PRIVACY POLICY

The following Privacy Policy describes how “We”, True Pesa Tech 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.

1.Definition

2.Personal information which we collect

3.Usage of personal information which we collect

4.Sharing of personal information which we collect

5.Where we store your personal information

6.Security of your personal information

7.Your rights under data protection laws

8.Changes to this privacy policy

9.Marketing and promotional material

10.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 which we collect may be provided by you directly (for example, when you opening 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).

To better understand your identity and evaluate your credit qualifications, we need to access your following permissions and collect relevant information with your consent. Your information will be encrypted and transmitted to our server (https://tp.truepesa.co/) in a secure manner. We will not collect or share data with any third party without your consent.

COLLECTION OF SMS

Purpose of Permission: As an important part of our loan process, our app reads your SMS information. To detect, combat and prevent fraud, attempted fraud, money laundering or other illegal use of our services, we will determine your fraud risk and credit situation. You can choose to agree or deny permission, when you refuse permission will mean lack of SMS information and inability to assess your risk and credit.

Type of Data Collect: We collect all your SMS logs, which helps us identify the various accounts the user owns and the flow patterns of cash held by the user.

Security of Data: We encrypt and transmits your SMS information to our server (https://tp.truepesa.co/) using the HTTPS protocol. We promise not to share data with the third parties without your permission.

COLLECTION OF INSTALLED APP

Purpose of Permission: Ensure that you do not have apps that are not trusted by Google or virus apps installed on your phone, as these may affect the security of your money. We need to identify and analyze your risk level to process the loan and help prevent fraud.

Type of Data Collect: We collect a list of the installed applications metadata information which includes the application name, package name, installed time, updated time, version name and version code of each installed application.

Security of Data: We will upload the collected data to our server (https://tp.truepesa.co/) with high level protection. We never share data with the third parties without your permission.

COLLECTION OF LOCATION

(i)We will collect your geographic location information for customer risk assessment. (ii)We will upload location data to the True Pesa server (https://tp.truepesa.co/) with high level protection.

COLLECTION OF PHONE DEVICE

(i)We may collect some of your device information, such as hardware information (including the device's operating system, Android version, IMEI number, IMSI number, MAC address, serial number, Android ID, screen size and other hardware information), and serial number to uniquely identify the device and ensure that unauthorized devices are not to act on your behalf to prevent frauds. (ii)We will upload the collected data to the True Pesa server (https://tp.truepesa.co/) with high level protection.

Data Security

In order to assess your eligibility and facilitate faster disbursement of your loan, we need some permissions to access your sms and location etc. You can delete your account and personal information at any time by contacting our customer service center. All the data and transactions are protected by 128 SSL encryption, data will be transmitted and uploaded to our service through a secure link. Your personal information will not be disclosed without your authorization.

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 to us certain Personal Information, including your name, national id , date of birth, gender, education background, 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 to us 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 to 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 web pages 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.

Meanwhile, your 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’s 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, 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 credit risk assessment. This enables faster and quicker loan disbursal. No personal SMS data is monitored, read, stored or shared.

We collect your Geo-location information when the App is running in the foreground. We endeavour to cease 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 which 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.

3.THE USAGE OF PERSONAL INFORMATION WHICH WE COLLECT

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:

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 in 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 Law, 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 enquire and feedback received from you;

to maintain, develop, test, enhance and personal the App to meet your needs and preferences as a user;

to contact you by telephone using auto-dialed or pre-record 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 analyse 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.

4.SHARING OF PERSONAL INFORMATION WHICH WE COLLECT

where required or authored by Applicable Law (including but not limited to responding to regulatory enquire, 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.

5.WHERE WE STORE YOUR PERSONAL INFORMATION

The Personal Information that we collect from you may be stored at, transferred to, or processed by third parties service providers. We will use all reasonable endeavor to ensure that all such third parties service providers provide a level of protection that is comparable to our commitments under this Privacy Policy.

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 parties 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).

6.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 authorized 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 unauthorized 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.

7.YOUR RIGHTS UNDER DATA PROTECTION LAWS

You have rights under data protection laws in relation to your personal data. These include rights to:

Request us to correct your personal data：

This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request deletion of your personal data：

This allows you to ask us to delete or delete personal data that we have no good reason to continue processing. You also have the right to ask us to delete or delete your personal data for which you have successfully exercised your right to object to processing (see below), where we may process your information unlawfully or where we need to delete your personal data to comply with local law. Please note, however, that due to specific legal reasons, we may not always be able to honor your removal request, and if applicable, we will notify you when you request it.

Object to processing of your personal data：

Where we are relying on a legitimate interest (or those of a third parties). You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request the transfer of your personal data to you or a third parties:

We will provide you or a third parties of your choice with your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information for which you originally consented to our use or we use that information to contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent we may not be able to provide certain products or services to you. We will advise you if this is the case at such time when you withdraw your consent.

You can put your needs to us through our customer service email or online customer service, and we try to respond to all legitimate requests within one month. If your request is particularly complex or you have made multiple requests, it may sometimes take us more than a month. In this case, we will notify you and keep you informed.

8.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.

9.MARKETING AND PROMOTIONAL MATERIAL

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.

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.

10.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@truepesa.co