Privacy Policy
Introduction
Welcome to the Ezee Loan App!
At Ezee Loan (referred to as “we”), we recognize the critical importance of your personal information. We are committed to safeguarding your privacy and handling your data with the utmost care. This “Ezee Loan Privacy Policy” (referred to as “this Policy”) outlines how we manage your personal information when you use our products and services, detailing your rights to access, update, delete, and protect your information in compliance with legal and regulatory standards.
Important Notice: Before you start using our products and services, please carefully read and understand this Policy, paying special attention to the bolded terms. You should only proceed if you fully agree to the terms outlined in this Policy. If you or your guardian (if you are a minor) disagree with any part of this Policy, you will not be able to use our products and services. For any questions, feedback, or concerns regarding this Policy, please reach out to us using the contact information provided in Article 9.
Scope of This Policy: This Policy applies to all products and services offered by the Ezee Loan platform. If any products or services provided by Ezee Loan or our affiliated companies use our platform but lack an independent privacy policy, this Policy will apply. In cases where an independent privacy policy exists for our products or services, that policy will take precedence. For any issues not covered by the independent privacy policy but addressed in this Policy, the provisions of this Policy will apply.
Entry into force: 12 July 2024
Part One: Definitions
- Ezee Loan Loan/We: Refers to Teravik Cash, the company that develops and operates the Ezee Loan loan platform [Registered Address: PLOT 22,ENTEBBE RD,2ND FLOOR SUITE, KAJJANSI,JKALANZI COMPLEX,P.O.BOX 980151,KAJJANSI].
- Ezee Loan app: Refers to the Ezee Loan loan webpage and client (including App or H5 pages), applicable to terminal devices including but not limited to PCs, tablets, mobile phones, etc.
- Affiliated Company: Refers to a company that is directly or indirectly controlled by one party; or directly or indirectly controls one party; or jointly controls a company or can exert significant influence on it with one party; or is controlled directly or indirectly by the same company as one party. This includes but is not limited to the parent company, subsidiaries, or subsidiaries controlled by the same parent company as one party; joint ventures, and associated enterprises of one party. Here, “institution” refers to any company, enterprise, or other legal entity; “control” refers to the ability to influence the management of the mentioned institution directly or indirectly through ownership, voting shares, contracts, or other ways recognized by the People’s Court.
- User/You: Refers to natural persons who access or use the products/services provided by the Ezee Loan loan platform, including registered and unregistered users.
- Personal Information: Refers to various information recorded electronically or otherwise that can identify a specific natural person alone or in combination with other information or reflect the activities of a specific natural person.
- Sensitive Personal Information: Refers to personal data that, if exposed, improperly shared, or misused, could jeopardize personal or property safety. This type of information has a high risk of causing damage to one’s reputation, physical or mental health, or resulting in discriminatory treatment. Under this Policy, sensitive personal information includes basic personal details, occupational data, family relationships, contact information, financial account details, and other related information.
- Personal Information Deletion: Refers to the act of removing personal information involved in daily business functions from the system, making it unsearchable and inaccessible.
- Child: Refers to minors under the age of fourteen.
- Minor: Refers to natural persons under the age of eighteen. Minors over the age of sixteen whose primary source of livelihood is their own labor income are considered persons with full civil capacity.
Part Two: Privacy Policy
This privacy policy aims to explain and help you understand the following:
- How we collect and use your personal information
- How we use cookies and similar technologies
- How we share, transfer, entrust processing, and disclose your personal information
- How we store your personal information
- How we protect the security of your personal information
- How we protect the personal information of minors
- Your personal Information rights
- Commitment to non-malicious software
- How This Privacy Policy Is Updated
- How to contact us
1. How We Collect and Use Your Personal Information
When you use our products/services, you need to authorize or can choose to authorize us to collect and use your personal information in the following situations:
- Basic Functions: To provide you with our products/services’ basic functions, you need to authorize us to collect and use necessary information. If you refuse to provide the necessary information, you will not be able to use our products/services properly.
- Additional Functions: To provide you with additional functions of our products/services, you can choose to authorize us to collect and use information. If you refuse to provide such information, you will not be able to use related additional functions or achieve the intended functionality, but it will not affect your use of the basic functions of our products/services.
