Last updated: 12 July 2023

Introduction

This privacy policy (“Privacy Policy”) applies to the personal information that Pay 24 Financial Services Limited processes in connection with the Azima app(s), website(s), software and related services (the “Platform”), that link to or reference this Privacy Policy.

Your personal privacy and the privacy of your data is paramount to us at MeWe. We have prepared this Privacy Policy to clearly explain how we protect you and your data at MeWe.

Privacy Bill of Rights

We are uncompromising about trust, respect and integrity.

·       You own your personal information & content. It is explicitly not ours. 

·       We do not sell your personal information to anyone.

·       Your face is your business. We do not use facial recognition technology.

·       We do not use cookies or other tracking technologies on our platform.

·       You will never receive targeted third-party advertisements or targeted third-party content.

·       Permissions & privacy are your rights. You control them.

·       You have the right to delete your account.

·       We are certified by the Personal Data Protection Office of Uganda. Contact us for a copy of the certificate.

What Information We Collect

We collect your information in three ways: Information You Provide, Automatically Collected Information, and Information From Other Sources. More detail is provided below.

Information You Provide

Profile Information. We collect information that you provide when you register for a loan, such as your date of birth, full name(s), mobile number, government-issued identity number (such as National Identity Number [NIN], National Identity Card Number [NID Card No.], passport number, driving license number, etc.) address, and login pin. We also collect additional information in the form of photographs submitted by you of yourself (selfie), and the front and rear of your government-issued identity document.

Information When You Contact Us. When you contact us, we collect the information you send us, such as proof of identity, alternate contact number(s), email address(es), social media IDs/handles, feedback or inquiries about your use of the Platform or information about possible violations of our Terms of Service (our “Terms”), Loan Agreement (our “Loan Agreement”), or other policies.

Automatically Collected Information

Technical Information. We collect your device model when you access the Platform.

Cookies. We do NOT use cookies and similar tracking technologies to operate and provide the Platform.

Information From Other Sources

Third-Party Platforms and Partners. Third-party platforms provide us with logistical support for hosting, authentication, data storage, marketing and usage monitoring. Our partners (such as Amazon Web Services, Google Analytics, Google AdSense, and AppsFlyer) have all implemented strict measures to maintain the integrity of our user’s (your) privacy. We ensure that all our service providers minimize PII (Personal Identifiable Information). You can read more about their respective policies at these links:

· How Google uses information from sites or apps that use our services | Google

· Data privacy | Amazon Web Services (AWS)

·The highest privacy standard in the industry | AppsFlyer

 

Payment Integrators and Telecommunication Service Providers. We may receive information about you from our payment integration partners and telecom providers in order to verify your mobile money wallet registration information, identity and related data.

Others. We may receive information about you from others, for example, where you are included or mentioned in a complaint, appeal, request or feedback submitted by a user, law enforcement or third party, or if your contact information is provided to us by a user.

How We Use Your Information

We use your information to operate, provide, develop, and improve the Platform, including for the following purposes. You can find more detail in “Our Legal Bases and How We Process Your Information”.

·       Provide and administer the Platform, such as enabling you to apply for a loan, borrow and repay your loan(s).

·       Calculate your Loan Limit, Azima Rating and/or Azima Score (refer to the “Loan Agreement”)

·       Process, facilitate, or fulfil requests related to our products and services.

·       Enforce our Terms, Loan Agreement, and other policies that apply to you.

·       Maintain and enhance the safety, security, and stability of the Platform by identifying and addressing technical or security issues or problems (such as technical bugs, spam accounts, and detecting abuse, fraud, and illegal activity).

·       Promote the Platform through marketing communications.

·       Comply with our legal obligations, or as necessary to perform tasks in the public interest, or to protect the vital interests of our users and other people.

How We Share Your Information

Service Providers

We engage service providers that help us provide, support, and develop the Platform and understand how it is used. They provide services such as cloud hosting, content delivery, customer and technical support, identity verification, marketing, analytics, text messaging services, online payment and mobile money services. We share Information You Provide, Automatically Collected Information, and Information From Other Sources with these service providers as necessary to enable them to provide their services.

Partners

Third-Party Platforms and Partners. We share limited information which may include Information You Provide, Technical Information, and Usage Information with third-party platforms and partners whose platform or services are integrated with the Platform. We do this to give you a seamless experience, access your account anywhere when you connect to the internet and enable us to authenticate users.

Marketing. Partners such as Google and AppsFlyer use aggregated and non-personalized information to deliver our marketing campaigns to the right set of potential users.

Measurement and Data Partners. We also share Technical Information and Usage Information with third-party measurement providers who help us measure advertising served on the Platform and help our advertisers determine how effective their ads have been.

Our Head Office

The Platform is supported by certain entities (“employees”, and “agents”) within or in cooperation with our corporate office. These entities process the Information You Provide, Automatically Collected Information, and Information From Other Sources for us as necessary to provide important functions, such as verification, loan approval, collections, storage, content delivery, security, research and development, analytics, online payments, customer and technical support, and content moderation.

