PRIVACY POLICY
Please Read Carefully
Effective Date: 1st June 2026
1. INTRODUCTION
Collectra Tech Ltd (“Collectra”, “we”, “us” or “our”) has created this Privacy Policy to explain
how we collect, use, process, disclose, store and protect Personal Data in connection with our
business and services.
Collectra is a Nigerian company established, amongst other purposes, to provide debt recovery,
collection and receivables management services for individuals, businesses and organizations. Our
services may also include customer engagement, tracing, follow-up, verification, field support and
recovery support services in connection with lawful commercial transactions.
This Privacy Policy applies to Personal Data processed by Collectra in the course of providing our
services, including Personal Data relating to customers, clients, debtors, borrowers, guarantors,
referees, contact persons, representatives, agents, service providers and other individuals whose
information may be provided to or obtained by us in connection with our business activities.
Where Collectra processes Personal Data on behalf of a client, creditor, lender, financial
institution, business or other organization, such processing may be undertaken pursuant to the
instructions and lawful authority of that organization and in accordance with applicable data
protection laws.
By interacting with Collectra, providing Personal Data to us, communicating with us, or otherwise
using our services, you acknowledge that you have read and understood this Privacy Policy.
Where consent is the applicable lawful basis for processing, you may withdraw your consent at
any time, provided that Collectra is not otherwise permitted or required by law to continue
processing your Personal Data.
We may amend this Privacy Policy from time to time. Where material changes are made, we may
notify you by updating the effective date of this Privacy Policy and, where appropriate, by
providing additional notice through our website, electronic communications or other appropriate
means.
We encourage you to review this Privacy Policy periodically to remain informed about how we
handle Personal Data.
2. COLLECTION OF INFORMATION
We may collect and process the following categories of Personal Data:
A. Information provided directly by you
We may collect Personal Data that you provide to us when you:
- contact us by telephone, email, messaging platforms, website forms or other communication
channels;
- respond to our communications concerning a debt, receivable, account or other lawful
commercial obligation;
- provide information for the purpose of verifying your identity or contact details;
- make or discuss a payment or payment arrangement;
- submit a complaint, enquiry, request or other communication to us;
- interact with our employees, agents, field officers or authorized representatives; or
- otherwise voluntarily provide information to us.
B. Information received from our clients and business partners
In providing collection and recovery services, Collectra may receive Personal Data from clients,
creditors, lenders, businesses, organizations or other persons who lawfully engage us to provide
services.
Such information may include, where applicable:
- names and contact details;
- identification and verification information;
- account or customer reference information;
- information concerning outstanding debts, receivables or other financial obligations;
- transaction and payment information;
- details relating to guarantors, referees or authorized contacts;
- correspondence and records concerning the underlying obligation;
- information relevant to tracing and contacting the relevant person; and
- other information reasonably necessary for the performance of our contracted services.
C. Information obtained from other sources
In connection with lawful tracing, verification and recovery activities, we may obtain Personal
Data from publicly available sources, third-party databases, authorized service providers, business
partners, referees, guarantors, representatives or other lawful sources.
Where we receive Personal Data about you from another source, we may provide you with
appropriate information regarding the source and purpose of processing where required by
applicable law.
D. Information collected through our website, systems and communications
We may collect technical and usage information when you interact with our website, online
platforms, systems or electronic communications, including information concerning your device,
browser, IP address, usage activity and other technical information.
E. Information collected when you contact us
Where you contact Collectra by telephone, email, chat or other communication channels, we may
collect information relating to your communication, including the content and details necessary to
respond to your enquiry, complaint or request.
Where permitted by applicable law and necessary for legitimate business, quality assurance,
security or evidential purposes, communications may be recorded or otherwise documented.
3. USE OF PERSONAL DATA
Collectra may use Personal Data for the following purposes:
i. To provide, maintain and improve our debt recovery, collection, receivables management and
related services;
ii. To perform collection, recovery and receivables management activities on behalf of our clients
and authorized principals;
iii. To contact individuals in connection with lawful commercial obligations, outstanding debts,
receivables, payment arrangements or related matters;
iv. To trace and verify contact information and other relevant information for legitimate recovery
and verification purposes;
v. To verify identity and contact information and prevent fraud, impersonation and other unlawful
activities;
vi. To communicate with debtors, customers, guarantors, referees, representatives and other
relevant persons concerning the services we provide;
vii. To facilitate, record and administer payments, payment arrangements, settlements and other
recovery-related transactions;
viii. To maintain records relating to collection and recovery activities and provide reports, updates
and account information to our clients or authorized principals;
ix. To respond to comments, questions, complaints, enquiries and requests and provide customer
service;
x. To investigate and resolve disputes relating to accounts, payments, collection activities or our
services;
xi. To comply with applicable legal, regulatory, judicial, contractual and other lawful obligations;
xii. To cooperate with courts, law enforcement agencies, regulators, auditors, investigators and
other authorized persons where legally permitted or required;
xiii. To protect the rights, property, safety and security of Collectra, our clients, our employees,
agents, service providers and other persons;
xiv. To monitor, assess and improve the quality, effectiveness and security of our services and
recovery processes;
xv. To conduct internal audits, risk assessments, compliance reviews and investigations;
xvi. To maintain business and operational records;
xvii. To communicate administrative notices, service updates, security alerts and other relevant
information;
xviii. To establish, exercise or defend legal rights and claims;
xix. To link or combine information lawfully obtained from different sources where reasonably
necessary for the purposes for which the information is processed; and
xx. To carry out any other purpose for which the Personal Data was lawfully collected or for which
we have a valid lawful basis.