Please note that due to the variety of products and services we provide, we will collect and use your personal information based on the specific products/services you choose, adhering to the principles of “reasonableness, legitimacy, and necessity,” and only collecting and using the minimum necessary personal information required to provide you with products/services. Furthermore, you understand and agree that to provide you with better products and services, we may introduce new or optimized functions from time to time, which may involve the collection and use of personal information for new purposes, scopes, and methods. In such cases, we will notify you separately through updates to this policy, pop-ups, or in-app messages, explaining the purposes, scopes, and methods of collecting and using the corresponding information, and providing you with the option to agree or disagree. We will only collect and use the corresponding information after obtaining your explicit consent. During this process, if you have any questions, comments, or suggestions, you can contact us through the contact information provided in Article 10 of this policy.
1.1 Helping You Register and Manage Your Ezee Loan Loan Account
1.1.1 Account Registration
If you want to use the products/services of the Ezee Loan loan platform, you first need to register a Ezee Loan loan account to become a member of the Ezee Loan loan platform. To create an account on the Ezee Loan loan platform, we need to collect your mobile phone number to identify your online identity on the Ezee Loan loan platform. If you refuse to provide a mobile phone number, we will not be able to create an account for you on the Ezee Loan loan platform and provide services. Under the same account, we may associate the information collected from your various devices to provide you with consistent services. If you refuse to provide the necessary information, you may not be able to use our services properly.
1.1.2 Account Login
When you first use a mobile phone number to log in to the Ezee Loan loan platform, to comply with legal requirements and protect your account security, we will send you a one-time verification code to verify your identity.
1.1.3 Information Maintenance and Account Management
To maintain your personal information and enhance your service experience, we will keep your information confidential.
1.2 Providing Security Functions
1.2.1 Real-name Authentication and Management
When using Ezee Loan loan services (including credit services, payments, and repayments), you need to provide and allow us to collect your identity information (including name, gender, nationality, occupation, residence, identification document type, number, marital information, work information, emergency contact information), bank card or third-party payment account information, and mobile phone number. We will submit this information to legal identity verification agencies to verify its accuracy. This information is considered sensitive. According to Ugandan regulations on financial services, if you do not provide the required information for real-name authentication, you will not be able to use the products or services of the Ezee Loan loan platform.
1.2.2 Security Guarantee
To ensure the stability and security of the system when you use our products/services, prevent unauthorized access to your personal information, more accurately prevent fraud, and protect account security, we need to collect your transaction information (transaction scenarios, transaction amounts, transaction times), log information, device application installation list, location information, Ezee Loan financial account ID, IMEI, IMSI, Android ID, boot_id, device basic information (brand, model, system version, storage space, screen resolution), MAC address, network type/network status, device-connected wireless network information (SSID/BSSID/status/list), IP address, application running process information. If you refuse to provide such information, you may not be able to use our services properly.
1.2.3 Credit Assessment
When using credit services on the Ezee Loan loan APP or applying for credit limits, to accurately assess your creditworthiness, repayment ability, and prevent fraud, you need to voluntarily provide your name, identification number, address, occupation and work information, education information, bank card number, mobile phone number, emergency contact information, income information, email address, marital status, and device information. If you refuse to provide such information, we cannot assess your eligibility, creditworthiness, and repayment ability, and thus cannot provide the required services.
1.3 Customer Service and Dispute Resolution
To ensure your account security, our customer service will use your account information (registered mobile number), identity information (name, identification number), and order information to verify your identity. When you need customer service related to your transactions, we will query your identity information, transaction information, behavior information, browsing information, commonly used device information, or software information from the backend, as well as any information you provide during contact with customer service. If you request customer service assistance in modifying information (such as personal information, contacts, or phone numbers), you may need to provide additional information. If you refuse to provide such information, you may not be able to use our services properly. When you contact us, we may keep a record of your communication/call and related information to contact you, help resolve issues, or record solutions and results. Such recordings will be automatically deleted after the minimum necessary retention period required by law (30 days), unless retention is required for compliance or legitimate interests.
