The Fewchore Privacy Policy

Here's how we protect your data and respect your privacy.

General Terms and Conditions

This Terms and Conditions constitute our offer and sets out the terms governing the Agreement between you and Fewchore Finance Company Limited on the use of the Fewchore Mobile Application (“the App”). It is important that you read the Terms and Conditions carefully and keep them for future reference. By accepting this online offer, you agree that you have read and accepted the Terms and Conditions (together with our Data Privacy Policy). You, therefore, authorize us to review your credit report and you understand that this loan (if granted) is subject to various fees and charges which includes but not limited to transaction fees and default fees.

You will be asked to provide certain information when you apply for this loan. This information is used for verification purposes and the handling of such information will be governed by this Terms and Conditions.

For ease of understanding, “you”, “your”, “Customer” and “Borrower” mean the person who applied for this loan facility and agrees to this Terms and Conditions, while “Fewchore Finance”, “we”, “us”, “our”, “Bank”, “Company” and “Lender” shall mean Fewchore Finance Company Limited, and following an assignment, any person, company or bank to whom the rights and/or obligations of the Lender have been assigned.

You have the right to seek independent legal counsel in order to fully understand the implications and potential consequences of agreeing to this Terms and Conditions prior to ticking the “I agree to the Terms and Conditions” box. By ticking the “I agree to the Terms and Conditions” box,, you indicate that you have read, understood and agreed to be bound by this Terms and Conditions (as may be amended, supplemented and varied from time to time).

From time to time updates to the App may be issued to you. Depending on the update, you may not be able to use the Services until you have downloaded the latest version of the App and accepted any new terms and conditions.

1. DEFINITIONS OF TERMS

For the purposes of this Agreement, unless the context requires otherwise:

  • Account means your loan account with the Company;
  • Business Day means a day other than a Saturday, Sunday or national or public holiday declared in the Federal Republic of Nigeria in which commercial banks are not open for business;
  • Credit Reference Bureau means a dedicated credit reference bureau duly licensed by the Central Bank of Nigeria (CBN) pursuant to the Credit Reporting Act, 2017 (as amended, revised or promulgated from time to time), the CBN Guidelines For The Licensing, Operations And Regulation Of Credit Bureaus In Nigeria and all other laws and regulations on the entities charged to collect and facilitate the sharing of customer credit information;
  • Force Majeure means events, circumstances or causes beyond the reasonable control of the Company making the Company’s performance of its obligations inadvisable, commercially impracticable, illegal, or impossible, including, without limitation, acts of God, inclement weather, fire, explosions, floods, pandemics, epidemics, strikes, work stoppages, slowdowns or other industrial disputes, riots or civil disturbances, health, safety and security risks and acts of government which causes a delay or failure in the performance by a party of its obligations (other than payment obligations hereunder under this Agreement);
  • Encumbrance includes any mortgage or charge (whether legal or equitable), lien, option, security interest, restrictive covenant, pledge, assignment, title retention, trust arrangement or other restriction of any kind or other encumbrance securing or any right conferring a priority of payment in respect of any obligation of any person;
  • Interest means the sum charged by the Company on the loan granted to the borrower;
  • Loan means the principal amount of the loan made or to be made by the Company to you under this Terms and Conditions from time to time through the App or (as the context requires) the principal amount outstanding for the time being of that loan;
  • Indebtedness means all outstanding sum owed by the you to the Company
  • Request means a request or instruction received by BIL from you or purportedly from you through the App or by mail or telephone conversation upon which the Company is authorised to act;
  • SMS means a short message service consisting of a text message transmitted from your mobile phone to another;
  • Third Parties mean banks, payment companies, asset management firms, credit reference bureaus, debt recovery companies, or any other person (entity) that provides any form of service or information to us for the provision of the Service;
2. GRANT AND SCOPE OF LICENSE

In consideration of you agreeing to abide by this Terms and Conditions, we grant you a non-transferable, non-exclusive license to use the App on your device. We reserve all other rights. Except as expressly set out in this Terms and Conditions or as permitted by any local law, you agree:

  • not to rent, lease, sub-license, loan, translate, merge, adapt, vary or modify the App;
  • not to make alterations to, or modifications of, the whole or any part of the App, or permit the App or any part of it to be combined with, or become incorporated in, any other programs;
  • not to provide or otherwise make available the App in whole or in part (including object and source code), in any form to any person without prior written consent from us;
  • not use the App in any unlawful manner, for any unlawful purpose, or in any manner inconsistent with this Terms and Conditions, or act fraudulently or maliciously, for example, by hacking into or inserting malicious code, including viruses, or harmful data, into the App;
  • not infringe our intellectual property rights or those of any third party in relation to your use of the App, including the submission of any material (to the extent that such use is not licensed by this Terms and Conditions);
  • not transmit any material that is defamatory, offensive or otherwise objectionable in relation to your use of the App;
  • not use the App in a way that could damage, disable, overburden, impair or compromise our systems or security or interfere with other users;
  • and to comply with all technology control or export laws and regulations that apply to the technology used or supported by the App (the Technology).
3. YOUR OBLIGATIONS ON THE LOAN ACCOUNT
  • You agree to repay the loan plus accrued interest in accordance with the dedicated repayment schedule as provided upon approval of this application. Such repayment schedule may change at the sole and absolute discretion of the Company
  • We presume that you have authorized any loan application made in your name via this platform. You will be deemed responsible for any unauthorized application using this platform. The Company nevertheless reserves the right to refuse to carry out any request in our sole and absolute discretion.
  • You acknowledge that to the full extent permitted by law, the Company shall not be liable for any unauthorized drawing, transfer, remittance, disclosure, any activity or any incident on your account by the fact of the knowledge and/or use or manipulation of your Account PIN, password, ID or any means whether or not occasioned by your negligence.
  • The Company is authorized to effect such orders in respect of your Account as may be required by any court order or competent authority or agency under the applicable laws.
  • You agree to repay the loan on the repayment due date via electronic debit from the debit card/bank account you provided.
  • We shall on the repayment due date deduct via the card details or bank account provided by you. We will never conduct any transactions via the card details or bank account, except as related to the scheduled loan repayments. In the event of a double repayment initiated in error by you, we will on a best effort basis process a refund within a reasonable time.
  • You hereby indemnify us against any and all losses, liabilities or damages that may arise in the event that you use a third party's card on this platform without the consent of such third party.
  • In the event of a default or insufficiency of funds in your bank account, you hereby authorize us to charge any other cards or bank accounts, details of which you may have provided to us on this platform (or which may be connected with your BVN) other than the primary card listed on an ongoing basis until the debt is settled.
  • You are permitted to rescind this application within seven (7) days from the date of loan approval, provided we have not disbursed the loan to you.
  • You shall provide us with information, via e-mail or other electronic medium or any other form of writing as well as documents submitted in support of the loan application form, that are true, accurate and complete. We accept no liability for consequences arising out of any erroneous, incorrect or incomplete information supplied by you. If you suspect that there is an error in the information you have provided to us, you shall advise us accordingly without delay. We will endeavor to correct the error whenever and wherever possible on a 'best effort' basis but shall have no liability arising therefrom.
  • You shall complete your repayment instrument details with true, accurate, up to date and complete personal information on this platform. In the event that your personal information, including phone number, address and status of employment changes, you are required to inform us of such change without delay. Under no circumstance would we be liable for any loss, expense or damage of any kind incurred by us due to your non-compliance with this requirement.
  • You warrant and represent that you have the right and capacity to accept this loan and have taken all necessary actions to authorize the same in accordance with the terms and conditions herein.
  • You also represent and warrant that you are not in default under any obligation in respect of any borrowed money that the acceptance of this facility will be or result in breach of or default under any provision of any other agreement to which you are a party.
4. INTEREST AND OTHER FEES
  1. Subject to iii and iv below, the Annualized Percentage Rate of Interest (“APR”) for the loan is in line with prevailing market conditions.
  2. We will calculate interest at a flat rate on the daily balance outstanding.
  3. We may in our sole discretion increase or decrease the prevailing interest rate for any reason.
  4. Any change in interest rate will take effect in respect of your loan following a minimum of 14 days’ written notice to you in this regard.
  5. All payments to be made by you under this Terms and Conditions shall be made in full without any set off or counter claim and save in so far as required by the law to the contrary, free and clear of and without any deduction or withholding whatsoever. If you are at any time required to make any deduction or withholding from any payment to the Company, you shall immediately pay to the Company such additional amounts as will result in the Company receiving the full amount it would have received had no such deduction or withholding been required
  6. Where you fail to pay the instalment by the payment due date, we will charge default interest at a rate of 2% per month (outstanding loan amount + outstanding accrued interest). We will apply default interest rate three (3) days after the payment due date. We shall have the right to apply other late fees or penalties on such amount loaned to you at a rate to be communicated to y0u.
  7. There would be a processing fee of ₦100 flat. In the event that we vary the rate of interest payable on the loan, you shall be duly notified 10 days prior to the implementation of said variation.
5. PAYMENTS
  1. All payments by you will be made via the following methods: electronic debit from your verified debit card/bank account. All other methods of payment will be accepted with our consent only.
  2. In particular, you will be given a dedicated and customized repayment schedule upon approval of the loan.
  3. You will make monthly repayments in accordance with the repayment schedule.
  4. You will be sent an electronic message or SMS alert five (5) business days before each monthly repayment date and you hereby agree that such notice shall be conclusively deemed received by you without need of any further notice
  5. You shall repay the amount owed by the payment due date via an electronic debit from the card/account provided by you or through a direct debit mandate.
  6. You hereby agree that non-payment of the amount owed by the payment due date shall render you in default and entitles us to take steps to recover the outstanding loan amount in accordance with Clause viii below.
  7. You shall ensure that your card, wallet, mobile money or bank accounts are pre funded on or before the repayment dates. You hereby authorize us to charge any other card or accounts listed against your name on the App after unsuccessful attempts on any of your account/cards. You shall also indemnify us for any charges or fees due in respect of failed or unsuccessful direct debits on your bank accounts or cards.
  8. You may make an early payment of all the outstanding loan obligation due hereunder on any day before the final payment date.
6. PROVISION OF ADDITIONAL INFORMATION