Collectra will process Personal Data in accordance with applicable data protection laws and will
not use Personal Data for purposes that are incompatible with the purpose for which it was
collected unless otherwise permitted by applicable law.
4. LEGAL BASIS FOR PROCESSING
Depending on the circumstances, Collectra may process Personal Data on one or more lawful bases
recognized under applicable data protection laws.
These may include:
- performance of a contract or steps taken at the request of a data subject before entering into a
contract;
- compliance with a legal or regulatory obligation;
- protection of the vital interests of an individual where applicable;
- performance of a task carried out in the public interest or in the exercise of official authority,
where applicable;
- legitimate interests pursued by Collectra, its clients or another authorized party, provided that
such interests are not overridden by the rights and freedoms of the Data Subject; and
- consent, where consent is required or relied upon as the lawful basis for processing.
Where Collectra processes Personal Data received from a client or principal for debt recovery or
receivables management purposes, the applicable lawful basis may arise from the underlying
relationship between that client and the relevant Data Subject, the client's legitimate interests,
contractual arrangements, legal obligations or another lawful basis recognised by applicable law.
5. DISCLOSURE OF INFORMATION
Collectra may disclose or provide access to Personal Data in the following circumstances:
A. Clients and authorized principals
We may disclose Personal Data to the client, creditor, lender, business or organization on whose
behalf we provide collection, recovery, tracing, verification or receivables management services.
B. Service providers and processors
We may provide Personal Data to trusted third-party service providers, contractors, technology
providers, consultants, field agents, tracing or verification service providers and other persons who
process Personal Data on our behalf or provide services necessary for our business.
We require such persons to process Personal Data only for authorized purposes and to maintain
appropriate confidentiality, security and data protection measures.
C. Professional advisers
We may disclose Personal Data to our lawyers, auditors, accountants, consultants, investigators or
other professional advisers where reasonably necessary for the provision of professional services
or the protection of our legitimate interests.
D. Courts, regulators and law enforcement
We may disclose Personal Data where required or permitted by law, regulation, court order, judicial
process or other lawful request, or where disclosure is reasonably necessary to cooperate with law
enforcement, regulatory authorities, investigators or other authorized bodies.
E. Legal proceedings and enforcement of rights
We may disclose Personal Data where reasonably necessary to establish, exercise or defend legal
rights, claims or proceedings.
F. Corporate transactions
In connection with an actual or proposed merger, acquisition, financing, restructuring, sale of
assets or other corporate transaction, Personal Data may be disclosed to relevant parties subject to
appropriate confidentiality and data protection safeguards.
G. With your consent or at your direction
We may disclose Personal Data where you have given appropriate consent or directed us to make
the disclosure.
H. Aggregated or anonymized information
We may use or disclose aggregated, anonymized or de-identified information that cannot
reasonably be used to identify an individual.
Where Collectra does not have a lawful basis for a particular disclosure, we will obtain consent
where required by applicable law.
6. TRACING, CONTACT AND RECOVERY ACTIVITIES
As part of our legitimate collection and recovery services, Collectra may contact individuals
concerning outstanding debts, receivables or other lawful commercial obligations.
Depending on the circumstances and information lawfully available to us, our recovery activities
may include:
- contacting you using contact details provided to us;
- verifying your identity and relevant contact information;
- tracing updated contact information where reasonably necessary;
- communicating concerning outstanding obligations;
- discussing payment arrangements or settlement options;
- conducting appropriate follow-up activities;
- providing account or recovery-related information to our client or authorized principal; and
- undertaking lawful field support or verification activities.
Collectra will conduct its collection and recovery activities in accordance with applicable laws and
will take reasonable steps to avoid unnecessary disclosure of Personal Data to persons who are not
authorized to receive it.
7. SECURITY
Collectra takes reasonable technical, organizational and administrative measures to protect
Personal Data against loss, theft, misuse, unauthorized access, disclosure, alteration, destruction
or other unlawful processing.
