PRIVACY POLICY
This Privacy Policy describes how " AJAX AIR LIMITED " collects, uses, shares, discloses and protects your Personal Information. By using the Services, you agree to the privacy practices described in this policy.
This Privacy Policy is incorporated into and subject to the Terms and Conditions. Capitalized terms not defined in the Privacy Policy have the meanings given to them in the Terms and Conditions.
USER CONSENT
By creating an Account and using our service, you expressly consent to and acknowledge KupaLoan’s collection, maintenance, use, processing and disclosure of your Sensitive Personal Data or other Information and Information in accordance with the terms and conditions set forth in this Privacy Policy. If you do not agree to this Privacy Policy in its entirety, you should not use this application or the products and/or services provided through it. If you have any questions or comments about this Privacy Policy, please contact us for details.
PERSONAL DATA PROVIDED DURING INTERACTIONS
1. Basic personal information:
Including name, gender, date of birth, etc.
2. Professional information :
Including type of work and monthly income
3. Contact details:
Data selected or filled in by the user from the address book, including the relationship to the contact, the contact's name, and the contact number.
4. Payment information:
Including payment account details provided by the user themselves and the account details used for payment.
5. Document information (If necessary):
A valid government-issued photo ID that verifies the user's identity.
6. Facial information:
User's personal selfie
The above shared information is an essential basis for the review of your loan application. This information will be stored securely on our server and will not be shared with third parties. You can also choose to delete your personal user data. Your facial information will be encrypted and sent to https://www.odohonline.info . After analysis, we will permanently delete the SMS data. We will not share your SMS data with third parties.
DATA COLLECTED FROM DEVICES
During your use of the Mobile App, we will collect such Information from you as you provide it to us including, but not limited to, the following: Sensitive Personal Data or Personal Information/Information that you provide to us when you contact us such as.
A.SMS
What information do we collect?
a. After obtaining your authorization for SMS access, we only collect financial-related data from SMS messages.(This data includes: SMS message content, sender, recipient, and time of sending and receiving.)
b. We use keyword filtering and sent to https://www.odohonline.info . After analysis, we will permanently delete the SMS data. Ensure that no non-financial SMS data is collected or uploaded.
c. KupaLoan will not read and collect your SMS data when the app is closed or not in use.
Why do we request your device's SMS data?
We analyze financial data in user SMS messages to assess their debt, financial status, and financial activities, thereby assessing their credit and financial status. This serves as a crucial source of information for our anti-fraud and credit assessment efforts.
Data security
a. a.SMS data of users is filtered by keywords, and we only collect data related to financial activities. We do not collect private information.
b. We will fully disclose and declare SMS data to users before collecting SMS data, and we will collect SMS data only after users have authorized SMS permissions
c. Your SMS data will be encrypted and sent to https://www.odohonline.info . After analysis, we will permanently delete the SMS data. We will not share your SMS data with third parties.
B. DEVICE INFORMATION
To maintain security and prevent fraudulent activity, KupaLoan requires access to your nationwide mobile network connection. This allows us to verify the authenticity of the device and protect your account from unauthorized access.
We collect important device specifications including:
Hardware details (model, operating system version, screen dimensions, system language)
Performance measurements (RAM capacity, storage space)
Unique identifiers (serial number, SSAID)
Network connection information (Wi-Fi status, mobile network information)
This carefully curated small data set enables us to:
• Improve your loan evaluation process
• Develop appropriate risk assessment models
• Maintain the highest levels of security for your transactions
All information collected remains strictly confidential and is used only for these authorized purposes.
C. CONNECTED NETWORK APP INFOMATION
What data we will collect
We will collect information about network-connected applications on user devices, including a list of applications that obtain INTERNET permissions, a list of applications that obtain ACCESS_NETWORK_STATE permissions, and the names, package names, versions, and other information of the applications in the list.
Why we request ?
We collect information about apps that obtain specific permissions on user devices. This information is intended to help us identify apps that are used to damage applications and potentially for anonymization and fraud, using the principle of least privilege. (For example, Fake GPS: fake location Super Clone: cloning software)
Data safety
a. We use the official and secure PackageManager API interface provided by Android and only used to identify third-party, non-system apps on the device that have been granted specific permissions (INTERNET, ACCESS_NETWORK_STATE). This feature is used for risk management and device environment assessment and does not involve user privacy or behavioral analysis.
b. The retrieved app list data will be GZIP compressed (using the gzipString() method) and encrypted for transmission to https://www.odohonline.info and ensure data security.
c. KupaLoan will never share your data with any third party. Data collection will only occur with your consent.
D. CAMERA
When you verify your identity, we will ask you to take a selfie using your device's camera. We will upload your selfie to our server for identity verification.