At our request, you will be required to provide us with latest financial statements, contingent liability details and any other reasonable information relating to you or your financial affairs. You hereby also consent to us requesting your Employer to confirm and or provide relevant information to us as well as any other information which we may require hereunder.

7. USE OF CREDIT BUREAU
  • We will approach some credit reference bureaus for a credit report on you in considering any application for a loan.
  • You authorize us to access any information available to us as provided by the credit reference bureau.
  • You consent tour disclosure and provision of your personal information to the credit reference bureaus.
  • You also agree that your details and the loan application decision will be registered with the credit agency.
8. EVENT OF DEFAULT

An Event of Default in terms of this Terms and Conditions will occur if:

  • You fail to make any scheduled repayment in full, on or before the payment due date in accordance with the monthly repayment plangiven to you.
  • A representation, information, warranty or assurance made or given by you in connection with this loan or any information or documentation supplied by you, is later discovered to be materially incorrect.
  • You do or omit to do anything which may prejudice our rights in terms of this Terms and Conditions or cause us to suffer any loss or damage.
  • A bankruptcy petition is filed against you.
  • Fraud is detected at any time during the lifespan of the loan.
  • Where you are unable to pay any other party within the meaning of Section 1 of the Bankruptcy Act (Cap 30) Laws of the Federation of Nigeria.
  • Where you fail to remedy any default in the performance or observance of any other term, condition or covenant herein after ten (10) days’ notice is given to you by us.

If you default in your obligations under this Agreement, we will be entitled to do the following:

  • On each repayment date, collect the total amount payable by the date in accordance with the repayment plan schedule given to you.
  • Where you fail to honor your obligation to repay your total monthly repayment amount by the payment due date, we will attempt to collect the outstanding amount.
  • Where a three (3) day period has elapsed since the payment due date and all or some of the repayment amount remains outstanding, we will start calculating accelerated interest at the rate of 2% per month plus the applicable borrowing interest rate.
  • Following your default, we reserve the right to assign our right, title and interest under the Terms and Conditions to an external collections agency who will take all steps, within the bounds of the law, to collect the outstanding loan amount.
  • Upon an event of default, notwithstanding any provision of this Terms and Conditions, we reserve the right to declare the loan (and all accrued interest and all other amounts outstanding) under this Terms and Conditions is immediately due and payable, whereupon they shall become immediately due and payable.
  • We also reserve the right to institute legal proceedings against you and are under no obligation to inform you before such proceedings commence.
  • We will be entitled to terminate this Agreement (after service of any notice required thereunder) ifyou in any way perpetrate, attempt to or are involved in any act of fraud or other criminal activity in respect of us or the loan, or if any information provided by you as part of your application is incorrect or misleading in any material manner. On such termination, we reserve the right to demand repayment of the full loan amount with interest calculated as stipulated in these Terms and Conditions.
  • We reserve the right to assign our right, title and interest in the Loan and rights under the Terms and Conditions to an external collections agency who will take all reasonable steps to collect the outstanding Loan (together with any interest and fees accrued), and in this regard, the Company shall have the right to share with such collection agencies, any information about you (including transaction history, Personal Information, Relevant Information) which it deems relevant. You agree and consent to all such disclosures.
  • We reserve the right to supply all information concerning the Event of Default to Credit Reference Bureaus. A copy of any information concerning you sent to a Credit Reference Bureau shall be made available to you upon written request.
  • Hold you responsible for all legal costs and expenses incurred by us in attempting to obtain repayment of any outstanding loan balance owed by you. Interest on any amount which becomes due and payable shall be charged in accordance with this Terms and Conditions.