1.4 Loan and Repayment Processing
When using Ezee Loan loan services for borrowing or repayment, depending on the service, you need to provide bank card numbers or mobile phone account information. If you refuse to provide such information, you may not be able to use our services properly.
1.5 Providing Product/Service Information
We will send the latest information about products or services, including Ezee Loan loan product information, promotional information, etc., via in-app messages, pop-ups, SMS, email, or phone. If you choose not to receive such information, you can turn off the notifications or contact customer service to cancel. Turning off notifications will not affect your use of the basic functions of the Ezee Loan loan platform.
1.6 Order Management
When you are ready to order products/services on the Ezee Loan loan platform, the system will automatically generate a loan order. During order management, we may collect the following information:
- Information required for the loan product/service you selected;
- Emergency contact name and phone number;
- Order information generated during the use of Ezee Loan loan platform products/services.
We collect this information to facilitate transactions, process payments, send notifications, manage orders, and provide customer support. Additionally, your order details help us detect and address any transaction anomalies to ensure your security.
When using our financial products and services, you will need to provide and authorize us to collect identity details (such as your name, gender, and ID type), bank card or third-party payment account information (including mobile accounts), mobile phone number, and other basic personal information as required by the loan products. Without supplying the necessary information for real-name authentication, you will be unable to access our financial products or services.
Further information may be requested to fully utilize our loan products and services. This will be clearly outlined or prompted during the loan process, so please review all information carefully.
1.7 Device Permission Instructions
To enhance your experience, our Ezee Loan app may request additional permissions based on your mobile device’s operating system. While you can still use our loan and related services without granting these permissions or providing the associated personal information, enabling them allows us to offer a more tailored service.
Please note that permissions may differ depending on your device’s operating system. Granting a permission authorizes us to collect and use the relevant personal information to deliver the corresponding services. If you choose to disable a permission, it means you revoke that authorization. Consequently, we will stop collecting and using related personal information and will no longer provide services associated with that permission. However, any information collected before you disabled the permission will remain unaffected.
For details on the permissions the Ezee Loan app may request, please refer to the device’s permission settings.
Android System Application Permission Instructions:
- Call Log
Purpose and Use of Collection of Call Records:
We request access to the user’s call log (CALL LOG) in our application for one explicit purpose only:
Device Authentication & Security: We use call logging permissions to verify that a user has installed our application on the same device and has accepted the voice-activated password (OTP) authentication that we send. Specifically, we read call logs to verify that the user has answered our voice verification code calls on the same device. This verification step is to ensure that the user’s account is secure from unauthorised access.
User Information and Consent: When users install the app, we clearly inform them that we will be requesting access to call logs and explain in detail exactly what this access will be used for and how we will ensure the security of their data. We will only access this data if the user is fully informed and has given their consent.
Data Minimisation and Security: We only access specific call logs that are relevant for device authentication and all data is encrypted to ensure that the user’s privacy is not violated. We do not use this data for any other purpose, nor do we store it on our servers.
User control and compliance: Users can manage or revoke their authorisation to access call logs at any time. We strictly adhere to Google’s Privacy Policy, Developer Agreement, and international data protection regulations such as GDPR to ensure that all operations meet the highest privacy standards.
- SMS
Collection of mobile phone SMS data collection purposes: We collect and analyse users’ finance-related SMS in order to provide accurate credit assessment services. This process helps us to understand the user’s financial situation, including income, expenses, borrowing and repayment history, etc., so that we can better assess their credit risk. User Informed and Consent: We explicitly inform users at the time of application launch that we will collect their financial-related SMS data and explain in detail how this data will be used for credit assessment. We collect data only after the user agrees to authorise it. We ensure that users are fully aware of our data collection and usage practices before granting permission. Data Minimisation Principle: We strictly follow the data minimisation principle and only screen, read and analyse financial text messages that are directly relevant to a credit assessment. We do not collect, store or process the content of personal text messages that are not related to credit assessment. Data encryption and security: Users’ SMS data is transmitted and stored using strong encryption technology to ensure data security and confidentiality. We undertake not to use the user’s personal data for any other purpose without the user’s explicit consent and not to share it with unauthorised third parties.
