Privacy Policy for SAWA CASH

1.0 Compliance Statement and Introduction

1.1 Sawa Cash (hereinafter referred to as the "Company" or "we") understands the importance of privacy to our customers (hereinafter referred to as "you"). This Privacy Policy is intended to explain how we collect, use, store, protect, and disclose your personal information when you visit our website or use the Sawa Cash application (hereinafter referred to as the "App"). 

1.2 By downloading, registering, or using this App, you acknowledge that you have read, understood, and accepted all terms of this Privacy Policy. If you do not agree with this policy, please stop using our services immediately.

2.0 Data Collection and Acquisition Channels

2.1 We collect certain personal information from you. This information may be provided directly by you (including, when registering an account or using services), provided legally by third parties, or collected automatically by the system when you use the App. We collect necessary information in various forms for purposes permitted by applicable laws. 

2.2 Information you provide directly includes: Name, ID Number, date of birth, gender, educational background, and marital status. 

2.3 Contact and account information includes: Mobile phone number, email address, physical residential address, and emergency contact information.

2.4 Financial and employment information includes: Occupation, income status, mobile wallet account details (M-Pesa), and bank account information.

3.0 Specialized Data Permissions: SMS Permission

3.1 Core Filtering Logic: The App utilizes intelligent filtering technology to extract only SMS messages directly related to financial transactions (e.g., bank notifications, mobile payment statements, and repayment reminders). 

3.2 Privacy Commitment: We explicitly pledge not to collect, access, or read any personal social private messages, verification codes (OTPs), or other non-financial SMS content. 

3.3 Purpose of Processing and Use: This data is used to establish your credit risk model, helping us accurately assess your repayment ability and identify fraudulent behavior. By analyzing your cash flow patterns and transaction amounts, we can more effectively prevent money laundering or other illegal uses of our services. You may choose to grant or deny this permission; however, denying authorization will result in our inability to assess your credit risk profile, thereby preventing the provision of loan services. 

3.4 Data Security Mechanism: All filtered financial data will be transmitted via HTTPS encryption to our secure servers. You may revoke this permission at any time, but this may lead to a failed credit assessment or the cancellation of your loan limit.

4.0 Key Device Permissions and Monitoring Scope

4.1 Device Identification Permission: We collect the device operating system version, IMEI number, IMSI number, MAC address, Android ID, and hardware serial number to uniquely identify the device and ensure that unauthorized devices do not act on your behalf, thereby strictly preventing fraud. 

4.2 Network Data Monitoring: We analyze Wi-Fi connection status, network type, and IP address. This is intended to improve request response speeds and identify unsafe network environments that may pose data risks. 

5.0 Advertising and Promotional Materials

5.1 Marketing Communication: We may send marketing information to you via mail, telephone, Short Message Service (SMS), email, online messaging, or App push notifications regarding special offers, promotions, or updates about the App’s products. 

5.2 Unsubscribe: You may opt-out of receiving such marketing communications at any time by clicking the "unsubscribe" link in the relevant message or by contacting us through the contact information provided below. Please note that even if you opt-out of marketing messages, we may still send you non-promotional information, such as loan disbursement notices or repayment receipts.

6.0 Cookies and Tracking Technology

6.1 We use cookies and similar technologies to understand user behavior and improve our services. You can adjust these preferences in your browser or device settings.

7.0 How We Use Collected Personal Information

7.1 Identity Verification: To identify you, complete user registration, and manage, maintain, or verify your account and credit status. 

7.2 Credit Decisioning: To establish credit models and scoring to assess your loan eligibility and credit limit. 

7.3 Service Management: To process loan disbursements, track repayment progress, and provide customer support services. 

7.4 Technical Support: To maintain, develop, test, improve, and personalize the application to meet user needs and preferences. 

7.5 Security Defense: To monitor abnormal activities and prevent hacking attacks and illegal financial behavior. 

7.6 Market Communication: To send you special offers, promotions, or service update notifications.

8.0 Data Security and Global Storage

8.1 Transmission Encryption Standards: All data is encrypted throughout the process via industry-standard HTTPS/SSL protocols to strictly prevent illegal interception during transit. 

8.2 Encrypted Storage Measures: Data is processed using Advanced Encryption Standards (AES) during storage and kept on dedicated servers with high-level protection capabilities. 

8.3 Cross-Border Processing: To optimize services, your data may be processed by our affiliates located in other regions. We will ensure that the level of protection fully complies with Kenyan law and relevant data protection requirements.

9.0 Data Retention and Deletion Policy

9.1 Retention Period: We retain data only for the necessary period required to achieve credit assessment and service purposes. According to Kenyan tax laws and financial regulatory requirements, certain transaction records will continue to be retained after you stop using the service until the statutory expiration period. 

9.2 Permanent Deletion: When the retention period expires and there is no commercial necessity, we will perform permanent physical deletion or irreversible anonymization of your personal information.

10.0 Information Sharing and Disclosure

10.1 Service Providers and Partners: Shared with credit reference bureaus, banks, telecommunications operators, debt collection agencies, and technical suppliers for credit assessment, transaction processing, and business operations. 

10.2 Legal and Regulatory Compliance: Disclosure in response to court orders, regulatory inquiries, or statutory filings as required by law to prevent money laundering, illegal activities, and economic loss. 

10.3 Affiliates and Restructuring: Shared with affiliates for data processing, or disclosed as necessary during commercial negotiations and transactions such as company mergers, financing, or asset sales. 

10.4 Debt Collection and Emergency Verification: In the event of a payment default and inability to contact you directly, we will contact your emergency contacts or transfer the matter to external collection agencies to verify identity and repayment intent. 

10.5 Legal Proceedings and Safety: Used for processing legal proceedings related to the service, or for necessary disclosure to enforce terms of use and protect personal or property safety. 10.6 Statistics and Anonymization: Sharing aggregated data that cannot identify individuals for market analysis, trend research, and product optimization.

11.0 Your Data Subject Rights

11.1 Right of Access and Correction: You have the right to view and request updates to any inaccurate or incomplete personal data. 

11.2 Right of Cancellation and Deletion: After all loan debts have been cleared, you may contact us to apply for account cancellation. 

11.3 Withdrawal of Authorization: You may withdraw data access permissions at any time. However, please note that withdrawing core authorizations may result in the termination of services.

12.0 Policy Revision and Limitation of Liability

12.1 Revision Notice: We may revise this policy based on business development or changes in laws and regulations. Once the revised content is published, your continued use of the App constitutes acceptance of the new terms.

12.2 Limitation of Liability: We assume no legal responsibility for the loss of credentials (including password leakage) caused by your personal negligence, internet failures caused by force majeure, or illegal acts of third parties beyond our reasonable control. 

12.3 Delay Disclaimer: We are not responsible for system delays or failures beyond our control.

13.0 Children's Privacy

13.1 Our services are not directed at children. We do not knowingly collect personal information from children under the age of 18. If we discover such collection has occurred, we will take immediate steps to delete the relevant information.

14.0 Contact Information

14.1 If you have any questions regarding this policy, please contact our Data Protection Officer through the following means.

14.2 Official Contact Email: marcomuhammad44@gmail.com