We will only ask you to take a selfie using the camera when verifying your identity. We will also only upload the selfie you have verified to our https://www.odohonline.info server after encryption. Your data will be protected and kept confidential.
E.STORAGE
To facilitate your loan application, we request access to your device storage for uploading required images/documents only. Important protections:
(1)Controlled Access
Only enabled with your explicit permission
It is limited to uploading application-related files.
(2)Advanced Protection
All data is encrypted end-to-end
It is transmitted securely via HTTPS to: https://www.odohonline.info
(3)Top Secret
Files are stored on dedicated member servers
Complete non-disclosure to third parties
Immediate cleaning upon request
F. CONTACTS IN YOUR ADDRESS BOOK
We collect the contacts you select from your phone book, including the name of the contact person and phone number. The information above will help you select emergency contacts in your loan application and allow us to contact them when necessary to prevent fraud and monitor debt collection. This will allow us to better assess your credit status and manage our identity risks and loan portfolio management. We will upload your contact information to the KupaLoan server ( https://www.odohonline.info ), and your data will be protected and kept strictly confidential.
G.PHOTO ALBUM
We will collect the photos you select in a photo album, which will help you select matching ID photos to upload to your loan application. This will allow us to better assess your credit risk profile. We will upload your contact information to the KupaLoan server ( https://www.odohonline.info ), and your data will be protected and kept strictly confidential.
COLLECTION OF USER BEHAVIOR DATA
We only collect data related to your interactions within the app, such as screen clicks, browsing behavior, app launches and closures. This information pertains to service-related activities only and is necessary to help us analyze user patterns, improve app performance, detect potential issues, and improve the overall user experience.
To protect your privacy, all collected behavioral data is anonymized and securely encrypted before storage or processing. This ensures that the data cannot be traced back to you personally. We do not—and never will—sell, rent, or share this data with third parties under any circumstances. Your trust and data security are our top priorities.
INFORMATION WE COLLECT AUTOMATICALLY
There is certain Information that we collect automatically from your use of the App. This information includes but is not limited to: The Internet Protocol (IP) address of the device from which you access the App.
INFORMATION FROM OTHER SOURCES
KupaLoan allows you to sign up and log in using your Google account. If you sign up using Google, Google will ask you for permission to share certain information from your Google account with KupaLoan . This includes information about you, such as your email address. This information is collected by Google and provided to us under the terms of Google’s privacy policy.
How we share, transfer and publicly disclose your personal information
where required or authorized by Applicable Law (including but not limited to responding to regulatory inquiries, investigations or orders, or complying with statutory or legal filing and reporting requirements), for the purposes set out in such Applicable Law;
where there is any form of legal proceeding between you and us, or between you and another party, in connection with, or in connection with the Services, for the purposes of such legal proceeding;
in connection with, or during negotiations for, any merger, sale of corporate assets, consolidation or restructuring, financing or acquisition of all or a portion of our business with or into another company, for the purpose of such transaction (even if the transaction is not consummated);
where we share your Personal Information with third parties (including Credit Reference Bureaus, Banks, Mobile Network Service Providers, collection agencies, our agents, vendors, suppliers, contractors, partners and any others who provide services to us, work on our behalf, or with whom we collaborate), for or in connection with the purposes for which the third parties are engaged or the purposes of the third parties, which may include such cases with third parties to identify you or provide products or services to you, or other activities conducted including marketing, research, analysis and product development;
Where we share Personal Information with Affiliates, we will do so solely for the purposes of them helping us provide the Software or operate our business (including, where you have subscribed to our email list, for direct marketing purposes), or for the purposes of them carrying out 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 they receive from us in accordance with this Privacy Policy and Applicable Law;
where we publish statistics relating to the use of the Software and Services, where all information will be aggregated and anonymized; 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 investigate violations of our Terms and Conditions;
2. Where it is not necessary for Personal Information to be disclosed or shared with third parties to be associated with you, we will use reasonable efforts to remove the means by which Personal Information can be associated with you as an individual before disclosing or sharing such information.
3. Except as set forth in this Privacy Policy, we may disclose or share your Personal Information if we notify you in advance and we have obtained your consent for the disclosure or sharing.
How We Use Your Personal Information
1. Your information is used to improve our services and enhance your interaction with Sunlit Loans. It enables us to:
a. To deliver, enhance, protect, analyze, bill for and provide support for our products and services.
b. Communicate important information about your services, products or programs.
c. Advertise our products and services.
d. Make research plans.
e. Detect and prevent fraudulent activities.
f. Make promotional efforts.
j. Make research plans.