- Contact List
Purpose of Emergency Contact Information Collection:
We ask users to fill in emergency contact information, mainly to be able to protect the rights and safety of users in special circumstances:
- Fraud Risks: When we detect a possible risk of fraud on a user’s account, in order to protect the user’s property and personal safety, we may attempt to contact the user through an emergency contact to confirm the situation.
- Unable to contact users: When a user is overdue, unresponsive, or out of contact, we use emergency contacts to obtain contact information with the user or to confirm his or her safety, to the extent permitted by laws and regulations. This helps to ensure that we are able to contact users in a timely manner and provide them with the necessary assistance.
User Knowledge and Consent: Before a user provides emergency contact information, we clearly communicate the purpose of the information and the scenarios in which it will be used, and we obtain the user’s express consent. Users provide such information in a fully informed manner, and we use it only in accordance with applicable laws and regulations.
Data Minimisation and Security: We only collect and store information about emergency contacts and strictly limit its use. All information is transmitted and stored using encryption technology to ensure data security and privacy.
User Control and Transparency: We allow users to modify or delete their emergency contact information at any time through our customer service hotline, and provide a detailed privacy policy within the application that describes what emergency contact information is used for and how it is handled. Users can manage or withdraw their authorisation for this information at any time.
- Clipboard
Purpose of clipboard data collection:
We collect and analyse users’ clipboard data in our application and use it only in specific credit assessment and fraud risk management scenarios. Specifically:
- Fraud risk management in credit evaluation: We read and analyse a user’s clipboard data only when our risk control system detects that the user may be a potential fraud risk, as a means of further confirmation and analysis. This action is intended to verify the legitimacy of the user’s behaviour and to protect the safety of other users and the platform.
- Data minimisation and legality: We strictly follow the principle of data minimisation and only collect and analyse clipboard data when necessary. We do not collect such data on an unwarranted or continuous basis and do not use or store any information that is not relevant for credit assessment.
User Information and Consent: At application launch, we explicitly inform users that their clipboard data may be read under certain circumstances and explain how this data may be used for fraud risk management. Clipboard data is only collected and analysed when the user is fully aware of and has consented to this action.
Data Security and User Control: Clipboard data is collected and transmitted using strict encryption measures to ensure the security of user data. No sensitive information is stored and users can choose to revoke authorisation or restrict access at any time.
Compliance: We operate in full compliance with Google’s Privacy Policy and Developer Agreement and in accordance with international data protection regulations, including the GDPR. We ensure that all data processing operations in the app comply with the principle of transparency and provide users with a clear explanation of our privacy policy.
- Location
Purpose and Use of Location Information Collection:
We collect approximate location information (both longitude and latitude) from users in our application for only two main purposes:
- Preventing illegal offshore visits: By collecting location information from our users, we are able to detect and block access from illegal or unauthorised offshore sources. This helps to secure user accounts and prevent potentially malicious activity.
- Compliance with Anti-Money Laundering (AML) requirements: In accordance with relevant international and Ugandan laws and regulations, we are obliged to monitor and prevent behaviour that may involve money laundering or other illegal financial activities. The collection of user location information helps us to ensure the legality and compliance of transactions and account activities.
User Knowledge and Consent: We clearly inform users at application launch of the purpose for which we will collect their general location information and explain in detail how this information will be used to prevent illegal offshore access and to comply with anti-money laundering requirements. We collect data only after the user has given their fully informed, opt-in consent.
Data Minimisation and Security: We only collect location information that is necessary in relation to the above purposes and ensure that no personal data is stored or processed that is unrelated to these purposes. All location data is processed using encryption technology to ensure its security and confidentiality.
User Controls and Compliance: Users can choose to turn off location permissions or restrict the app’s access to their location information at any time. We are committed to fully complying with Google’s Privacy Policy, Developer Agreement, and relevant international data protection regulations, including GDPR.
- Calendar
Purpose and use of calendar information collection:
We request access to a user’s calendar permissions in our application for one key purpose:
- Reminders & Credit Management: We use calendar permissions to help users receive important repayment reminders at the right time to ensure they don’t miss a repayment date due to forgetfulness. With this feature, we want to help users maintain a good credit history and avoid the adverse credit implications of not making timely repayments. This feature is crucial to users’ financial management and credit health.