The default interest rate:

  • is charged by us in addition to the normal interest rate which we charge you at the same time and in the same manner as that normal interest;
  • accrues before and after any court judgment, which we obtain against you; and
  • is a form of liquidated damages to compensate us for the additional risk and other administrative costs and expenses associated with your failure to pay the outstanding sum.
9. ELECTRONIC DOCUMENT INDEMNITY

We hereby agree to act upon this electronic application, as provided by you, for loan facilities with us and you hereby irrevocably and unconditionally agree that this Terms and Conditions shall be binding and enforceable against you.

10. MISCELLANEOUS
  • This Terms and Conditions shall be governed by the laws of the Federal Republic of Nigeria and shall be subject to the jurisdiction of the courts of the Federal Republic of Nigeria.
  • If we do not strictly enforce our rights under this Terms and Conditions (including our right to insist on the repayment of all sums due on the Payment Due Date) or grant you an indulgence, we will not be prevented from insisting upon our strict rights at a later date.
  • We reserve the right to transfer or assign our rights and obligation under this Terms and Conditions (including our obligation to lend money to you or the amount owed under this Terms and Conditions) to another person.
  • We may inform you of a transfer/assignment of our rights hereunder if such a transfer results in a change in the administration of this Terms and Conditions.
  • You authorize us to disclose any information or documentation relating to the loan to third parties including credit reference bureaus, collection agencies, law enforcement agencies including but not limited to the Economic and Financial Crimes Commission and the Special Fraud Unit of the Nigerian Police Force as well as your employers (where you are in salaried employment) if the loan has ceased to be serviced by you.
  • The Company reserves the right, at all times, to vary the terms and conditions of the loan. Any such variation will become effective upon notice to you by any means we consider reasonable in the circumstance.
  • We may at any time with or without notice (a) combine or consolidate some or all of your loan account with us, without any liability to us and (b) set off and transfer any sum standing to the credit of any such account in full or partial payment of any amount you owe to us.
  • You waive all rights of confidentiality whether arising under any applicable law or in any other manner whatsoever and irrevocably agree that you shall not argue to the contrary before any court of law, tribunal, administrative authority or any other body acting in any judicial or quasi-judicial capacity.
  • This clause is in addition to and does not amend or qualify any other present or future right of ours to combine or set off any of your accounts with us.

Privacy Policy

The following Privacy Policy describes what information we gather about you and how we, collect, store, use, transfer, disclose and protect your Personal Information. This Privacy Policy must be read together with the above Terms and Conditions.
Please read the following carefully to understand our views and practices regarding your Personal Information and how we will treat it.

1. CONSENT

By downloading the Fewchore Mobile App (“the App"), visiting our website at Fewchore Mobile, ticking the box saying, “I agree to the Terms and Conditions”, or performing any other activity that form part of our business (digitally or non-digitally), you confirm that you have read, understood and accepted the terms of this Privacy Policy set out hereunder. You also consent to the following:

  • That we can provide materials and other information about your legal rights and duties to you electronically.
  • That we are authorized to share, receive and use data/information collected from your transaction with other affiliated third parties.
  • That we are authorized to access data and contacts on your device for the purpose of this loan facility.
  • That your electronic signature on agreements and documents has the same effect as if you signed them using ink on paper or any other physical means.
  • That we can send all important communications, billing statements and demand notes and reminders to you electronically via our app or to an email address that you provide to us. When we send you such information/data electronically and/or make it available online as indicated above, that shall have the same meaning and effect as if we provided said information/data to you physically.
  • For the avoidance of doubt, approval of the credit facility under this Agreement is conditional upon the validation of your bank verification number (BVN) and verification of your debit card. This offer will be rescinded and the approval for the credit facility will not be successful if the BVN validation and other verification checks are unsatisfactory.

