FLUXIS CAPITALDebtReady
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PRIVACY NOTICE · VERSION 1.1

DebtReady Privacy Notice

Effective date: 27 September 2026 · Governed by the Nigeria Data Protection Act 2023

1. Who we are

DebtReady is operated by Fluxis Capital. For the purposes of the Nigeria Data Protection Act 2023, Fluxis Capital is the data controller for the personal data you submit through this tool. Our Data Protection Officer function is provided by Accelerate Advisory Limited; you can reach the DPO through the contact form on our website and we will route your enquiry to them.

2. What we collect and why

We collect information about your business (company name, country of registration, sector, revenue and financial figures, use of funds proposed, existing debt), the directors you name for background screening, and your contact details (your name, work email, and phone number). We do not ask you for your ultimate beneficial owners at this stage. We use this information to run our automated eligibility model, draft your report, screen the named directors against sanctions and adverse-media lists, and contact you about your assessment and any next steps. Our lawful basis is your consent (given when you submit the form) for the assessment and follow-up contact, and our legitimate interests as a financial services firm for the screening we conduct on named directors.

3. Who we share it with

We use three categories of external service providers, each acting as a data processor under written terms with us: Cloudflare (site hosting and delivery), Anthropic (the large-language-model service that drafts the narrative sections of your report), and our chosen sanctions and adverse-media screening provider. We also use SendGrid to deliver the confirmation email carrying your report. Some of your data is processed outside Nigeria by these providers; we rely on the safeguards permitted under the NDPA 2023 for those transfers and full details are available on request through our DPO. We do not sell your personal data and we do not use it for advertising.

4. How long we keep it

We keep your assessment records for six years from the date of your last interaction with us, consistent with standard retention for financial services records. If your assessment does not progress to a financing conversation, you may request earlier deletion through our DPO.

5. Your rights

Under the NDPA 2023 you have the right to access the personal data we hold about you, to have inaccurate data corrected, to have your data deleted where the law allows, to receive a copy of your data in a portable format, to object to certain processing, and to withdraw the consent you gave when you submitted the form. To exercise any of these rights, contact our DPO through the website contact form. We will respond within thirty days.

6. Complaints

If you are not satisfied with how we have handled your data, please raise it with our DPO first. You also have the right to complain to the Nigeria Data Protection Commission at ndpc.gov.ng.

7. Changes to this notice

We may update this notice from time to time. The effective date at the top of this notice will always show the current version.