User Information and Consent: We clearly inform users when they install the app that we will be requesting access to the calendar and explain in detail exactly what this access will be used for. Access to calendar data is granted only with the user’s full knowledge and consent.
Data Minimisation and Security: We only access specific calendar entries related to repayment reminders and all data is encrypted to ensure that user privacy is not violated. We do not use this data for any other purpose, nor do we store it on our servers.
User control and compliance: Users can manage or revoke their authorisation of calendar permissions at any time. We strictly adhere to Google’s Privacy Policy, Developer Agreement, and international data protection regulations, including the GDPR, to ensure that all operations meet the highest standards of privacy protection.
By using our products/services, you consent to the collection and use of your information according to this privacy policy. If you have any questions or concerns, please contact our customer service team.
- Device
Purpose of collecting device hardware information:
We collect hardware information about user devices in our application for several key purposes:
- Device identification and security: By collecting device model numbers, operating system versions, and unique device identifiers (e.g., IMEI, MEID), we are able to better identify each device. This is critical to preventing fraud and ensuring the security of user accounts.
- Performance Optimisation: We collect device screen size, resolution, processor information, and storage space information in order to optimise the performance of the application’s user interface and functionality to provide a smoother user experience.
- Battery Management: Collecting battery information helps us adjust the performance of the app when the user’s device is low on power to reduce battery consumption and extend the life of the device.
User Knowledge and Consent: We clearly inform users at the time of application installation of the specific purposes for which information about their device hardware will be collected. We collect this information only with the full knowledge and consent of the user.
Data Minimisation and Security: We only collect information about the hardware that is necessary to fulfil the purposes described above and ensure that all data is protected by encryption technology to prevent data leakage or misuse. We undertake not to use this data for other unauthorised purposes.
User Controls and Compliance: Users can manage or revoke their authorisation to collect hardware information at any time. We strictly adhere to Google’s Privacy Policy, Developer Agreement, and international data protection regulations, including the GDPR, to ensure that all data processing activities meet the highest standards of privacy protection.
- Installed apps
Purpose of collecting information about installed applications:
We collect information about users’ installed applications in our applications for the following key purposes:
- Credit assessment and risk control: By analysing information about a user’s installed applications, we are able to better understand the user’s consumption behaviour and usage habits, and thus more accurately assess his or her credit risk. This helps us provide more personalised and reliable financial services in the credit decision-making process.
- Fraud Detection and Protection: Collecting information on installed applications helps us to identify potential malware or fraudulent applications, thereby protecting the security of user accounts and preventing unauthorised access and operations.
User Knowledge and Consent: At application launch, we clearly inform users that we will collect information about their installed applications and explain in detail how this data will be used for credit assessment and fraud detection. Users are fully informed that we will only collect such data if they have given their authorised consent.
Data Minimisation and Security: We strictly follow the principle of data minimisation and only collect information about applications that are directly relevant to credit assessment and fraud detection. All data collected is encrypted to ensure its security and confidentiality and will not be used for other unauthorised purposes.
User Controls and Compliance: Users can manage or withdraw their authorisation for the collection of application information at any time. We are committed to fully complying with Google’s Privacy Policy, Developer Agreement, and relevant data protection laws and regulations, such as GDPR.
1.8 Improving Ezee Loan Loan Platform Products/Services
(1) We may conduct de-identified research, statistical analysis, and predictions on the collected information to improve the content and layout of the Ezee Loan loan platform, support product or service for business decisions, and enhance our products and services.
(2) We may use your order data for data analysis to understand your location, preferences, and demographic information, or to match it with data from other sources (including third parties) to develop and improve our products and services.
(3) We may invite you to participate in market surveys through the contact information you provide. Based on the information you provide in the market surveys, we will analyze and measure your interest in our products, services, and website, thereby developing and improving our products and services. If you choose not to participate in market surveys and provide relevant information (based on the specific market survey display page), it will not affect your use of the basic functions of the Ezee Loan loan platform.
