LENDTRADERS TRADING CLUB - Privacy Policy

LENDTRADERS LIMITED

RC: 7942080 | EFCC SCUML: SC 122101912

GLOBAL PRIVACY POLICY

Version 2.1 — Effective March 2025

Protecting Your Data. Respecting Your Rights. Everywhere.

GLOBAL COMPLIANCE COVERAGE

LENDTRADERS LIMITED (RC: 7942080 | SCUML: SC 122101912) operates a global private club. This Privacy Policy meets or exceeds the privacy standards of every major jurisdiction in which we operate. We are transparent about how we handle your data.

Document Title

Global Privacy Policy

Issued By

LENDTRADERS LIMITED

RC Number

7942080

SCUML Registration

SC 122101912

Version

2.1

Effective Date

March 2025

Last Updated

March 2025

General Contact

support@lendtraders.com

Privacy Officer

privacy@lendtraders.com

Data Protection Officer

dpo@lendtraders.com

Data Controller

LENDTRADERS LIMITED, Nigeria

Scope

All LendTraders platform users globally

1. WHO WE ARE AND HOW TO CONTACT US

LENDTRADERS LIMITED is a private club operator registered in Nigeria under CAMA 2020 (RC: 7942080), certified by the EFCC SCUML (SC 122101912) as Anti-Money Laundering compliant. We operate the LendTraders platform globally, providing private club membership across multiple pool types including trading pools, real estate pools, and other lawful business pools.

We are the Data Controller responsible for your personal information. This means we determine how and why your personal data is processed.

Data Controller

LENDTRADERS LIMITED, Nigeria

General Email

support@lendtraders.com

Privacy Officer

privacy@lendtraders.com

Data Protection Officer

dpo@lendtraders.com

EU/UK Representative

eurepresentative@lendtraders.com

Response Time

Within 30 days of any privacy request

2. WHAT PERSONAL DATA WE COLLECT

2.1 Identity and KYC Data

When you apply for membership, we collect the following:

• Full legal name, date of birth, nationality, and country of residence

• Government-issued ID (National ID, International Passport, or Driver's Licence)

• Bank Verification Number (BVN) — for Nigerian members

• Tax Identification Number (TIN) — where applicable in your jurisdiction

• Proof of address (utility bill, bank statement, or equivalent)

• Facial biometric data (selfie or liveness check) for identity verification

• Source of funds declaration

2.2 Account and Financial Data

• Username and encrypted password, email address, phone number

• Bank account details and payment information

• Contribution amounts, pool membership history, transaction records

• Profit and loss records across all pool types

• Withdrawal requests and payment confirmations

• Referral code and the identity of the member who referred you

2.3 Usage and Technical Data

• IP address and approximate geolocation

• Device type, operating system, and browser information

• Login timestamps, session duration, and pages visited

• Error logs and crash reports

2.4 Communications Data

• Email and chat correspondence with our support team

• Support ticket content and history

• Records of consent given to this Policy and our Member Agreement

DATA WE DO NOT COLLECT

We do not sell your personal data to any third party — ever.

We do not store full payment card numbers. Payments are processed by certified third-party providers.

We do not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or health information unless you voluntarily provide it for a specific purpose.

3. WHY WE COLLECT YOUR DATA — LEGAL BASIS

We only collect and process your personal data where we have a valid legal basis to do so:

KYC and identity verification

Legal obligation (EFCC SCUML, AML regulations globally)

Processing Contributions

Performance of contract (Member Agreement)

Distributing profits across all pools

Performance of contract (Member Agreement)

Processing withdrawals

Performance of contract (Member Agreement)

AML monitoring and fraud prevention

Legal obligation (SCUML, FATF standards)

