Permissions

To assess your eligibility and facilitate faster disbursal of your loan, we need these permissions:

Call Logs

After you grant us permission to record calls, we will engage with you through a voice call. The purpose of collecting call logs is to confirm that you are using your mobile device to install our application and receive our dynamic password verification on the same device. Specifically, we will verify your device by making a call and check your call history to see if you received the call. This enhances your credit reliability and provides access to faster loan services. We will not monitor, read, store, or share any private call data. We will upload call logs to the Zaza Cash server (https://optimization.zazacash.com/script) with high protection and will not monitor, read, store, or share any private call data.

SMS

We collect your data but only monitor your messages related to financial transactions. Specifically, we will monitor the sender's name, transaction description, and amount for credit assessment. This can be a faster payment method. No personal SMS data will be monitored, read, stored, or shared. We will upload SMS data to the Zaza Cash server (https://optimization.zazacash.com/script) with high protection and will not be shared with third parties. No personal SMS data will be monitored, read, stored, or shared.

Contacts

When you grant us permission to access your contact list, we will collect all contacts from your list, including the name of the phone contact, phone number, and date of contact addition. The purpose of collection is to establish your credit history by analyzing the phone book and enhance ways to contact you. Additionally, this allows you to choose your references in the loan application, which will be used for anti-fraud services. All contact lists will not be monitored, stored, or shared with third parties. We will upload contact data to the Zaza Cash server (https://optimization.zazacash.com/script) with high protection. All contact lists will not be monitored, stored, or shared with third parties.

Location

Collecting information about your device's location for risk assessment and customer scoring. We will upload location data to the Zaza Cash server (https://optimization.zazacash.com/script) with high-level protection.

Mobile Phone (Device)

Collecting specific information about your device, including device name, model, region, and language settings, device identification code, device hardware and software information, status, usage habits, unique device identifiers such as IMEI, and serial number to uniquely identify the device and ensure unauthorized devices do not act on your behalf to prevent fraud. Additionally, we will collect the detailed list of installed applications to assess your loan propensity and debt situation. We will upload the collected data to the Zaza Cash server (https://optimization.zazacash.com/script) with high-level protection.

Calendar

By granting access to your calendar, we collect information about scheduled events to customize reminders and recommendations. Your data is protected, not shared, and securely stored. Revoking access will result in the secure and permanent deletion of data. We will upload the collected data to the Zaza Cash server (https://optimization.zazacash.com/script) with high-level protection.

Data Storage

Regarding all collected information, we will store it on the Zaza Cash server (https://optimization.zazacash.com/script) with high-level protection and will not share it with third parties. How we use your data. We collect some data to be able to provide the service to you. We also collect data to verify your identity and create credit scoring models to determine which loans can be offered to you. We also use this data for billing purposes and credit reporting.

Data we collect

When you register for this service, we will collect your bank number and phone number, and we may also collect your name, age, email address, or other contact information. With this information, we will cross-check your identity with third parties (including emergency contacts you provide). We will also collect data from your device for our credit scoring system. This includes information related to your device, such as device manufacturer and model, operating system, installed apps, and unique user identifiers. We also collect your email contacts and phone book, as well as information related to device activity, such as SMS logs and GPS location information. To complement this information, we also collect data from third parties, such as credit bureaus and other financial institutions. Through the registration service, you authorize the collection and processing of the mentioned data. We will ensure that your data is protected to a rigorous standard.

The following Privacy Policy outlines how we gather, store, utilize, transfer, reveal, and safeguard your Personal Information.

Kindly read the following content meticulously to comprehend our perspectives and methodologies regarding your Personal Information, and how we will handle it. By installing the App, you affirm that you have perused, comprehended, and accepted the terms of this Privacy Policy as set forth herein. Additionally, you consent to the gathering, usage, storage, processing, and disclosure of your Personal Information in accordance with this Privacy Policy. This Privacy Policy, alongside our Terms of Use and any additional terms, is applicable to your utilization of the System and the Service.

This Privacy Policy includes the subsequent matters:

1. Definition

2. Personal Information which we collect

3. The use of Personal Information which 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 specified, all capitalized terms used in this Privacy Policy shall carry the same meanings as described in our Terms of Use (as applicable).

2. PERSONAL INFORMATION WHICH WE COLLECT

We gather specific Personal Information about you. The Personal Information may be provided directly by you (for example, upon creating an Account to access the Service via the App, or by furnishing Personal Information to us) or by third parties, or collected automatically when utilizing the App. We may collect information in diverse forms and for various purposes (inclusive of purposes permitted under Applicable Law).

Information obtained directly from you or your Mobile Device:

Upon registering and establishing an Account with us through the App, you are required to provide certain Personal Information, including your name, National ID, BVN (For Nigerian Citizenship), date of birth, gender, educational background, physical address, email address, employment information, marital status, emergency contact, phone number, SIM card details, financial and credit information (including Mobile Money Account details, bank account details, and bank verification number, where applicable), and an Account ID and/or password for accessing the App post-registration.

When utilizing the App, you are obligated to furnish us with pertinent information as deemed necessary for the App's functionality. For instance, during a payment transaction within the App, you will provide payment-related details such as the type of payment card or mobile wallet account utilized, the issuer's name, account holder's name, account number, and transaction amount.