1.9 Special Instructions on Collecting and Using Your Personal Information
(1) If the information you provide contains personal information of other users, for example, when you order products/services for others through the Ezee Loan loan platform, you need to submit the personal information of the actual orderer, or if the information you actively upload through the Ezee Loan loan platform involves the personal information of other users, you must ensure that you have obtained their consent and that they are aware of and accept this policy before providing such personal information to the Ezee Loan loan platform. If it involves the personal information of children, you need to obtain the consent of the corresponding child’s guardian in advance. Unless it meets the exceptions for obtaining authorized consent (see “I. How We Collect and Use Your Personal Information” in this policy), we will process sensitive personal information in certain scenarios in accordance with legal regulations and national standards, and obtain your separate consent through reasonable means. The specific method of separate consent will be displayed on the specific functional page.
(2) If we use the information for purposes not specified in this policy, or if we use the information collected for a specific purpose for other purposes, we will obtain your authorized consent again.
(3) With your consent, we may also obtain your personal information from affiliates, partners, credit agencies, and other third parties that legally hold your relevant information for the purposes of real-name management, security protection, and credit evaluation services. Since different products or services require different personal information, we will obtain your consent through page prompts, interactive processes, etc., before you use specific products or services. The scope of personal information obtained will be based on the specific product or service agreement or rules you agree to. For example, when you apply for a credit loan with our affiliates or business partners, our affiliates or business partners will pass your loan amount, interest rate, and approval progress to us so that we can promptly display the basic loan situation to you. We will require third parties to explain the source of your personal information before collecting it and confirm the legality and compliance of the source of such personal information. We will also understand the scope of authorization consent for the personal information collected by the third parties. If the purpose of collecting and using your information exceeds the scope of authorization obtained by the third parties, we will obtain your consent again before processing your personal information. As our products and services are continuously updated, if a product or service is not specified in the aforementioned content but collects your information, we will explain the information collection content separately through page prompts, interactive processes, website announcements, etc., to obtain your consent. This information is subject to the terms of this privacy policy.
(4) Exceptions to Authorized Consent
You fully understand that, according to legal requirements, we do not need to obtain your authorized consent for the collection and use of your personal information in the following situations:
- Necessary for the performance of Ezee Loan’s statutory duties or obligations;
- Related to national security or national defense security;
- Related to public safety, public health, or significant public interests;
- Related to criminal investigations, prosecutions, trials, and enforcement of judgments;
- Necessary for the conclusion or performance of a contract to which you are a party;
- In emergency situations, necessary for protecting the life, health, and property of you or other individuals;
- Personal information that is disclosed by the personal information subject to the public or other legally disclosed personal information;
- Personal information collected from legally disclosed information, such as legal news reports, government information disclosures, etc.;
- For public interest purposes such as news reporting and public opinion supervision, processing personal information within a reasonable scope;
- Necessary for maintaining the safe and stable operation of the products or services provided, such as detecting and handling product or service failures;
- Necessary for academic research institutions to conduct statistical or academic research based on public interests, and when providing academic research or descriptive results to the public, the personal information contained in the results is de-identified;
- Other circumstances stipulated by laws, regulations, and national standards.
Please be aware that according to applicable laws, if we take technical measures and other necessary measures to process personal information so that the data recipient cannot re-identify a specific individual and cannot restore it, the use of such processed data does not require further notification and consent from you.
This privacy policy only applies to situations where we need to process your personal information to provide you with Ezee Loan loan APP products and services.
2. How We Use Cookies and Similar Technologies
(1) To ensure you can normally use our services or receive higher quality services, we will store small data files called Cookies on your device. When users visit a site that requires login for access to information or services, we will encrypt and store the user’s login name in the Cookie file on the user’s device. Since this is irreversible encrypted storage, even if others can use the user’s computer, they cannot identify the user’s username and password. Users do not need to do any extra work; all collection and storage are done automatically by the system. We will not use cookies for any purposes other than those described in this privacy policy.
(2) You have the right to accept or reject Cookies. If your browser automatically accepts Cookies, you can modify your browser settings to reject Cookies according to your needs. Please note that if you choose to reject cookies, you may not be able to fully use the services we provide to you.
(3) In addition to Cookies, we also use pixel tag technology on our website to monitor the effectiveness of ad placements. With pixel tags, we can better understand whether our ads have been viewed by users.