2. Therefore, we are authorized :
a. Maintain records of the products and services you use or order.
b. Provide product or service information (such as order confirmations and service-related notifications).
c. Facilitate the creation and access of online accounts managed by us.
d. Charge fees and ensure that you receive your payment without any complications.
e. Distribute information to others (if required by the products or services you have ordered), or send it to another communications service provider if you purchase specific services from them and us.
3. The information collected will be used to evaluate the provision of financial services or products to customers, assess the associated risks, and set relevant terms and conditions for the said services or products.
4. We may engage a third - party payment service provider or payment processing company to facilitate payment processing, transfer funds to operating or user accounts, manage payments, and provide additional products and services. Accordingly, your information may be disclosed to such third-party payment service providers.
5. When you purchase products or services from us, subscribe to our newsletters, respond to surveys or marketing communications, browse our website or KupaLoan , or register for an online account, the information collected may be used in the following ways :
a. Personalize your experience to suit your preferences.
b. Requesting ratings and reviews of services or products.
c. Administering contests, promotions, surveys and website features.
d. Improve the performance of our website/app to better serve you.
e. Facilitate follow-up after communication (live chat, email, or phone inquiries).
f. Improve our ability to meet your customer service needs.
6. Additionally, we rely on the following information to deliver products, services, and manage your account :
a. Your contact details and other information necessary for verifying your identity and for the purpose of communication. This includes your personal data and relevant documents.
b. Your payment and financial data.
c. Records of your communications with us, including emails, web chats and telephone calls. In addition, your communication settings and preferences will be recorded.
d. We may need information from cookies placed on your connected device to enable the provision of our services.
7. If we have a good faith belief that disclosure is necessary for the enforcement of any of the terms and conditions set forth, or this Policy, or to assist in the prevention, detection, investigation, or prosecution of criminal or fraudulent activity, we may disclose your personal information to domestic or international law enforcement agencies, government regulatory agencies, or government agencies.
8. We will use your data to aggregate statistical insights related to our user base, financial products or services. This aggregated insights may be disclosed to third parties for analytical purposes, with the assurance that such data will remain anonymous.
Access and Correction of Personal Information
We will retain your personal information for as long as necessary to fulfill the purposes set out in this Privacy Policy or as permitted by applicable law.
Where We Store Your Personal Information
1. Personal Information collected from you may be stored, transferred or processed by third party service providers. We are committed to taking all reasonable steps to ensure that these third party service providers comply with the level of protection consistent with our commitments set out in this Privacy Policy .
2. In addition, your Personal Information may be stored or processed outside your country, either by our employees located in another country or by our other service providers, distributors, contractors, or Affiliates. This will be done to the extent permitted by applicable law. In such cases, we ensure that your Personal Information will continue to be subject to a level of protection equivalent to the requirements set out under the laws of your country. This assurance is consistent with the commitments set out in this Privacy Policy.
3. The Apps and Websites may contain links to websites operated by third parties. We have no control over and are not responsible for these websites or the data collection, use, maintenance, sharing or disclosure practices of such third parties. Please refer to the terms and conditions, and privacy policies of these third party websites to understand how they collect and use your Personal Information.
Children's Privacy
Our Service does not address anyone under the age of 18 . We do not knowingly collect personally identifiable information from anyone under the age of 18 . If You are a parent or guardian and You are aware that Your Child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 18 without verification of parental consent, We take steps to remove that information from Our servers. If You believe that We may have information from or about anyone under the age of 18 , please contact Us using the details provided in the 'Contact Us' section below.
If We need to rely on consent as a legal basis for processing Your information and your country requires parental consent, We may require your parent's consent before We collect and use that information.
7. Changes to this Privacy Policy
We reserve the right to update this Privacy Policy from time to time. Any changes will be communicated by posting the revised policy on the App.
Third Party Websites
1. The Apps and Websites may contain links to websites operated by third parties. We have no control over and are not responsible for these websites or the data collection, use, maintenance, sharing or disclosure practices of such third parties. Please refer to the terms and conditions, and privacy policies of these third-party websites to understand how they collect and use your Personal Information.
2. Advertisements on our App or Website act as links to the advertiser's website. Therefore, any data collected when you click on these links will be subject to collection and use by the relevant advertiser, as set out in their privacy policy .
Liability and Limitation
Our liability for any breach of this Privacy Policy is limited to the extent permitted by law.
Confirmation and Approval
By using the App, you confirm that you have read and understood this Privacy Policy. You hereby consent to the collection, use, and disclosure of your personal information as set forth herein.
Contact Us
If you have any comments, questions or concerns, please email
Company Name: AJAX AIR LIMITED
Phone number : +263 0783332021
Email: Kupajbbwservice@outlook.com
Address: 943V+H9M, Gutu, Zimbabwe