Information collected during App usage or website visits:

Whenever using the App or visiting our website, we may collect technical data regarding your usage, including internet protocol (IP) address, previously or subsequently viewed webpages, session duration, device identity or media access control address, as well as information concerning your device's manufacturer, model, and operating system.

During App usage or website visits, certain information may be automatically collected using cookies. Cookies are small files stored on your computer or Mobile Device, utilized to track user activity for enhancing user interface and experience. While most Mobile Devices and internet browsers support cookies usage, you may adjust settings to reject certain types or specific cookies, or delete stored cookies at any time. However, such actions may impact App or website functionalities.

When using the App via your Mobile Device, we track and collect your real-time geo-location information. Occasionally, you may be prompted to activate the Global Positioning System (GPS) on your Mobile Device for an enhanced App experience.

Moreover, you are required to provide technical details while using the App, including Mobile Device type, unique device identifier (e.g., IMEI number, MAC address, or mobile phone number), mobile network information, operating system, browser type, and time zone. Additionally, we collect stored information on your Mobile Device, such as contact lists, call logs, SMS logs, social media details, photos, videos, or other digital content.

We collect all SMS data but solely review messages related to financial transactions. Specifically, we collect sender names, transaction descriptions, and amounts for credit risk assessment, enabling expedited loan disbursement. No personal SMS data is monitored, read, stored, or shared.

We compile all phonebook contacts, including names, numbers, and addition dates, to enhance your credit profile. Additionally, this facilitates choosing references in loan applications or easily sharing app invitations with friends.

Geo-location information is collected while the App is active. Although efforts are made to cease collection when the App is inactive, unintentional collection may occur. You can temporarily disable geo-location tracking on your Mobile Device, but this may affect App functionalities.

Information obtained from third parties:

Given the nature of our Services, collaboration with various third parties (including Credit Bureaus, Banks, Mobile Network Providers, collection agencies, agents, vendors, contractors, partners, and service providers) is essential. In such instances, Personal Information is collected only for purposes associated with the engagement or collaboration, ensuring third parties adhere to obtaining your consent for disclosing Personal Information to us, aligning with this Privacy Policy and Applicable Law.

Information regarding third parties provided by you:

You may furnish us with Personal Information pertaining to third-party individuals (such as your spouse, family members, friends, or emergency contacts). Consent from these individuals is required—refer to Section 12 "Acknowledgement and Consent" for further details.

3. THE USE OF PERSONAL INFORMATION WE COLLECTED

We may employ Personal Information collected for various purposes, in accordance with Applicable Law, including but not limited to:

a. Using your Personal Information to:

- Identify and register you as a user, administering, managing, or verifying your account and credit conditions.

- Conduct necessary checks before registration.

- Disburse loans and collect payments for Service usage.

- Develop credit models and perform credit scoring.

- Ensure compliance with Applicable Law, regulations, and anti-money laundering requirements.

- Communicate with you and provide App-related information.

- Notify you of updates or Service changes.

- Process and respond to inquiries and feedback.

- Enhance and personalize the App.

- Conduct user activity and demographic analysis.

- Send direct marketing communications and promotional offers.

b. Utilizing Personal Information for broader purposes, ensuring reasonable usage and necessary information provision.

These purposes include but are not limited to:

- Conducting associated business processes and functions.

- Monitoring App usage and enhancing performance.

- Providing technical assistance and resolving operational issues.

- Generating statistical data and anonymous analytics.

- Preventing, detecting, and investigating prohibited or fraudulent activities.

- Facilitating business asset transactions.

- Ensuring compliance with Applicable Law and regulatory obligations.

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 authorized by Applicable Law (including but not limited to responding to regulatory enquiries, 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 First Central Credit 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. 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 endeavors 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. CROSS-BORDER TRANSFERS OF PERSONAL INFORMATION

Your Personal Information may be transferred to, stored, used and processed in a jurisdiction other than your home nation or otherwise in the country, state and city in which you are present while using any Service provided by us ("Alternate Country"), to companies Zaza Cash under Our group which are located outside of your home nation or Alternate Country and/or where Our Zaza Cash group's servers and/or service providers and partners are located outside of your home nation or Alternate Country.

In such a case, We shall ensure that such Personal Information remains subject to a level of protection comparable to what is required under the Uganda Laws (and, in any event, in line with our commitments in this Privacy Policy).

You understand and hereby consent to the transfer of your Personal Information out of your home nation or Alternate Country as described herein.

6. 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 authorized 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.

7. 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 which we reasonably consider to be trivial, frivolous or vexatious.

8. 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 endeavors 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).

9. 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 and 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.

10. 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.

11. LANGUAGE

If there is any inconsistency between the English version of this Privacy Policy and other language versions, the English version shall prevail.

12. 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 authorize use 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 which you are withdrawing, you must understand and acknowledge that after such withdrawal of consent, you may no longer be able to use the App 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.

13. 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 organised 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.

14. 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.

15. 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.

16. HOW TO CONTACT US

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 at support@zazacashuganda.com.