Others

We share your information in other limited scenarios as follows:

Corporate Transactions. Your information may be disclosed to third parties in connection with a corporate transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control, or acquisition of all or a portion of our business.

Legal Obligations and Rights. We may access, preserve, and share the information described in “What Information We Collect” with law enforcement agencies, public authorities, or other third parties if we have good faith belief that it is necessary to:

·       comply with applicable law, legal process or government requests,

·    protect the rights, property, and safety of our users, shareholders, and others, including protecting life or preventing imminent bodily harm. For example, we may provide information (such as your contact information) to law enforcement in the event of an emergency where someone’s life or safety is at risk,

·       investigate potential violations of and enforce our Terms, Loan Agreement, or any other applicable terms, policies, or standards, or

·       detect, investigate, prevent, or address misleading activity, fraud, or other illegal activity.

Our Legal Bases and How We Process Your Information

We may only use your information when we have a “legal basis” to do so. We use different legal bases depending on why we use your information (in other words, the “purpose” of our processing). These legal bases are contractual necessity, legitimate interests (ours, yours or those of another party), consent, compliance with a legal obligation, performing a task in the public interest, and protection of vital interests.

Here we explain the legal bases we rely on when we process your information. This section also describes why we use your information, how this information is processed, the categories of information involved, and the associated rights (which always include the right to access your information). For more information on how to exercise any of your rights, please check out the “Your Rights and Choices” section.

Contractual Necessity

We use Information You Provide, Automatically Collected Information, and Information From Other Sources where it is necessary to perform the contract you enter into (our Terms) when you register for, access, or use the Platform. This means we use your information to:

·       Provide you with the Platform. We use your information to allow you to access and use the Platform, including allowing you to contact our support services, and provide you with products and services you wish to access. We also use your information to calculate your Azima Score and/or Azima Rating in order to provide you with a Loan Limit (refer the “Loan Agreement”).

·       Enforce our Terms, Loan Agreement, or policies. We use your information to enforce our Terms, Loan Agreement, and policies. This may include removing uploaded information (including through automated means) or suspending or banning your account if we determine that you are violating our Terms or Loan Agreement.

·       Administer the Platform. We also use the information we have to administer the Platform, such as to communicate with you on service-related matters and respond to your queries (including when you tell us about a problem or ask for a copy of your information).

Your Rights: Whenever we use your information on the basis that it is necessary for the contract or agreement we have with you, you have the right to update the information you have provided to us.

Legitimate Interests

We use your information where this is necessary to achieve legitimate interests – whether belonging to us, you, or a third party – provided these interests are not outweighed by your interests or fundamental rights. We use the information we collect to:

Ensure the safety of our Security (refer to “Loan Agreement”) and Product.

·       We use your information to ensure the safety our loan product, by reviewing for breaches of our Terms, Loan Agreement, and other policies. Under certain circumstances, we may ask you to provide additional information to confirm your identity.

·       Legitimate Interest relied upon: To keep our community safe, review compliance with our Terms, Loan Agreement, and other policies, and identify misuse of the Platform.

·       Information used: Information You Provide, Automatically Collected Information and Information From Other Sources.

Ensure the security and stability of the Platform.

·       We use your information to ensure the stability and security of the Platform, including by identifying and combating technical or security issues (such as technical bugs, spam accounts, and detecting abuse, fraud, and illegal activity).

·       Legitimate Interest relied upon: To ensure the ongoing stability and security of the Platform and to ensure it is continuously available and functioning.

·       Information used: Information You Provide, Automatically Collected Information and Information From Other Sources.

Review, improve, promote and develop the Platform.

·       We use the information we have to understand how people are using the Platform and to develop and improve the Platform, including to train, develop, and improve our technology such as our machine learning models and algorithms. We also use this information to better understand and promote the Platform, popular topics, and emerging trends.

·       Legitimate Interest relied upon: To improve, promote, and develop the Platform in an informed way.

·       Information used: Information You Provide, Automatically Collected Information, and Information From Other Sources.

Share your information with third parties.

·       We share your information with third parties whose platforms or services are integrated with the Platform.

·       Legitimate Interest relied upon: To provide you with a login authentication, secure access to your content, and optimise user experience.

·       Information used: Information You Provide, Automatically Collected Information, and Information From Other Sources.

Your Rights: Whenever we use your information on the basis that it is necessary for legitimate interests, you can request clarification on such usage.

Your Consent

We ask for your consent to access or use your information for specific purposes. If we do, you’ll always be able to revoke your consent through your device permissions or in-app settings. It is important to understand that when you revoke certain permissions, we may not be able to product with access to our products and/or services, as the case may be.

Compliance with a legal obligation

We may use your information including your Profile Information or User Content where it is necessary to comply with a legal obligation. This includes situations where we have obligations to take measures to comply with terms of the licensing authority in the country or comply with a valid legal request such as an order from law enforcement agencies or courts. We generally use Information You Provide and Automatically Collected Information, although it depends on the specific situation.

