To assess your eligibility and facilitate faster
Disbursal of your loan, we need these permissions
1. SMS
We collect all your SMS data but only monitor your messages related to financial transactions. To be specific, we will monitor the name of the sender, the description, and the amount of transactions to perform credit risk assessment. This enables faster and quicker loan disbursal. No personal SMS data is
monitored, read, stored, or shared. We will upload and transmit SMS data to the Company server with high-level protection and will not be shared with any third party.
2. Location
Collect and monitor information about the location of your device for customer risk assessment and scoring. We will upload location data to the Company server with high-level protection.
3. Mobile Phone (Device)
Collect and monitor specific information about your device including your device name, model, region and language settings, device identification code, device hardware and software information, status, usage habits, and unique device identifiers like IMEI and serial number to uniquely identify the device and
ensure that unauthorized devices are not to act on your behalf to prevent frauds. In addition, we will collect your installed application detailed list to assess your borrowing propensity and your debt situation. We will upload the collected data to the server with high-level protection.
4. Data Storage
Regarding all the collected information, we will store it on the Company server with high-level protection
and will not be shared with any third party.
5. Call Logs
After you have authorized the call logs authority to us, we will make a call to you through voice call. The reason for collecting the call record is to be able to confirm that you are using your own mobile phone to install our application and receive our dynamic password verification on the same machine. Specifically,
we will verify your device by dialing the phone, Check your call log to see if you have received a call. This makes your credit more reliable and get faster loan service. We will not monitor, read, store or share any private call data.
How do we use your data?
We collect certain data to be able to provide the Service to you. We also collect data for use in verifying your identity and creating credit scoring models to determine what Loans can be offered to you. We also use this data for purposes of collections and credit reporting.
The data we collect
When you register for the Service, we will collect your M-Pesa number and telephone number and may also collect your name, age, email address, or other contact information. With this information, we cross-check your identity with third parties including the person you have provided as your emergency contact.
We will also collect data from your device for our credit scoring system. This includes information relating to your device, such as device maker and model, operating system, installed software applications, and the unique user identifier. We also collect your email and phone book contacts and information related to device activity such as SMS logs and GPS location information. To supplement this information, we also collect data from third parties such as credit bureaus and other financial institutions. By registering for the Service, you authorize the collection and processing of the foregoing
data. We will ensure that your data is protected to a strict standard.
The following Privacy Policy describes how the Company and its Affiliates, collect, store, use, transfer,
disclose, and protect your Personal Information.
Please read the following carefully to understand our views and practices regarding your Personal Information and how we will treat it. By downloading the App, you confirm that you have read, understood, and accept the terms of this Privacy Policy set out hereunder. You also consent to the collection,use,storage,processing, and disclosure of your Personal Information in the manner set out in this Privacy Policy. This Privacy Policy together with our Terms of Use and any additional terms applies to your use of the System and the Service.
This Privacy Policy includes the following matters:
1. Definition
2. Personal Information which we collect
3. The use of Personal Information that we collect
4. Sharing of Personal Information which we collect
5. Cross-border transfers of Personal Information
6. Retention of Personal Information
7. Access and correction of Personal Information
8. Where we store your Personal Information
9. Security of your Personal Information
10. Changes to this Privacy Policy
11. Language
12. Acknowledgement and consent
13. Marketing and promotional material
14. Third party websites
15. How to contact us
1. DEFINITION
Unless otherwise defined, all capitalized terms used in this Privacy Policy shall have the same meanings ascribed to them in our Terms of Use (as applicable).
2. PERSONAL INFORMATION WHICH WE COLLECT
We collect certain Personal Information about you. The Personal Information that we collect may be provided by you directly (for example, when you open an Account to use the Service via App, or you otherwise provide Personal Information to us) or by third parties, 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 us with certain Personal Information, including your name, BVN, date of birth, gender, educational background, religion, photo, physical address, e-mail address, working information, marital status, emergence contact, your
phone number, SIM card details, financial and credit information (including your Mobile Money Account details, bank account details, and bank verification number, where applicable) and an Account ID and/or password that you will use to access the App after registration. When you use the App, you have to provide us with such relevant information as may reasonably be required by us in order for the App to work. For example, when a payment is made through the electronic
money facility within the App, you will provide us information relating to the payment, such as the type of payment card or mobile wallet account used, the name of the issuer of that payment card or mobile wallet account, the name of the account holder for that payment card or mobile wallet account, the
number of that payment card or mobile wallet account, and the amount of money paid. Information collected whenever you use the App or visit our Website:
Whenever you use the App or visit our Website, 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 or our Website.