Marketing communications

Your explicit consent — opt-in only

Platform improvement

Legitimate interests

Regulatory reporting

Legal obligation

Non-essential cookies

Your explicit consent

4. HOW WE USE YOUR DATA

4.1 Club Membership and Pool Operations

• To process and verify your membership application

• To create and manage your account and all pool memberships

• To process Contributions and calculate profit shares across all pool types

• To process withdrawal requests

• To provide Monthly Reports and your account dashboard

• To communicate important account notices and policy updates

4.2 Legal and Regulatory Compliance

• To fulfil our EFCC SCUML obligations

• To comply with AML and CTF laws in Nigeria and internationally

• To verify the source of your funds for all pool types

• To respond to lawful requests from regulatory authorities and law enforcement

4.3 Security and Fraud Prevention

• To detect, investigate, and prevent fraudulent activity

• To monitor for suspicious transactions as required by SCUML

• To protect the security and integrity of the platform

4.4 Marketing — Consent Only

We will only send you marketing communications if you have explicitly opted in. You may opt out at any time by clicking Unsubscribe in any marketing email or by contacting support@lendtraders.com. Opting out of marketing does not affect the processing of data necessary for your membership.

5. COOKIES AND TRACKING TECHNOLOGIES

Cookies are small text files stored on your device when you visit our platform. We use them to make our platform work, remember your preferences, and understand how you use the site.

Essential Cookies

Required for the platform to function. Cannot be disabled. Examples: login session, security tokens.

Functional Cookies

Remember your preferences and settings. Can be disabled but may affect your experience.

Analytics Cookies

Help us understand how members use the platform. Disabled unless you consent.

Marketing Cookies

Track visits to serve relevant content. Only activated with your explicit consent.

When you first visit our platform, you will see a Cookie Consent banner. You may accept all cookies, accept only essential cookies, or customise your preferences. You can change your cookie settings at any time through the Cookie Settings link in the platform footer.

6. SHARING YOUR DATA WITH THIRD PARTIES

We do not sell your personal data. We may share your data only with the following, strictly for the purposes described:

• Payment Processors: To process Contributions and withdrawals. PCI-DSS certified providers.

• KYC and Identity Verification Providers: To verify your identity. Examples: Smile Identity, Paystack Identity. All bound by confidentiality.

• Cloud Infrastructure Providers: Our platform is hosted on secure cloud infrastructure. All under appropriate data protection agreements.

• Professional Advisers: Lawyers, auditors, and accountants under professional confidentiality obligations.

• Regulatory Authorities: The EFCC, SCUML (SC 122101912), and any Nigerian or international regulatory body where legally required.

• Law Enforcement: Where required by a valid court order or law enforcement request.

• Business Successors: In the event of merger or acquisition, under equivalent privacy protections.

All third parties with whom we share your data are required to handle it in accordance with applicable privacy laws and under contractual obligations that protect your rights.

7. INTERNATIONAL DATA TRANSFERS

As a global platform, your personal data may be transferred to and processed in countries outside your country of residence. When we transfer data internationally, we ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses (SCCs) approved by the European Commission — for EU/EEA data transfers

• Adequacy decisions — where the destination country has been recognised as providing adequate protection

• Your explicit consent — where required by local law

8. HOW LONG WE KEEP YOUR DATA

KYC and identity documents

7 years after membership termination (AML legal requirement)

Transaction and financial records

7 years after the transaction (tax and regulatory requirement)

Pool activity records

7 years after pool closure

Account data

Duration of membership + 3 years after termination

Communications and support logs

3 years from the date of the communication

Marketing consent records

Until consent is withdrawn + 3 years

Cookie data (analytics)

Maximum 13 months from collection

After the applicable retention period, your data will be securely deleted or anonymised so that it can no longer be linked to you.

9. YOUR PRIVACY RIGHTS — BY JURISDICTION

Depending on where you live, you have specific legal rights over your personal data. We honour all of these rights regardless of your location.

Nigeria — NDPR 2019 + NDPA 2023

Right to access, correct, delete, object, portability, and withdraw consent

European Union/EEA — GDPR

Right to access, rectification, erasure, restrict processing, portability, object, and complain to your national DPA

United Kingdom — UK GDPR

Same rights as EU GDPR above. Complain to the ICO: ico.org.uk

USA — California — CCPA/CPRA

Right to know, delete, opt-out of sale, non-discrimination, and correct inaccurate data

Canada — PIPEDA

Right to access, challenge accuracy, and withdraw consent

South Africa — POPIA

Right to access, correction/deletion, object to processing, and complain to the Information Regulator

Ghana, Kenya, and others

Rights per local Data Protection Authority — contact privacy@lendtraders.com

HOW TO EXERCISE YOUR RIGHTS

Please include your full name, registered email address, and a clear description of the right you wish to exercise.

