PRIVACY POLICY

This Privacy Policy ("Policy") has been drafted in accordance with the Information Technology Act 2000 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules 2011.

By accessing this HakiMoney mobile application ("App") (collectively, the "Platform") and using the services we provide ("Services"), you agree to be bound by the terms and conditions of this Privacy Policy.

Upon acceptance, this policy constitutes a legal agreement between you (as the user of the platform) and HakiMoney (as the owner of the platform).

This policy describes our policies and procedures for the collection, use, storage, processing, disclosure and protection of any information, including but not limited to business or personal information you provide as a user ("User" or "You/R") during the use of platform. User means anyone who accesses, uses, processes and/or transacts through the Platform or uses our Services and includes a browser.

By accessing/visiting the Platform and voluntarily providing information to us (personal and/or non-personal), you consent to our use of it in accordance with this Policy and applicable law.

This policy does not apply to third-party websites/mobile applications connected through platform links. If you do not agree to this policy, please do not continue to use/access this platform.

1.PERMISSIONS

To assess your eligibility and facilitate faster disbursal of your loan, we need some permissions to access your phone, sms you can contact our customer center to delete your personal information at any time.

(1).SMS

HakiMoney will upload and transmit your SMS data from your phone to https://www.hakimoney.top.SMS will be used to manage risks and conduct anti-fraud checks. HakiMoney will never share data to the third party without your permission. The information will only be collected if you consent to the authorization. The data will transfer and upload over a secure connection(https).

(2).Phone state

We will collect and monitor specific information about your mobile phone, such as device brand and phone model. These information helps us uniquely identify users in order to detect and prevent any unauthorized device from acting on your behalf, which enables us to better detect fraud and manage risk.

(3).Data Security

All transactions are protected by 128-bit SSL encryption.the data will transfer and upload over a secure connection(https)to server:https://www.hakimoney.top.We only disclose your data with the financial service providers,banks and our third party partners for faciliation of a loan or line of credit. We will share your information under a confidentiality agreement with the third parties, there will be no unauthorized disclosure of your information.

2. COLLECTION OF INFORMATION

You irrevocably authorize and consent Us to collect your information hereinafter:

(1). Personal Data and Information collected directly

i. Personal Information:

Personal information includes any information concerning the personal or material circumstances of an identified or identifiable User, e.g. name, e-mail address, gender, date of birth, postal address, phone number, a unique login name, password, password validation, marital status, family details, business information and other details shared via application form or via email or via any other medium.

It can also include information such as username, account number, password and any other personally identifiable information.

While You can browse some sections of Our Platform without being a registered member as mentioned above, most activities (such as filling in personal information on the Platform) requires registration and for You to provide the above details.

ii. Financial Information:

The Company may have access to User’s financial information such as bank account, details regarding payment instrument, and transaction data pertaining to Users collected from partnering merchants; and/or bureau data collected from financial organizations;

The Company may also have access to User’s payment card details like the credit, debit card and/ or internet banking account information etc. collected via the Platform. User, by submitting these details expressly consents to the sharing of its information with the sellers/ merchants, third-party payment processors, payment gateways, payment aggregators and other third-party service providers.

Company clarifies that it cannot view the User’s banking username and passwords, and the same will be securely stored in separate encrypted areas with the financial services providers.

iii. Collection of Device Information:

The information the Platform collects, and how that information is used, depends on how You manage Your privacy controls on Your device.

When You install Our mobile application, We store the information We collect with unique identifiers tied to the device You’re using.

We collect information from the device when You download and install the mobile application and explicitly seek permissions from You to get the required information from the device.

The information We collect from Your device includes the unique ID i.e. IMEI number, information on operating system, SDK version and mobile network information including carrier name, SIM Serial and SIM Slot, Your profile information, list of installed apps, wi-fi information.

We collect information about Your device to provide automatic updates and additional security so that Your account is not used in other people’s devices. In addition, the information provides Us valuable feedback on Your identity as a device holder as well as Your device behavior, thereby allowing Us to improve Our services and provide an enhanced customized user experience to You.

The key information collected from the device is further detailed below

iv. Equipment, operator, network information:

We need to obtain your device, carrier and network information;

After we collect it, it will be applied to: ensure that your device and network are normal, and that you can use the program normally.

v. Authentication information:

We will obtain your identity verification information from your ID photo;

We will read the ID number based on the ID photo, help you pre-fill the information and confirm your qualifications, and provide corresponding loan services according to your qualifications.

The above information will be uploaded to: https://www.hakimoney.top. We will not share your information with third parties without your permission.