3. How We Share, Transfer, Entrust Processing, and Disclose Your Personal Information
3.1 Sharing and Provision
3.1.1 Processing Principles
We may share your order information, account information, and device information with third parties such as partners to ensure the smooth completion of the services we provide. However, we will only share your personal information for lawful, legitimate, necessary, specific, honest, and clear purposes, and will only share the personal information necessary for providing the service. We will evaluate the legality, legitimacy, and necessity of the third parties’ collection of your personal information, and require third parties to process your personal information within the scope of your authorization, taking necessary information management measures and technical means to prevent leakage, damage, loss, or tampering of your personal information. Third parties are not allowed to use the shared personal information for any other purposes; if they wish to change the purpose or method of processing personal information, they must obtain your renewed consent.
3.1.2 Separate Consent
Unless it falls under the exceptions for obtaining authorization (see “How We Collect and Use Your Personal Information” in this policy), we will, in accordance with legal regulations and national standards, obtain your separate consent for sharing and provision of personal information in scenarios other than those mentioned above. Regardless of whether separate consent is required, we will reasonably inform you about the third-party suppliers providing the products/services involved and the purposes, methods, and categories of processing your personal information. The specific form of separate consent will be as displayed on the service page.
3.1.3 Our Partners Include the Following Types:
(1) Financial Institutions and Third-party Payment Institutions: When you generate a loan order or apply for a refund, we will share specific order information with financial institutions or third-party payment institutions. If we deem it necessary for fraud detection and prevention, we will further share other necessary information, such as IP addresses, with relevant financial institutions. When you use our credit products, we will share your identity information, contact details, bank account information, and other information required to meet the risk control requirements of partner financial institutions to provide the services you need. Before using such services, we will separately inform you of the relevant personal information sharing rules and obtain your consent through page prompts, interaction processes, or online agreements.
(2) Business Partners: We may share necessary personal information with partners to provide you with products or services, including courier services, communication services, customer service, marketing, advertising, technical services, real-name authentication services, consulting services, etc. For example, to provide you with better services, we may entrust advertising service partners with handling information related to ad coverage and effectiveness (such as unique device identifiers), but will not provide your personal identity information, or we will anonymize the information so that it does not identify you personally. These partners may combine this information with other legally obtained data to perform the advertising services we commissioned. To provide you with service information or commercial information pushes, we may provide your phone number and proposed push content to SMS service providers; of course, you can set to turn off commercial information push functions, and we will stop sending commercial information to you once the function is turned off.
(3) Affiliated Companies: We may share necessary personal information with our affiliated companies to provide you with travel-related or other products or services. They will take protection measures that are no less strict than those in this policy. Please note that for the purpose of preventing and detecting fraud, we may also cautiously provide necessary personal information to business partners and affiliated companies. This information sharing will undergo strict internal security assessments and approvals, and the use of this information will be limited by signing relevant agreements.
3.2 Information Transfer
We will not transfer your personal information to any company, organization, or individual except in the following cases:
(1) With your explicit consent or authorization in advance;
(2) As required by applicable laws, regulations, legal procedures, or mandatory administrative or judicial requirements;
(3) In the event of mergers, splits, acquisitions, asset transfers, or similar transactions involving personal information transfer, we will inform you of the name and contact details of the receiving company or organization before the formal transfer of information and require the new holder of your personal information to continue to be bound by this policy and to continue to fulfill the personal information processing obligations originally undertaken by us. Otherwise, we will require the company or organization to seek your authorization again.
3.3 Public Disclosure
We will only disclose your personal information under the following circumstances:
(1) At your request, with your separate consent, and according to the disclosure method you approve, disclose the personal information you designate;
(2) As required by laws, regulations, mandatory administrative enforcement, or judicial requirements, we may disclose your personal information according to the type and method of disclosure required. In compliance with laws and regulations, when we receive such disclosure requests, we will require the provision of corresponding legal documents, such as subpoenas or investigation letters.
