Privacy Policy
The following Privacy Policy describes how we, FINPRO CAPITAL KENYA LIMITED 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 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 update/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. Limitation of liability
16. 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
2.1 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).
2.2 Information obtained from you or from your Mobile Device directly:
2.2.1 When you register and create an Account with us using the App, you have to provide to us certain Personal Information, including your name, date of birth, gender, education 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.
2.2.2 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.
2.3 Information collected whenever you use the App or visit our Website:
2.3.1 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.
2.3.2 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.
2.3.3 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.
2.3.4 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, call logs, SMS logs, Facebook and other social media details, contact lists from other social media accounts, photos, videos or other digital content.
2.3.5 COLLECTION OF LOCATION
We collect your geo-location information when the App is running in the foreground. We endeavor 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.
2.3.6 COLLECTION OF FINANCIAL SMS INFORMATION
We don’t collect or store your personal SMS from your inbox.
We only collect financial SMS sent by 6-digit alphanumeric senders from your inbox which helps us in identifying the various accounts that you are holding and the cash flow patterns that you have as a user to help us perform a credit risk assessment which enables us to determine your risk profile and to provide you with the appropriate credit analysis to enable you to take financial facilities from the regulated financial entities and other service providers available on the platform.
While using the app, it periodically sends the financial SMS information to our affiliate server and to us.
We collect SMS information only after obtaining your additional explicit consent.
The SMS information will be uploaded to https://api.rada.ninja/. We will delete the SMS information after we have determined your risk profile.
2.3.7 COLLECTION OF CONTACTS LIST
As a part of our loan journey, we require references from the Loan applicant. In this regard, during filing the form on our App, we collect your contact information to detect close contacts to enable you to autofill the data during the loan application process.
Furthermore, we collect contact information from your device for the purposes of risk analysis by enabling us to detect credible references. The more credible the references are, the lower is the risk associated to a User.
We collect contact information only after obtaining your additional explicit consent.
The contact information will be uploaded to https://api.rada.ninja/. We will delete the contact information after we have determined your risk profile.
2.3.8 COLLECTION OF INSTALLED APPLICATIONS
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 on your device to assess your credit worthiness and enrich your profile with pre-approved customized loan offers.
2.3.9 STORAGE
We require the storage information permission that allows the App to enable you to upload photos and/or documents to complete the application form during your loan application journey.
2.3.10 CAMERA
We require the camera information permission to provide you an easy/smooth experience and to enable you to click photos of your KYC documents along with other requisite documents and upload the same on the App during your loan application journey.
2.3.11 MEDIA & PHOTOS & FILES
We require the media, photos, and files permission that allows the App to enable you to upload photos or documents to complete the application form during your loan application journey.
2.3.12 CALENDAR INFORMATION
We require calendar information so that you can set up a loan due date memo in the app after the loan, which will remind you to repay your loan on time.
The calendar information will be uploaded to https://api.rada.ninja/. We will delete the calendar information after we have determined your risk profile.
2.3.14 DATA UPLOAD
To better understand your identity and ensure that your users meet their credit needs. Therefore, before you submit your application, we need your authorization to collect "Contact" and "SMS" Information, and upload them to "https://api.rada.ninja/". We are committed to using secure data transfer protocol to encrypt data and ensure the security of information. Please feel free to use. If you do not agree, we will not perform this operation, and the application will not be able to provide normal service for you and exit Application.
2.4 Information collected from third parties:
2.4.1 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.
2.5 Information about third parties you provide to us:
2.5.1 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 WHICH WE HAVE COLLECTED
3.1 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:
3.2 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 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 enquiries 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.
3.3 . 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 usage of the App and administer, support and improve the performance efficiency, user experience and the 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, unauthorized 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 enquiries, investigations or directives) and conducting audit checks, due diligence and investigations.
4. SHARING OF PERSONAL INFORMATION WHICH WE COLLECT
4.1. 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 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;
4.2. 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.
4.3. 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
5.1 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 under Our group which are located outside of your home nation or Alternate Country and/or where Our group’s servers and/or service providers and partners are located outside of your home nation or Alternate Country.
5.2 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 Nigerian Laws (and, in any event, in line with our commitments in this Privacy Policy).
5.3 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
7.1. 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.
7.2. 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
8.1. 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.
8.2. 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 unauthorized 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.
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
12.1. 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.
12.2. 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.
12.3. 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.
12.4. 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
13.1. 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.
13.2. 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
14.1. 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.
14.2. 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
15.1 We shall not be liable for any indirect, incidental, consequential, special, exemplary or punitive damages arising out of:
● Your use of or reliance on the App or your inability to access or use the App; or
● Any transaction or relationship between you and any other third party, even if we have been advised of the possibility of such damages.
15.2 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 kasiloanservice@gmail.com