Our security measures may include:
- access controls limiting Personal Data to authorized personnel;
- confidentiality obligations applicable to personnel and service providers;
- appropriate physical and digital security measures;
- secure storage and transmission measures;
- encryption or other appropriate technical safeguards where applicable;
- monitoring and review of information security controls;
- internal policies and procedures for the protection of Personal Data; and
- continuous awareness and capacity-building for relevant personnel.
While we take reasonable steps to protect Personal Data, no method of electronic storage or
transmission can be guaranteed to be completely secure.
8. HOW LONG WE KEEP YOUR PERSONAL DATA
Collectra will retain Personal Data for only as long as reasonably necessary to fulfil the purpose
for which it was collected or processed, including the performance of our contractual obligations
and legitimate business activities.
We may retain Personal Data for longer where necessary to:
- comply with applicable legal or regulatory requirements;
- establish, exercise or defend legal claims;
- resolve disputes;
- maintain appropriate business and financial records;
- comply with contractual obligations; or
- protect the legitimate interests of Collectra or our clients.
When Personal Data is no longer required, it will be securely deleted, destroyed, anonymized or
otherwise disposed of in accordance with applicable laws and our applicable retention policies.
9. YOUR RIGHTS AS A DATA SUBJECT
Subject to applicable law and any lawful limitations, you may have the following rights in relation
to your Personal Data processed by Collectra:
RIGHT OF ACCESS
You may request access to the Personal Data we hold about you and request information regarding
how it is being processed.
RIGHT TO RECTIFICATION
You may request that inaccurate, incomplete or outdated Personal Data be corrected or updated.
RIGHT TO ERASURE
In certain circumstances, you may request that your Personal Data be erased from our records,
subject to circumstances where Collectra is legally entitled or required to retain the information.
RIGHT TO RESTRICT PROCESSING
In certain circumstances, you may request that the processing of your Personal Data be restricted.
RIGHT TO DATA PORTABILITY
Where applicable, you may request that your Personal Data be provided in a structured, commonly
used and machine-readable format or transmitted to another organization, subject to applicable
legal requirements.
RIGHT TO OBJECT
You may have the right to object to certain processing of your Personal Data, including processing
based on legitimate interests, subject to applicable law.
RIGHT TO WITHDRAW CONSENT
Where Collectra relies on your consent as the lawful basis for processing, you may withdraw your
consent at any time. Withdrawal of consent will not affect the lawfulness of processing carried out
before the withdrawal.
RIGHT TO LODGE A COMPLAINT
You may lodge a complaint concerning the processing of your Personal Data with the Nigeria Data
Protection Commission (“NDPC”) where you believe your rights have been infringed.
The NDPC provides information regarding Data Subject rights and data protection requirements
through its official channels.
If you wish to exercise any of your rights or raise a privacy concern, please contact Collectra using
the contact details provided in Section 12 of this Privacy Policy.
10. BREACH / PRIVACY VIOLATION
In the event of a personal data breach involving the accidental or unlawful destruction, loss,
alteration, unauthorized disclosure of, or access to Personal Data, Collectra will take appropriate
steps to contain, investigate, assess and remedy the breach.
Where notification to the Nigeria Data Protection Commission or any other competent authority
is required under applicable law, Collectra will make such notification within the applicable
statutory timeframe.
Where a breach is likely to result in a high risk to the rights and freedoms of affected Data Subjects,
Collectra will take appropriate steps to notify affected Data Subjects in accordance with applicable
law.
Collectra will also maintain appropriate records of personal data breaches and take reasonable
steps to prevent recurrence.
11. CONTACT US / DATA PROTECTION OFFICER
If you have any questions regarding this Privacy Policy, wish to exercise your rights as a Data
Subject, or wish to make a complaint concerning the processing of your Personal Data, please
contact:
Collectra Tech Ltd
Data Protection Officer: Peace Ufoh
Email: peace.ufoh@collectra.ng
We will take reasonable steps to respond to requests and complaints within the timeframes
prescribed by applicable law.
12. GOVERNING DATA PROTECTION LAWS
Collectra is based in Nigeria and the Personal Data we process is subject to applicable Nigerian
data protection laws, including the Nigeria Data Protection Act (NDPA) and applicable regulations,
guidelines, codes and other requirements issued by the Nigeria Data Protection Commission.
Where applicable, Collectra will also comply with other data protection or privacy laws that may
apply to a particular processing activity.
13. UPDATES TO THIS PRIVACY POLICY
Collectra may review and update this Privacy Policy periodically to reflect changes in our business
activities, technology, applicable laws, regulatory requirements or data processing practices.
Where material changes are made, we will update the Effective Date appearing at the beginning
of this Privacy Policy and may provide additional notice where appropriate.