Whenever you use the App or visit our Website, 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. Whenever you use the App through your Mobile Device, we will track and collect your geo-location information in real-time. In some cases, you will be prompted or required to activate the Global Positioning System (GPS) on your Mobile Device to enable us to give you a better experience in using the App.
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 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. We collect all your SMS data but only monitor your messages related to financial transactions. To be specific, we will monitor the name of the sender, the description, and the amount of transaction to perform a credit risk assessment. This enables faster and quicker loan disbursal. No personal SMS data is monitored, read, stored, or shared.
We gather all your phonebook contacts which includes their phone contact names, phone numbers, and contact added dates to augment your credit profile, Additionally, this can allow you to choose your references in the loan application or share our app invitation with your friends easily.
We collect your geo-location information when the App is running in the foreground. We endeavour to cease the 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.
Information collected from third parties:
Due to the nature of the Services that 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.
3. THE USE OF PERSONAL INFORMATION THAT WE HAVE COLLECTED
We may use Personal Information collected for any of the following purposes as well as for such other
purposes as are permitted by Applicable Law:
a. We may use your Personal Information:
to identify you and to register you as a user and to administer, manage, or verify your Account and your
credit conditions as such; to facilitate or enable any checks as we may at our discretion consider necessary before we register you as
a user; to disburse Loan and collect payments for your use of the Service; to build credit models and perform credit scoring;
to comply with Applicable Laws, regulations, and rules, such as those relating to “know-your-customer” and anti-money laundering requirements;
to communicate with you and to send you information in connection with the use of the App; to notify you of any updates to the App or changes to the Service (including interest rate, Transaction Fees, etc.) available; to process and respond to inquiries and feedback received from you;
to maintain, develop, test, enhance, and personalize the App to meet your needs and preferences as a user;
to contact you by telephone using auto-dialed or pre-recorded message calls or text (SMS) messages (if applicable) as authorized for the purposes described in this Privacy Policy and the Terms of Use; to monitor and analyze user activities and demographic data including trends and usage of the Service
available on the App; and to send you direct marketing communications and information on special offers or promotions.
b. We may also use your Personal Information more generally for the following purposes (although we will in each such case always act reasonably and use no more Personal Information than what is required for the particular purpose): to undertake associated business processes and functions;to monitor the usage of the App and administer, support, and improve the performance efficiency, user experience, and functions of the App; to provide assistance in relation to and to resolve any technical difficulties or operational problems with the App;
to generate statistical information and anonymous analytics data for the purpose of testing, research, analysis, and product development; to prevent, detect, and investigate any prohibited, illegal, unauthorised, or fraudulent activities; to facilitate business asset transactions (which may extend to any mergers, acquisitions, or asset sales) involving us and/or any of our Affiliates; and to enable us to comply with our obligations under any Applicable Law (including but not limited to
responding to regulatory inquiries, investigations, or directives) and conducting audit checks, due diligence, and investigations.
4. SHARING OF PERSONAL INFORMATION WHICH WE COLLECT
a. We may disclose to or share with Affiliates and other parties your Personal Information for any of the
following purposes as well as for such other purposes as are permitted by Applicable Law (although we
will in each such case always act reasonably and disclose or share no more Personal Information than
what is required for the particular purpose):
where required or authorised by Applicable Law (including but not limited to responding to regulatory
inquiries, investigations, or directives, or complying with statutory or regulatory filing and reporting
requirements), for the purpose so specified in that Applicable Law;
where there is any form of legal proceeding between you and us, or between you and another party, in
connection with, or relating to the Service, for the purposes of that legal proceeding;
in connection with, or during negotiations of, any merger, sale of company assets, consolidation or
restructuring, financing or acquisition of all or a portion of our business by or into another company, for
the purposes of such a transaction (even if the transaction is eventually not proceeded with);
where we share your Personal Information with 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), 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), which may include allowing such third parties
to introduce or offer products or services to you, or other conducting activities including marketing,
research, analysis and product development;
where we share Personal Information with Affiliates, we will only do so for the purpose of them helping
us to provide the App or to operate our business (including, where you have subscribed to our mailing
list, for direct marketing purposes), or for the purpose of them conducting data processing on our behalf.
