty applies on standard loan products
- In the event of financial difficulty, you must contact your relationship manager immediately. We will work in good faith to find a solution — ignoring payments will not
Failure to repay may result in: (a) reporting to credit bureaus, affecting your credit score; (b) legal action to recover outstanding amounts; (c) repossession of collateral where applicable; (d) recovery of costs and legal fees. We urge clients to communicate early if facing difficulties.
Investment Terms
For clients using our Cash Investment or Real Estate Investment products, the following applies:
- Investment terms, rates, and maturity dates are confirmed exclusively in writing via a signed Investment Agreement
- Verbal representations of rates or returns do not constitute a binding commitment
- Investment funds are held in designated accounts and are not used for operational expenses of Cool Financials
- Returns are paid on the maturity date stated in your Investment Agreement. Early withdrawal may be subject to a penalty as stated in that agreement
- Investments are not covered by the Nigerian Deposit Insurance Corporation (NDIC). Past returns are not a guarantee of future performance
- You must declare any investment income to the Federal Inland Revenue Service (FIRS) as required by Nigerian tax law — this is your individual responsibility
Fees & Charges
We operate a zero hidden fees policy. All fees applicable to your product are disclosed in your offer letter or product agreement before you sign. Standard fee categories include:
- Processing / Origination Fee: A one-time fee charged at disbursement for loan products, stated as a percentage of the loan amount
- Interest: Calculated and disclosed in your agreement. Rates are personalised based on your profile and product
- Late Payment Fee: Applied when a repayment is received after the due date
- Legal/Recovery Fees: Only apply if your account defaults and recovery action is required
Cool Financials will never charge fees not disclosed in your signed agreement. If you are asked to pay any undisclosed fee, please report it immediately to info@coolfinancials.org.
Client Responsibilities
As a client of Cool Financials, you agree to:
- Provide accurate, complete, and up-to-date information at all times
- Notify us promptly of any changes to your contact details, employment, business status, or financial circumstances that may affect your account
- Keep your account credentials confidential and not share them with third parties
- Use our services only for lawful purposes and in compliance with all applicable Nigerian laws and regulations
- Not use funds obtained from Cool Financials for any illegal, fraudulent, or prohibited activities, including money laundering, terrorism financing, or any activity prohibited under Nigerian law
- Cooperate fully with any verification, KYC, or AML checks we are required to carry out
Limitation of Liability
To the maximum extent permitted by applicable Nigerian law:
- Cool Financials shall not be liable for any indirect, incidental, special, or consequential loss arising from your use of our services
- Our total liability to you for any claim shall not exceed the total amount you have paid to us in fees in the 12 months preceding the claim
- We are not liable for losses arising from circumstances beyond our reasonable control, including but not limited to: Acts of God, government actions, power failures, cyberattacks, or third-party failures
Nothing in these Terms excludes or limits our liability for fraud, gross negligence, death or personal injury caused by our negligence, or any liability that cannot be excluded by law.
Termination
Cool Financials may suspend or terminate your access to its services immediately and without prior notice if:
- You breach any of these Terms or any product agreement
- We reasonably suspect fraud, misrepresentation, or any criminal activity
- You become insolvent, bankrupt, or subject to creditor proceedings
- We are required to do so by a regulatory or legal authority
Termination does not affect any existing loan or investment obligations — all outstanding amounts remain immediately due and payable upon termination.
Dispute Resolution
We hope to resolve all disputes amicably and quickly. Our process:
- Step 1 — Direct Resolution: Contact your relationship manager or our complaints desk at info@coolfinancials.org. We aim to resolve complaints within 10 business days
- Step 2 — Internal Escalation: If unresolved, escalate to our Manager or the HR. Written response within 15 business days
- Step 3 — Mediation: If still unresolved, both parties agree to attempt resolution via an independent mediator before pursuing litigation
- Step 4 — Legal Action: If mediation fails, disputes shall be subject to the exclusive jurisdiction of the courts of the Federal Republic of Nigeria
Governing Law
These Terms and Conditions are governed by and construed in accordance with the laws of the Federal Republic of Nigeria. Any disputes arising under these Terms shall be subject to the exclusive jurisdiction of Nigerian courts.
Relevant legislation includes but is not limited to: the Banks and Other Financial Institutions Act (BOFIA), the Companies and Allied Matters Act (CAMA), the Nigeria Data Protection Act 2023, and the Consumer Protection Act.
Changes to These Terms
We reserve the right to update these Terms from time to time. When we make material changes, we will provide notice by email and by updating the "Last updated" date on this page. Changes take effect 14 days after notification unless you object in writing within that period.
Your continued use of our services after the 14-day notice period constitutes acceptance of the revised Terms.
Contact Us
For questions about these Terms, or to exercise any rights described herein, please contact:
Cool Financials Services Limited
Legal & Compliance Department