We will respond within 30 days. We may need to verify your identity before processing your request.

We will not charge a fee unless your request is manifestly unfounded or excessive.

10. DATA SECURITY

We take the security of your personal data extremely seriously and implement the following measures:

• Encryption: All data transmitted uses TLS 1.2 or higher. Sensitive stored data uses AES-256 encryption.

• Access Controls: Access to personal data is restricted to authorised personnel on a strict need-to-know basis.

• Two-Factor Authentication: Required for all member logins and all internal staff access.

• Regular Security Audits: Regular security assessments and penetration tests are conducted.

• Incident Response: We have a documented data breach response procedure. In the event of a qualifying breach, we will notify you and the relevant regulatory authority within 72 hours of discovery.

Despite our best efforts, no method of transmission over the internet is 100% secure. If you believe your interaction with us is no longer secure, contact support@lendtraders.com immediately.

11. CHILDREN'S PRIVACY

The LendTraders platform is strictly for persons aged 18 and above. We do not knowingly collect, use, or store personal data from anyone under 18. Our KYC process includes age verification.

If you believe a person under 18 has provided us with personal data, please contact privacy@lendtraders.com immediately and we will promptly delete that information.

12. AUTOMATED DECISION-MAKING

We use some automated processes including KYC verification, transaction monitoring, and AML risk scoring as required by our SCUML obligations. Where automated decisions significantly affect you, you have the right to request human review of the decision. Contact privacy@lendtraders.com to exercise this right.

13. CALIFORNIA RESIDENTS — CCPA DISCLOSURES

If you are a California resident, the following additional information applies:

• Categories Collected: Identifiers, financial information, commercial information, internet activity, geolocation, and inferences.

• Sale of Data: We do NOT sell your personal data to any third party.

• Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.

• Authorised Agent: Contact privacy@lendtraders.com with written proof of authorisation.

14. EU AND UK RESIDENTS — ADDITIONAL GDPR DISCLOSURES

If you are located in the EU, EEA, or United Kingdom, the following additional information applies:

• Data Controller: LENDTRADERS LIMITED, Nigeria (RC: 7942080).

• EU/UK Representative: [INSERT EU/UK REPRESENTATIVE — required if actively targeting EU/UK members]. eurepresentative@lendtraders.com

• Supervisory Authority: EU: edpb.europa.eu | UK ICO: ico.org.uk

• Data Protection Officer: dpo@lendtraders.com

15. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy to reflect changes in our practices, technology, legal requirements, or for other operational reasons. When we make changes we will:

• Update the Last Updated date at the top of this Policy

• Notify all members by email at least 14 days before changes take effect

• Display a prominent notice on our platform

• Where required by law, request your renewed consent

Your continued use of the platform after the effective date constitutes acceptance of the updated Policy.

16. COMPLAINTS

If you have a complaint about how we handled your personal data, please first contact us at privacy@lendtraders.com. We will respond within 30 days. If you are not satisfied, you have the right to complain to the relevant supervisory authority in your jurisdiction:

Nigeria

NITDA — nitda.gov.ng

European Union

Your national DPA — edpb.europa.eu

United Kingdom

Information Commissioner's Office (ICO) — ico.org.uk

South Africa

Information Regulator — justice.gov.za/inforeg

Kenya

Office of the Data Protection Commissioner — odpc.go.ke

Ghana

Data Protection Commission — dataprotection.org.gh

Canada

Office of the Privacy Commissioner — priv.gc.ca

USA

Federal Trade Commission — ftc.gov and relevant state authority

CONTACT OUR PRIVACY TEAM

General Queries: support@lendtraders.com

Rights Requests: privacy@lendtraders.com

Data Protection Officer: dpo@lendtraders.com

EU/UK Representative: eurepresentative@lendtraders.com

LENDTRADERS LIMITED | RC: 7942080 | EFCC SCUML: SC 122101912

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