Such consent can be withdrawn at any time, provided always that such withdrawal will not affect the legality and binding effect of the processing of your personal information before the consent given was withdrawn.

This Privacy Policy together with our Terms and Conditions and any additional terms applies to your use of the System and the Service.

2. LINKED WEBSITES

Other websites that may be linked to us are not governed by this Privacy Policy. You re advised to review the privacy policies on each of the websites before disclosing any personal information.

This Privacy Policy includes the following matters:

  • Definition
  • Personal Information which we collect
  • The use of Personal Information which we collect
  • Sharing of Personal Information which we collect
  • Cross-border transfers of Personal Information
  • Retention of Personal Information
  • Access and update/correction of Personal Information
  • Where we store your Personal Information
  • Security of your Personal Information
  • Changes to this Privacy Policy
  • Language
  • Acknowledgement and consent
  • Marketing and promotional material
  • Third party websites
  • Limitation of liability
  • How to contact us
3. DEFINITION

Unless otherwise defined, all capitalized terms used in this Privacy Policy shall have the same meanings ascribed to them in our Terms and Conditions (as applicable).

  • “Applicable Law” means all national and international legislations, regulations, circulars, guidelines that govern this Privacy Policy or any activities done by us in the processing of your personal information. It shall include, without limitations, the Nigeria Data Protection Regulation, 2019, the Money Laundering (Prevention and Prohibition) Act, 2022 etc.
  • “Processing” means the collecting, handling, protecting, and storing of your personal information. It shall include the need and manner of disclosure of your personal information to third parties (including without limitation, our service providers and credit rating agencies).
  • “You” means all users of the App, including persons that have downloaded the app, visited the website, or performed any activity that forms part of our business.
4. PERSONAL INFORMATION WHICH WE COLLECT

We collect certain Personal Information about you in various forms. The Personal Information which we collect may be provided by you directly (for example, when you open an Account to use the Service via the App, or you otherwise provide Personal Information to us in a form on our app or website) or by third parties (including but not limited to your employer, providers of “Know-Your-Client” and anti-money laundering services, background check providers, your banks and financial institutions, credit rating and reference providers etc.), or collected by corresponding with us via email or chat, or be collected automatically when you use the App. We may collect information in various forms and for various purposes (including purposes permitted under Applicable Law).

Information obtained from you or from your Mobile Device directly:

  • When you register and create an Account with us using the App, you have to provide certain Personal Information, including (without limitation) your name, age, date of birth, gender, photo, physical home address, e-mail address, working information, emergency contact, your phone number, country of residence, employment details (e.g. the name, address and contact details of the organization you work for, your job title, your salary details etc.) SIM card details, financial and credit information (including your bank account details bank verification number, and bank statements where applicable) and an Account ID and/or password amongst others that you will use to access the App after registration.
  • When you use the App, you must provide such relevant information as may reasonably be required by us for the App to work. For example, when a payment is made through the electronic money facility within the App, you will provide information relating to the payment, such as the type of payment card used, the name of the issuer of that payment card, the name of the account holder for that payment card, the name of the beneficiary of the payment, the account number of the beneficiary of the payment, the number of that payment card, and the amount of money paid amongst others .
  • You agree to provide the information listed in Clauses 4.1.1. and 4.1.2. above because they are mandatory requirements of the Central Bank of Nigeria, the regulator of our business.

Information collected whenever you use the App:

  • Whenever you use the App, we may collect certain technical data concerning your usage such as, internet protocol (IP) address, information as webpages previously or subsequently viewed, duration of every visit/session, the internet device identity (ID) or media access control address, and also information regarding the manufacturer, model and operating system of the device that you use to access the App.
  • Whenever you use the App, certain information may also be collected on an automated basis using cookies. Cookies are small application files stored on your computer or Mobile Device. We use cookies to track user activity to enhance user interface and experience. Most Mobile Devices and internet browsers support the use of cookies; but you may adjust the settings on your mobile device or internet browser to reject several types of certain cookies or certain specific cookies. Your Mobile Device and/or browser would also enable to you to delete at any time whatever cookies have previously been stored. However, doing so may affect the functionalities available on the App or our Website.
  • Meanwhile, you will be required to provide technical information to us while using the App, including the type of Mobile Device you use, a unique device identifier (for example, your mobile device’s IMEI number, the MAC address of your Mobile Device’s wireless network interface, or the mobile phone number used by your Mobile Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting. We will also collect information stored on your Mobile Device, including contact lists, call logs, SMS logs, Facebook, and other social media details, contact lists from other social media accounts, photos, videos or other digital content.