To perform a task in the public interest

We may use your information where it is necessary to perform a task in the public interest, including undertaking research, preventing and detecting crime, safeguarding our financial accounts, and promoting public safety, security, and integrity as laid down by applicable law. We generally use Information You Provide and Automatically Collected Information, although it depends on the specific situation.

To protect someone’s vital interests

We may use your information where it is necessary to protect your or someone else’s life, physical integrity, or safety. This could include providing law enforcement agencies or emergency services with information in urgent situations to protect health or life. We generally provide Information You Provide and Automatically Collected Information, although it depends on the specific situation.

Your Rights and Choices

You have rights and choices when it comes to your information. Some of these rights generally apply, while others will only apply in certain circumstances. Depending on the scenario, these rights may be subject to some limitations. Pay 24 Financial Services Limited will be responsible for responding to your request within the gamut of the law.

Access your information. You can ask us to confirm what information we process about you, to provide certain information about the processing, and for a copy of your information.

Delete your information. You can delete or ask us to delete some or all of your information. This request can be fulfilled provided your information is not needed to meet our legal and/or regulatory obligations.

Rectify your information. You can change or ask us to change or correct your information where that information is not accurate. You can change or correct much of your information through the in-app controls and settings.

Object to the processing of your information. You also have the right to object to the processing of your information in certain circumstances. This right applies when we are performing a task in the public interest or pursuing our legitimate interests or those of a third party. In submitting an objection request, please provide all relevant information, including the processing activity you are objecting to, why you want to object and how the processing activity affects you, and any additional information that you think will help us review your request. We will stop the particular processing if we don’t have compelling legitimate grounds to continue that processing or don’t need it for legal claims.

Restrict the processing of your information. You have the right to request the restriction of the processing of your information where (a) you are challenging the accuracy of the information, (b) the information has been unlawfully processed, but you are opposing the deletion of that information, (c) where you need the information to be retained for the pursuit or defence of a legal claim, or (d) you have objected to processing and you are awaiting the outcome of that objection request.

To exercise any of the above rights, please contact us. Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details or provide additional information so that we can understand your request.

We encourage you to “Contact us” if you are not satisfied with how we have responded to any of your rights requests. You also have the right to lodge a complaint with the Personal Data Protection Office | PDPO of Uganda (Pay 24 Financial Services’ data protection supervisory authority in Uganda).

Data Security and Retention

Security of your information is important to us. We maintain appropriate technical, administrative, and physical security measures that are designed to protect your information from unauthorised access, theft, disclosure, modification, or loss. We regularly review our security measures to consider available new technology and methods.

We retain information for as long as necessary to provide the Platform and for the other purposes set out in this Privacy Policy. We also retain information when necessary to comply with contractual and legal obligations, when we have a legitimate business interest to do so (such as improving and developing the Platform, and enhancing its safety, security and stability), and for the exercise or defence of legal claims.

The retention periods will be different depending on the type of information and the purposes for which we use the information. For example, when we process your information to provide you with the Platform, we keep this information for as long as you have an account. This information includes your Profile Information, Identity Information, and Transactional Information. If you violate our Loan Agreement or Terms, we may remove your Profile Information and/or User Content from third-party view immediately but keep your information as is necessary to process the violation.

Our Operations and Data Transfers

We store the information described in What Information We Collect in secure servers operated by Amazon Web Services (AWS).

Certain entities (“Employees”, “Agents”), located in or outside your country of residence, are given limited remote access to this information so they can provide certain functions, as described in the Our Head Office section in How We Share Your Information. This access is limited, secure and only granted where necessary under strict security controls and authorisation approval protocols.

We share What Information We Collect with service providers, partners and other third-party entities, as described in How We Share Your Information. These third parties may or may not be located outside your country of residence. These entities commit to processing information in compliance with applicable privacy laws and to implementing appropriate security measures to protect your information.

Security

We maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of your personal user data and other information transmitted to us. For example, we encrypt your personally identifiable information (PII), and most, if not all requests from you to the server are created over a secure connection (HTTPS).

However, no data transmission over the Internet or other network can be guaranteed to be 100% secure.

Younger Users

You must be at least 18 years old to use the Platform. If you believe that there is a user who is below this minimum age, please contact us using the details set out in the “Contact Us” section below.

Privacy Policy Updates

We may amend or update this Privacy Policy from time to time. We will notify you of any material changes to this policy by a notice provided through the Platform or by other means. The “Last Updated” date at the top of this policy reflects the effective date of such policy changes.

Contact Us

You can contact us about this Privacy Policy through the following means:

·       Speak to our support team on one of our support helplines: +256-759-993-960, +256-752-609-935, +256-781-133-653 and +256-205-010-900

·       Use WhatsApp to text our support team on +256-781-133-653

·       Write to our support team via email on support@azima.app

You can reach Pay 24 Financial Services‘ Data Protection Officer by email: dpo@azima.app