Privacy Policy

Last updated: 28 September 2026

Your trust matters to us. This policy explains what personal information HIR collects when you use this website or become a customer, why we collect it, who we share it with, and the choices and rights you have.

1. Who we are

HIR Investment Limited, trading as HIR Initiatives ("HIR", "we", "us"), provides savings, loan and financing products in Nigeria. We are the data controller for the personal information described in this policy. We process personal information in line with the Nigeria Data Protection Act 2023 and regulations issued by the Nigeria Data Protection Commission (NDPC).

Our office is at Shop 63, Block B, Sangotedo Ultramodern Market, Ajah, Lagos.

2. Information we collect

Information you give us

When you request a call back: your name, phone or WhatsApp number, email address (optional), the product you are interested in and the amount you have in mind.
When you open an account: your first and last name, email address, phone number and home address.
When you save with us or apply for a loan or financing: the information needed to verify your identity and assess your application, as required by law and our product terms. This can include identification documents, your Bank Verification Number (BVN) or National Identification Number (NIN), employment or business details, income and bank account details.
When you contact us: the content of your messages and calls, whether by WhatsApp, phone, email or in person.

Information collected automatically

Campaign information: if you arrive from an advert, the campaign tags in the link (for example the source, campaign name or ad click ID). We keep these in your browser for the current visit so we know which adverts bring people to us.
Security checks: our sign-up form uses Google reCAPTCHA to protect against spam and abuse. reCAPTCHA collects hardware and software information, such as device and browser data, and sends it to Google.
Advertising and analytics: where we use measurement tools from Meta, Google or TikTok, they collect information about your visit (such as pages viewed, buttons clicked and your device) to help us measure and improve our adverts. See section 9.

Information from others

When you apply for a loan or financing, we may receive information about you from credit bureaus, identity verification services and your referees or employer, where you have agreed to this or the law allows it.

3. How we use your information

We use personal information only where we have a lawful basis to do so:

To provide our products (contract): opening and running your account, processing deposits and withdrawals, assessing loan and financing applications, disbursing funds and collecting repayments.
To meet our legal obligations: verifying your identity, preventing fraud and money laundering, keeping financial records and responding to lawful requests from regulators and authorities.
For our legitimate interests: responding to your enquiries, keeping our website and services secure, understanding which adverts work and improving our products. We balance these interests against your rights and do not use your information in ways you would not reasonably expect.
With your consent: contacting you about your enquiry by phone, WhatsApp or email, and sending you marketing messages. You can withdraw your consent at any time.

We do not sell your personal information. We share it only when needed, with:

Service providers who help us run our business, such as website hosting, IT and security providers, messaging services (including WhatsApp) and payment processors. They may use your information only to provide their services to us.
Credit bureaus and verification services, when you apply for a loan or financing, to check your identity and creditworthiness and to report on how the loan is repaid, as permitted by law.
Advertising and analytics partners (Meta, Google and TikTok), as described in section 9.
Regulators, law enforcement and courts, when the law requires it or to protect our rights, our customers or the public.
Professional advisers such as auditors and lawyers, under duties of confidentiality.
A buyer or successor, if all or part of our business is sold or reorganised, under the same protections described here.

5. Transfers outside Nigeria

Some of our service providers, such as Google and Meta, store or process information outside Nigeria. When this happens, we rely on the safeguards the Nigeria Data Protection Act 2023 requires, such as the recipient country's level of protection or contractual commitments to protect your information.

6. How long we keep it

We keep personal information only for as long as we need it for the purposes above. Call-back enquiries that do not lead to an account are deleted once they are no longer needed to respond to you. Customer records are kept for as long as you are a customer and afterwards for the period required by financial, tax and anti-money-laundering laws. When we no longer need information, we delete it or make it anonymous.

7. How we protect it

We use technical and organisational measures to protect your information, including encrypted connections (HTTPS), access controls that limit information to staff who need it, and confidentiality obligations on our staff and service providers. No system is completely secure, so please keep your login details private and tell us straight away if you think your account has been misused.

8. Your rights

Under the Nigeria Data Protection Act 2023, you have the right to:

be told how your personal information is used (this policy);
get a copy of the personal information we hold about you;
ask us to correct information that is wrong or incomplete;
ask us to delete your information, where we are not required to keep it;
ask us to restrict or stop using your information, including for direct marketing;
receive your information in a commonly used format, or have it sent to another organisation;
withdraw your consent at any time, without affecting anything we did before you withdrew it;
not be subject to a decision based solely on automated processing that significantly affects you, and to ask for a person to review it.

To use any of these rights, contact us using the details in section 12. We may need to confirm your identity first, and we will respond within the time the law allows. If you are not satisfied with our response, you can complain to the Nigeria Data Protection Commission (NDPC).

9. Cookies and similar technologies

Our website uses a small amount of storage in your browser:

Session storage to remember the advert that brought you to us while you move between our pages. It is cleared when you close the browser tab.
Local storage on the log-in page to remember the email address you last used on that device, so you don't have to retype it.
Google reCAPTCHA on the sign-up page, which may set cookies to tell people and automated programs apart. Google's Privacy Policy and Terms apply.
Advertising and analytics tags from Meta, Google and TikTok, when we switch them on for a campaign. These may set cookies to measure how many people act on our adverts, and the providers may combine this with other information they hold under their own privacy policies.

You can block or delete cookies and site storage in your browser settings. The website will still work, although some features, such as remembering your email address, may not.

10. Children

Our website and products are for people aged 18 and over. We do not knowingly collect personal information from children through this website. If you believe a child has given us their information, please contact us and we will delete it.

11. Changes to this policy

We may update this policy from time to time. The date at the top shows when it last changed. If we make significant changes, we will tell customers directly.

12. Contact us

For any question about this policy or your personal information, contact us:

Email: [email protected]
Phone: +234 816 788 0142 or +234 913 226 1929
In person or by post: Shop 63, Block B, Sangotedo Ultramodern Market, Ajah, Lagos