Privacy Policy

1. Who we are

LendCore is a multi-microlender management platform operated by Nei Shot WebX Solutions CC (CC/2025/02042), a close corporation registered in Namibia ("Nei Shot", "we", "us"). This Privacy Policy explains how the LendCore platform collects, uses, stores, and protects personal information.

It applies to:

• Microlenders that subscribe to the platform (the data controllers);
• Borrowers and applicants who interact with services delivered through the platform (the data subjects); and
• Staff users employed by participating microlenders.

2. Controller / processor split

Each microlender that operates on LendCore is the data controller for its own borrowers - they decide what information is collected and why. Nei Shot is the data processor: we host, store, and process information on the microlender's instructions and only for the purposes set out in our service agreement with that microlender.

If you are a borrower, your specific privacy notice is published by the microlender you applied with (e.g. nei-shot-loans.lendcore.neishot.com/privacy-policy). That notice tells you who to contact for borrower-specific data requests.

3. Information we collect

The platform processes the following categories of personal information on behalf of microlenders:

• Identity data - full name, National ID or passport number, gender, date of birth, marital status, nationality.
• Contact data - physical address, postal address, mobile and landline numbers, email address.
• Financial data - employment status, employer details, declared income, bank statements, proof of income, debit-order mandates.
• Credit data - credit-bureau reports retrieved from Creditinfo Namibia, internal score history, repayment performance, adverse listings.
• Document data - KYC documents uploaded by the borrower (ID copy, payslip, proof of residence, bank statements).
• Application & loan data - application details, affordability assessments, underwriting decisions, loan terms, repayment records, complaints.
• Technical data - IP address, browser, device fingerprint, login activity, audit logs.

4. Purposes & legal basis

We process this information only for these specific purposes:

• To verify borrower identity and prevent fraud (legal obligation under FIA / NAMFISA Microlending Act).
• To run affordability and credit-bureau checks (legitimate interest + consent for the bureau pull).
• To process loan applications, disbursement, repayment collection, and arrears management (contractual necessity).
• To meet regulatory record-keeping and reporting duties (legal obligation).
• To detect and prevent platform abuse, fraud rings, and unauthorised access (legitimate interest).
• To communicate with you about your account, application, or loan (contractual necessity).

5. Who we share with

Nei Shot does not sell personal information. The platform shares data only with the following named parties, and only as needed for the purposes above:

6. Retention

Personal data is retained only for as long as necessary:

• Loan records, agreements and payment history - 7 years after the loan is closed (NAMFISA Microlending Act).
• KYC documents - 5 years after end of relationship (Financial Intelligence Act).
• Bureau pull consent - kept for the life of the active loan plus 7 years (audit trail).
• Bureau reports retrieved - 12 months from pull date.
• Audit logs - 7 years.
• Marketing preferences - until withdrawn.

7. Your rights

You have the right to:

• Ask what personal information we hold about you.
• Have inaccurate information corrected.
• Request deletion, except where law requires us to retain it (e.g. closed-loan records).
• Withdraw bureau-pull consent at any time (note: this may delay future loan applications).
• Lodge a complaint with the microlender directly, or escalate to NAMFISA (Namibia Financial Institutions Supervisory Authority) for regulatory issues, or to the relevant data-protection authority once the Namibia Data Protection Bill is enacted.

For borrower-specific requests, contact the microlender you applied with. For platform-level requests (e.g. about Nei Shot's processing) contact us at the email below.

8. Security

We protect personal information using industry-standard measures including TLS (HTTPS) in transit, encryption at rest for sensitive fields (credentials, signatures), strict role-based access, audit logging of every staff action, two-factor authentication for staff accounts, and regular security reviews. No system is 100% secure; we will notify affected microlenders without undue delay if we become aware of a breach involving personal data.

9. International transfers

Platform data is hosted on infrastructure located in supported regions. Where any sub-processor is located outside Namibia, we ensure equivalent protection through contractual safeguards. We will not transfer your data to a jurisdiction without adequate protection.

10. Cookies

The platform uses only essential cookies (session, CSRF protection, theme preference). We do not use tracking, advertising, or analytics cookies that profile you across sites. The cookie banner shown on first visit lets you confirm essential-only or accept all.

11. Changes

We may update this policy. The "Last updated" date at the top reflects the most recent change. Material changes affecting borrowers will also be notified through the relevant microlender.

12. Contact

For platform-level privacy enquiries: privacy@lendcore.neishot.com.

For complaints, see our Terms of Service for the escalation path. NAMFISA can be reached at namfisa.com.na.