Collection of Location

We collect your geo-location information when the App is running in the foreground. We endeavor to cease collection of your geo-location information when the App is in the background, but such information may still be collected unintentionally. You can always choose to disable the geo-location tracking information on your Mobile Device temporarily. However, this may affect the functionalities available on the App.

Collection of Financial SMS Information

  • We don’t collect or store your personal SMS from your inbox.
  • We only collect financial SMS sent by 6-digit alphanumeric senders from your inbox which helps us in identifying the various accounts that you are holding and the cash flow patterns that you have as a user to help us perform a credit risk assessment which enables us to determine your risk profile and to provide you with the appropriate credit analysis to enable you to take financial facilities from the regulated financial entities and other service providers available on the platform.
  • While using the app, it periodically sends the financial SMS information to our affiliate server and to us.
  • We collect SMS information only after obtaining your additional explicit consent.
  • The SMS information will be uploaded to Fewchore Mobile. We will delete the SMS information after we have determined your risk profile.

Collection of Contact List

  • As a part of our loan journey, we require references from the Loan applicant. In this regard, during filing the form on our App, we collect your contact information to detect close contacts to enable you to autofill the data during the loan application process and assure that the data collected shall not be shared with any third party without your prior consent.
  • We collect contact information from your device for the purposes of risk analysis by enabling us to detect credible references. The more credible the references are, the lower the risk associated to a User.
  • We collect contact information only after obtaining your additional explicit consent. The contact information will be uploaded to Fewchore Mobile. We will delete the contact information after we have determined your risk profile.

Collection of Installed Applications

We collect a list of the installed applications metadata information which includes the application name, package name, installed time, updated time, version name and version code of each installed application on your device to assess your credit worthiness and enrich your profile with pre-approved customized loan offers only for the purpose of this service and undertake not to disclose the information to a third party without your prior consent.

Storage

We require the storage information permission that allows the App to enable you to upload photos and/or documents to complete the application form during your loan application journey.

Camera

We require the camera information permission to provide you an easy/smooth experience and to enable you to click photos of your KYC documents along with other requisite documents and upload the same on the App during your loan application journey.

Media, Photos and Files

We require the media, photos, and files permission that allows the App to enable you to upload photos or documents to complete the application form during your loan application journey.

Calendar Information

  • We require calendar information so that you can set up a loan due date memo in the app after the loan, which will remind you to repay your loan on time.
  • The calendar information will be uploaded to Fewchore Mobile. We will delete the calendar information after we have determined your risk profile.

Data Upload

To better understand your identity and ensure that your users meet their credit needs. Therefore, before you submit your application, we need your authorization to collect "Contact" and "SMS" Information, and upload them to Fewchore Mobile and other credit rating and reference platforms. We are committed to using secure data transfer protocol to encrypt data and ensure the security of information. Please feel free to use. If you do not agree, please log out and uninstall the Application.

Information collected from Third Parties

Due to the nature of the Services which we provide, we are required to work with a number of third parties (including Credit Reference Bureaus, Banks, Mobile Network Providers, collection agencies, our agents, vendors, suppliers, contractors, partners and any others who provide services to us, perform functions on our behalf, or whom we collaborate with) and we may receive information about you from them. In such cases, we will only collect your Personal Information for or in connection with the purposes for which such third parties are engaged or the purposes of our collaboration with such third parties (as the case may be), provided that we have taken reasonable steps to ensure that such third parties would undertake to us to obtain your consent for the disclosure of your Personal Information to us in line with this Privacy Policy and Applicable Law.

Information about Third Parties you provide to us

You may provide us with Personal Information relating to other third-party individuals (such as Personal Information relating to your spouse, family members, friends and emergency contact). You will of course need their consent to do so–see Section 12 “Acknowledgement and Consent”, below, for further information.