(2). Personal Data from Third Parties

i. Credit Reports:

We also collect Your credit reports and credit data on Your behalf in the event You have requested the same from Us. In this regard, You:

a. Authorize Us, to request and receive Your credit score / report from credit information companies, now and on a periodic basis, at its discretion until such time You communicate in writing to Us to discontinue such requests.

b. further fully understand that the purpose of this credit score / report is to enable Us to effectively make personalized offers to You and enable faster processing of credit applications to help provide speedier access to credit through Our Platform.

c. also understand that We may apply for the credit score / report either ourselves directly or through any of their partner tie ups who are members of credit information companies, and fully authorize Us to share Your details with such partner.

ii. Social Media:

We also collect information and data through Facebook, Twitter, LinkedIn or other social media accounts of the Users which have been linked to the account on the mobile application, if any.

We may receive Your Personal Information from such social media websites/ applications, in accordance with the privacy policy of such sites/applications. Such information received from the other websites/platforms/applications at the time of accessing Platform may include, and not be limited to, the user name, profile picture, e-mail address associated with that particular website/ application, any information that has been made public in connection with that website/ application belonging to You and/ or any information or content the social media website/ application has the right to share with Us.

(3). Collection of Other Non-Personal Information

i. Additional Information

We automatically track certain information about You based upon Your behavior on Our Platform. We use this information to do internal research on Our users' demographics, interests, and behavior to better understand, protect and serve Our users and improve Our services. This information is compiled and analyzed on an aggregated basis.

We also collect Your Internet Protocol (IP) address and the URL used by You to connect Your computer to the internet, etc. This information may include the URL that You just came from (whether this URL is on Our Platform or not), which URL You next go to (whether this URL is on Our Platform or not), Your computer browser information, and Your IP address.

If You send Us personal correspondence, such as emails or letters, or if other users or third parties send Us correspondence about Your activities or postings on the Platform, We collect such information into a file specific to You.

ii. Cookies

The Company may use "cookies" as required on the Platform. "Cookies" is a term generally used for small text files a web site uses to recognize repeat users, facilitate the user's ongoing access to and use of the site, allow a site to track usage behavior and compile aggregate data that will allow content improvements and targeted advertising, preferences etc.

Cookies themselves do not personally identify the User, but it identifies User device. Generally, cookies work by assigning a unique number to the computer that has no meaning outside the assigning site.

For the purpose of this Policy Users are informed that cookies also exist within mobile applications when a browser is needed to view certain content or display an advertisement within the application.

Users are being made aware that the Company cannot control the use of cookies or the resulting information by advertisers or third parties hosting data on the Company’s Platform. If Users do not want information collected through the use of cookies, they may change the settings in the browsers that allows to deny or accept the cookie feature as per User discretion and in the manner agreed by them.

iii. Web Beacons

The web pages of the website contain electronic images known as “web beacons”, sometimes called single-pixel gifs and are used along with cookies to compile aggregated statistics to analyze how the website is used. Web beacons may also be used in some of the Company’s emails to so as to know which emails and links recipients have opened, allowing it to gauge the effectiveness of its customer communications and marketing campaigns.

3. MODE OF COLLECTION OF INFORMATION

We may collect User information in a manner that includes the following:

(1). Information that the User provide to Us by filling in registration / enrollment / signing up forms on the Platform/ or availing any other financial service from the Platform.

(2). Information that the User provides when Users writes directly to Us by way of e-mail, letters, messages, etc.

(3). Information that the User provides merely by accessing/navigating the Platform.

(4). Information collected by the Company through independent third-party sources like merchants, financial organizations and other credit bureaus.

4. USE OF INFORMATION

You explicitly authorize and consent that We may use the information provided by You in the following ways:

(1). to establish identity and verify the same;

(2). monitor, improve and administer Our Platform;

(3). design and offer customized products and services offered by Our third-party financial partners;

(4). analyze how the Platform is used, diagnose service or technical problems and maintain security;

(5). send communications notifications, information regarding the products or services requested by You or process queries and applications that You have made on the Platform;

(6). manage Our relationship with You and inform You about other products or services We think You might find of some use;

(7). conduct data analysis in order to improve the services provided to the User;

(8). use the User information in order to comply with applicable laws and regulations;

(9). For fraud prevention and detection;

(10). use the User information in other ways permitted by law to enable You to take financial services from Our lending partners.

(11). We will use and retain Your information for such periods as necessary to provide You the services on Our Platform, to comply with Our legal obligations, to resolve disputes, and enforce Our agreements.

(12). Share the User information with Our lender partners enabling them to pull out credit reports through independent credit bureau agencies.

5. STORAGE OF INFORMATION

We store and process Your personal information on Ali cloud servers and other cloud service providers within Kenya. Some of the safeguards We use are firewalls and 2048 bit data encryption using SSL, and information access authorization controls. We use reasonable safeguards to preserve the integrity and security of

Your information against loss, theft, unauthorized access, disclosure, reproduction, use or amendment. To achieve the same, We use reasonable security practices and procedures as mandated under applicable laws for the protection of Your information. Information You provide to Us may be stored on Our secure servers located within or outside Kenya.