For example, our Affiliate in another country may process and/or store your Personal Information on
behalf of our group company in your country. All of our Affiliates are committed to processing the
Personal Information that they receive from us in line with this Privacy Policy and Applicable Law;
where we publish statistics relating to the use of the App and the Service, in which case all information
will be aggregated and made anonymous; and
when we believe in good faith that disclosure of your Personal Information is necessary to comply with
Applicable Law, prevent physical harm or financial loss, report suspected illegal activity, or to investigate
violations of our Terms of Use;
b. Where it is not necessary for the Personal Information disclosed or shared with other parties to be
associated with you, we will use reasonable endeavours to remove the means by which the Personal
Information can be associated with you as an individual before disclosing or sharing such information.
c. Other than as provided for in this Privacy Policy, we may disclose or share your Personal Information if
we notify you of this in advance and we have obtained your consent for the disclosure or sharing.
5. RETENTION OF PERSONAL INFORMATION
Your Personal Information will only be held for as long as it is necessary to fulfill the purpose for which
it was collected, or for as long as such retention is required or authorised by Applicable Law. We shall
cease to retain Personal Information or remove the means by which the Personal Information can be
associated with you as an individual, as soon as it is reasonable to assume that the purpose for which that
Personal Information was collected is no longer being served by retention of Personal Information and
retention is no longer necessary for legal or business purposes.
6. ACCESS AND UPDATE/CORRECTION OF PERSONAL INFORMATION
a. You may request us for access to and/or the correction of your Personal Information in our possession
and control, by contacting us at the details provided below. Subject to Applicable Law, we reserve the
right to charge an administrative fee for such requests.
b. We reserve the right to refuse your requests for access to, or to correct, some or all of your Personal
Information in our possession or control if permitted or required under any Applicable Law. This may
include circumstances where the Personal Information may contain references to other individuals or
where the request for access or request to correct is for reasons that we reasonably consider to be trivial,
frivolous, or vexatious.
7. WHERE WE STORE YOUR PERSONAL INFORMATION
a. The Personal Information that we collect from you may be stored at, transferred to, or processed by
third-party service providers. We will use all reasonable endeavours to ensure that all such third-party
service providers provide a level of protection that is comparable to our commitments under this Privacy
Policy.
b. Your Personal Information may also be stored or processed outside of your country by personnel who
work for us in other countries, or by our third-party service providers, suppliers, contractors, or Affiliates,
to the extent permitted under Applicable law. In such a case, we will ensure that such Personal
Information remains subject to a level of protection comparable to what is required under the laws of your
country (and, in any event, in line with our commitments in this Privacy Policy).
8. SECURITY OF YOUR PERSONAL INFORMATION
Confidentiality of your Personal Information is of utmost importance to us. We will use all reasonable
efforts to protect and secure your Personal Information against access, collection, use, or disclosure by
unauthorised persons and against unlawful processing, accidental loss, destruction, damage, or similar
risks. Unfortunately, the transmission of information via the Internet is not completely secure. Although
we will do our best to protect your Personal Information, you acknowledge that we cannot guarantee the
integrity and accuracy of any Personal Information which you transmit over the Internet, nor guarantee
that such Personal Information would not be intercepted, accessed, disclosed, altered or destroyed by
unauthorised third parties<, due to factors beyond our control. You are responsible for keeping your
Account details confidential and you must not share your password with anyone and you must always
maintain the security of the Mobile Device that you use.
