Introduction

Thank you for accessing the Privacy Policy of Sufficient Grace Investment Limited (“SGI”, “we”, “our”, or “us”), including our website, mobile applications, and other products and services (collectively, the “Services”).

We respect your privacy and are committed to protecting your personal information. Data protection is a matter of trust, and your privacy is important to us. We only collect, use, disclose, and retain your personal information where necessary to provide our Services, comply with applicable laws, and improve your experience.

By accessing or using our Services, you acknowledge that you have read and understood this Privacy Policy.

What Data We Collect and How We Use It

We collect information from you when you use our website, mobile application, or other Services to provide secure, reliable, and personalized financial services.

1. Personal and Account Information

We may collect personal information including:

  • Full name
  • Gender
  • Date of birth
  • Residential and postal address
  • Email address
  • Phone number
  • Government-issued identification
  • Passport photograph
  • Bank account information
  • Payment details
  • Next of kin information
  • Employment and income information where applicable
  • Biometric or identity verification information where required by law

Purpose

We use this information to:

  • Create and manage your account
  • Verify your identity
  • Process savings, investments, loans, financing, and other financial services
  • Communicate with you
  • Perform Know Your Customer (KYC), Anti-Money Laundering (AML), Counter Terrorism Financing (CTF), and other regulatory compliance obligations
  • Prevent fraud and financial crimes
  • Provide customer support

2. Financial Information

We may collect financial information including:

  • Bank account details
  • Transaction history
  • Savings records
  • Investment records
  • Loan applications
  • Loan repayment history
  • Financing records
  • Payment information

Purpose

This information is used to:

  • Process deposits and withdrawals
  • Manage savings and investment accounts
  • Assess loan and financing applications
  • Monitor repayments
  • Maintain financial records
  • Meet legal and regulatory obligations

3. Location Information

Our Services may collect your precise or approximate location information, including background location where applicable and permitted by your device settings.

Purpose

We use location information to:

  • Verify account security
  • Detect and prevent fraudulent activities
  • Enable location-based security features
  • Improve operational efficiency
  • Comply with applicable regulatory requirements

You may disable location access through your device settings, although certain features may become unavailable.

4. Device and Technical Information

We automatically collect certain technical information including:

  • Device model
  • Operating system
  • Device identifiers
  • Browser type
  • IP address
  • Mobile network information
  • Crash reports
  • System logs
  • App version

Purpose

We use this information to:

  • Maintain platform security
  • Improve application performance
  • Diagnose technical issues
  • Prevent unauthorized access
  • Ensure compatibility across devices

5. Usage Information

We collect information regarding how you use our Services, including:

  • Features accessed
  • Pages viewed
  • Time spent
  • Navigation patterns
  • Login activities
  • Transaction activities

Purpose

This helps us:

  • Improve our Services
  • Personalize user experiences
  • Monitor system performance
  • Detect suspicious activities
  • Develop new products and features

6. Communications

If you communicate with us through email, telephone, social media, chat, or other support channels, we may collect:

  • Communication content
  • Support requests
  • Call recordings where permitted
  • Feedback
  • Related metadata

Purpose

We use this information to:

  • Respond to inquiries
  • Resolve complaints
  • Improve customer service
  • Maintain service records

7. Optional Device Permissions

Depending on the features you use, we may request access to:

  • Camera
  • Photos
  • File storage
  • Contacts
  • Notifications

These permissions are requested only with your consent and may be withdrawn through your device settings at any time.

These permissions may be used for:

  • Identity verification
  • Document uploads
  • Profile photographs
  • Sharing payment information
  • Customer support
  • Security verification

Information Sharing and Disclosure

We may share your personal information with:

  • Regulatory authorities
  • Banking partners
  • Payment processors
  • Credit bureaus
  • Identity verification providers
  • Fraud prevention agencies
  • Cloud service providers
  • Technology vendors
  • Professional advisers
  • Auditors
  • Collection agencies where legally permitted

We may also share information:

  • To comply with applicable laws or lawful requests by government authorities
  • To protect our legal rights
  • To prevent fraud or financial crimes
  • During mergers, acquisitions, restructuring, or sale of business assets

We do not sell your personal information to third parties.

Any third party processing your information on our behalf is required to maintain appropriate confidentiality and security standards.

Cookies and Similar Technologies

Our website uses cookies and similar technologies to improve your browsing experience.

Cookies help us:

  • Remember your preferences
  • Keep you signed in
  • Analyze website traffic
  • Improve performance
  • Enhance security

You may disable cookies through your browser settings, although some features of our Services may not function properly.

Data Security

We maintain appropriate administrative, technical, and physical safeguards designed to protect your personal information against unauthorized access, disclosure, alteration, or destruction.

Our security measures include:

  • SSL/TLS encryption
  • Secure servers
  • Firewalls
  • Access controls
  • Encryption of sensitive information
  • Regular security monitoring
  • Employee confidentiality obligations

While we employ industry-standard security measures, no internet transmission or electronic storage method can be guaranteed to be completely secure.

You are responsible for maintaining the confidentiality of your account credentials and should never share your password with anyone.

Data Retention

We retain your personal information only for as long as necessary to:

  • Provide our Services
  • Meet contractual obligations
  • Resolve disputes
  • Enforce agreements
  • Comply with legal and regulatory requirements

Where retention is no longer necessary, we securely delete or anonymize your personal information.

Your Rights

Subject to applicable laws, you may have the right to:

  • Access your personal information
  • Correct inaccurate information
  • Request deletion of your information
  • Restrict certain processing activities
  • Object to certain processing
  • Withdraw consent where processing is based on consent
  • Request data portability where applicable

Requests may be subject to legal or regulatory limitations.

Account and Data Deletion

You may request the deletion of your account and personal information by contacting us.

Upon verification of your identity, we will process your request within a reasonable timeframe and delete your personal information from our active systems where permitted by law.

However, we may retain certain information where required for:

  • Financial regulations
  • Anti-Money Laundering (AML)
  • Know Your Customer (KYC)
  • Tax obligations
  • Accounting requirements
  • Fraud prevention
  • Legal proceedings
  • Regulatory compliance

Once your account has been deleted, it cannot be recovered. Any future use of our Services will require the creation of a new account.

Children’s Privacy

Our Services are not intended for individuals under the age permitted by applicable law to enter into financial agreements without appropriate consent.

We do not knowingly collect personal information from children without lawful authorization.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our Services, legal obligations, or business practices.

Where significant changes are made, we will notify users through appropriate channels. Continued use of our Services after such updates constitutes acceptance of the revised Privacy Policy.

Contact Us

If you have any questions, requests, or concerns regarding this Privacy Policy or our handling of your personal information, please contact us:

Sufficient Grace Investment Limited

Email: [email protected]

We will respond to your request as promptly as reasonably possible.

Effective Date: Feb 25, 2026.