However, You understand and accept that there’s no guarantee that data transmission over the Internet will be completely secure and that any information that You transmit to Us is at Your own risk. We assume no liability for any disclosure of information due to errors in transmission, unauthorized third party access to Our Platform and data bases or other acts of third parties, or acts or omissions beyond Our reasonable control and You shall not be entitled to hold Us responsible for any breach of security.

6. INFORMATION SHARING

(1). We will share Your information with third parties to facilitate provisioning of services by Us to You only in such manner as described below:

(2). We may share Your information with third parties under a confidentiality agreement for provision of services which inter alia restricts such third parties from further disclosing the information unless such disclosure is for the purpose as detailed under that confidentiality agreement.

(3). We may disclose Your information to the financial service providers, banks or NBFCs and Our third-party partners for providing the services as detailed under the Terms & Conditions;

(4). We may share Your information with Our third-party partners in order to conduct data analysis in order to serve You better and provide services on Our Platform;

(5). We may disclose Your information, without prior notice, if We are under a duty to do so in order to comply with any legal obligation or an order from the government and/or a statutory authority, or in order to enforce or apply Our terms of use or assign such information in the course of corporate divestitures, mergers, or to protect the rights, property, or safety of Us, Our users, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction;

(6). We may disclose Your information to authorities as requested upon applicable laws and regulations.

7. THIRD PARTY WEBSITES

With this Policy We’re only addressing the disclosure and use of data collected by Us. If You visit any websites through the links on the Platform, please ensure You go through the privacy policies of each of those websites. Their data collection practices and their policies might be different from this Policy and We do not have control over any of their policies neither do We have any liability in this regard.

We might post Your data, excluding personally identifiable information, on various pages of Our Platform that will be visible to people other than registered Users.

8. PHISHING

"Phishing" usually occurs when users of a website are induced by an individual/entity into divulging sensitive personal data by using fraudulent websites and/ or e-mail addresses. In the event You provide information to a website or respond to an e-mail which does not belong to Us or is not connected with Us in any

manner, You will be a victim to Phishing. We do not send e-mails requesting a user for payment information, user name or passwords. However, We may verify the user name, password etc. provided by You from time to time.

9. SEVERABILITY AND EXCLUSION

We have taken every effort to ensure that this Policy adheres with the applicable laws. The invalidity or unenforceability of any part of this Policy shall not prejudice or affect the validity or enforceability of the remainder of this Policy. This Policy does not apply to any information other than the information collected by Us through the Platform. This Policy shall be inapplicable to any unsolicited information You provide Us through the Platform or through any other means. This includes, but is not limited to, information posted in any public areas of the Platform. All unsolicited information shall be deemed to be non-confidential and the Company shall be free to use and/ or disclose such unsolicited information without any limitations.

10. NO WAIVER

The rights and remedies of available under this Policy may be exercised as often as necessary and are cumulative and not exclusive of rights or remedies provided by law. It may be waived only in writing. Delay in exercising or non-exercise of any such right or remedy does not constitute a waiver of that right or remedy, or any other right or remedy.

11. USER ACKNOWLEDGEMNET AND CONSENT

(1). Users acknowledge that by accessing the Platform, Users expressly consent, authorize and confirm Us to collection, maintenance, usage, handling and disclosures of User information including the sensitive personal data by Us in accordance with this Policy.

(2). Users acknowledge and understand that based on Your written request, We will collect Your credit reports and credit data on Your behalf from credit information companies that We collaborate with. In this regard, You, authorize Us, to request and receive Your credit score / report from such credit information companies, now and on a periodic basis, until such time You communicate in writing to Us to discontinue such requests.

(3). Users acknowledge that the Platform may contain links to other websites. If a User clicks on a third-party link, the User will be directed to that website/mobile application. Note that these external sites are not operated by Us and therefore, it is strongly advised that Users review the privacy policy of these websites / external links. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

(4). Users acknowledge that they have the option not to provide or agree to the collection of information. If a User chooses not to agree with the Policy, they will not be entitled to use Our services.

12. CHANGES TO THIS PRIVACY POLICY

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

While we will always endeavor to notify you, you must periodically review the policy for the latest information on our privacy practices. Changes to this Privacy Policy will be effective as soon as they are posted on this page. By continuing to access and use the platforms and services we provide, you agree to all changes to this Privacy Policy.

13.CONTACT US

ZAMARADI CAPITAL & CREDIT GROUP LTD

HakiMoney

Mail:service@hakimoney.top

POSTAL ADDRESS: P.O BOX 3683 ELDORET

COUNTY: NAIROBI,

DISTRICT: KASARANI DISTRICT ,

LOCALITY: ROYSAMBU

STREET: GALANA ROAD,

BUILDING: GALANA PLAZA