9. CHANGES TO THIS PRIVACY POLICY
We may review and amend this Privacy Policy at our sole discretion from time to time, to ensure that it is
consistent with our future developments, and/or changes in legal or regulatory requirements. If we decide
to amend this Privacy Policy, we will notify you of any such amendments by means of a general notice
published on the App and/or Website, or otherwise to your e-mail address set out in your Account. You
agree that it is your responsibility to review this Privacy Policy regularly for the latest information on our
data processing and data protection practices and that your continued use of the App or Website,
communications with us, or access to and use of the Service following any amendments to this Privacy
Policy will constitute your acceptance to the amendments.
10. LANGUAGE
If there is any inconsistency between the English version of this Privacy Policy and other language
versions, the English version shall prevail.
11. ACKNOWLEDGEMENT AND CONSENT
a. By accepting the Privacy Policy, you acknowledge that you have read and understood this Privacy Policy and you accept all of its terms. In particular, you agree and consent to us collecting, using, disclosing, storing, transferring, or otherwise processing your Personal Information in accordance with this Privacy Policy.
b. In circumstances where you provide us with Personal Information relating to other individuals (such as Personal Information relating to your spouse, family members, friends, or emergency contact), you represent and warrant that you have obtained such individual’s consent for, and hereby consent on behalf
of such individual to, the collection, use, disclosure, and processing of his/her Personal Information by us.
c. You also consent and expressly authorise us to contact you and your emergency contact who has expressly agreed upon it, to verify your information or when we are unable to contact you via other methods or when we have not received your payment in connection with Loan.
d. You may withdraw your consent to any or all collection, use, or disclosure of your Personal Information at any time by giving us reasonable notice in writing using the contact details stated below.
You may also withdraw your consent for us to send you certain communications and information via any “opt-out” or “unsubscribe” facility contained in our messages to you. Depending on the circumstances and the nature of the consent that you are withdrawing, you must understand and acknowledge that after
such withdrawal of consent, you may no longer be able to use the Application or certain of the Service. A withdrawal of consent by you may result in the termination of your Account or of your contractual relationship with us, with all accrued rights and obligations remaining fully reserved. Upon receipt of
your notice to withdraw consent for any collection, use, or disclosure of your Personal Information, we will inform you of the likely consequences of such withdrawal so that you can decide if indeed you wish to withdraw consent.
12. MARKETING AND PROMOTIONAL MATERIAL
a. We may send you marketing and promotional communications via post, telephone call, short message
service (SMS), e-mail, online messaging, or push notifications via the App to notify you about special
privileges, promotions, or events offered or organized by us, our partners, sponsors, or advertisers, or to
provide updates on our App and/or the products and services offered therein.
b. You may opt out from receiving such marketing communications at any time by clicking on any
“unsubscribe” facility embedded in the relevant message or otherwise contacting us using the contact
details stated below. Please note that if you opt-out, we may still send you non-promotional messages,
such as Loan disbursement or repayment receipts, or information about your Account or the App.
13. THIRD PARTY WEBSITES
a. The App and Website may contain links to websites that are operated by third parties. We do not
control nor accept liability or responsibility for these websites and for the collection, use, maintenance,
sharing, or disclosure of data and information by such third parties. Please consult the terms and
conditions and privacy policies of those third-party websites to find out how they collect and use your
Personal Information.
b. Advertisements contained on our App or Website operate as links to the advertiser’s website and as
such any information they collect by virtue of your clicking on that link will be collected and used by the
relevant advertiser in accordance with the privacy policy of that advertiser.
14. LIMITATION OF LIABILITY
We shall not be liable for any indirect, incidental, consequential, special, exemplary, or punitive damages
arising out of:
a. Your use of or reliance on the App or your inability to access or use the App; or
b. Any transaction or relationship between you and any other third party, even if we have been advised of
the possibility of such damages.
We shall not be liable for delay or failure in performance resulting from causes beyond our reasonable
control.
15. HOW TO CONTACT US
You might be called by our agents or receive SMS reminders from time to time about pending overdue loans. If you have any questions regarding this Privacy Policy or you would like to obtain access and/or make corrections to your Personal Information, please contact our Data Protection Officer will be available.