4. How We Store Your Personal Information
4.1 Storage Principles
We do not transfer your personal information to any company, organization, or individual except in the following cases:
(1) With your explicit consent, we transfer your personal information to others;
(2) As required by applicable laws, regulations, legal procedures, or mandatory administrative or judicial requirements;
(3) In the case of mergers, acquisitions, or bankruptcy liquidation, if personal information transfer is involved, we will require the new company or organization holding your personal information to continue to comply with this policy, or we will require that company or organization to seek your authorization again.
4.2 Storage Duration
We retain your information only for the period necessary for the purposes described in this policy and for the minimum duration (90 days), or within the time limits required by laws and regulations.
For example, when you use the registration function on the Ezee Loan lending platform, we need to collect your phone number and retain it while you use the function to provide you with normal service, ensure the security of your account and system. After the above storage period has elapsed, or if you exercise your right to delete personal information or cancel your account, we will delete or anonymize your personal information.
However, in the following cases, we may adjust the storage time of personal information to comply with legal requirements:
(1) To comply with applicable laws and regulations;
(2) To comply with court judgments, rulings, or other legal procedures;
(3) To comply with the requirements of relevant government agencies or legally authorized organizations;
(4) For maintaining public interest, and protecting the personal and property safety or other legal rights of Ezee Loan platform users, our company, our affiliated companies, other users, or employees.
4.3 Termination of Operations
If we cease operation of the Ezee Loan lending platform products or services, we will promptly stop the collection of your personal information. We will notify you of the cessation of operations either individually or through announcements and will delete or anonymize the personal information we hold.
5. How We Protect Your Personal Information Security
5.1 Security Measures
We have implemented industry-standard security measures to protect the personal information you provide from unauthorized access, disclosure, use, modification, damage, or loss. We take all reasonable and feasible measures to safeguard your personal information, including but not limited to:
(1) Encryption Technology: When storing your information, we use encryption technology to ensure the confidentiality of the data and employ trusted protection mechanisms to prevent malicious attacks;
(2) Data Security in Use: When using your personal information, such as displaying it to you, assessing and analyzing it, or during internal data transfers, we use methods like content replacement and anonymization to enhance security;
(3) Data Encryption: When sharing your personal information externally, such as identity or bank card information, we use various data desensitization techniques for encryption based on the specific data being protected;
(4) Special Security Measures: Given the specific requirements for personal information security in the financial services sector, we ensure the safety of transactions and personal information through comprehensive security management, policies, processes, and network architecture.
5.2 Security Protocols
(1) Access Control: We implement access control mechanisms to ensure that only authorized personnel can access personal information and that they have signed confidentiality agreements;
(2) Monitoring and Logging: We strictly monitor processes and retain data access logs or other technical records for a reasonable period to track internal information security;
(3) Training and Audits: We conduct security and privacy protection training courses to enhance employees’ awareness of the importance of personal information protection and perform personal information security audits;
(4) Code and Log Analysis: We use code security checks and data access log analysis techniques for personal information security audits;
(5) Information Minimization: We take all reasonable and feasible measures to ensure that we do not collect irrelevant personal information. We retain your personal information only for the duration necessary to achieve the purposes described in this privacy policy, unless a longer retention period is required or permitted by law.
5.3 Incident Handling
In the event of a personal information security incident, we will handle it in accordance with legal requirements and follow these rules:
(1) Notification: We will promptly inform you of the basic situation and possible impact of the security incident, the measures we have taken or will take, suggestions for mitigating and reducing risks on your own, and any remedial actions;
(2) Communication: We will notify you of the incident details via email, letter, phone, push notifications, or other means. If it is difficult to individually inform all data subjects, we will use reasonable and effective methods to publish a notice;
(3) Reporting: We will also report the handling of the personal information security incident to the regulatory authorities as required;
(4) Service Termination: If we terminate services or operations, we will notify you at least thirty days in advance through an announcement and delete or anonymize your personal information after the termination of services or operations;
(5) Legal Liability: If your legal rights are harmed, we will assume corresponding legal responsibilities.
6. How We Protect the Personal Information of Minors
Ezee Loan is committed to protecting the personal information of minors. If you are under 18 years old, we will not provide our services to you. If a minor is found to have registered and used our services without parental consent, the guardian can contact our customer service at 0707746943, and we will promptly delete the minor’s personal information upon verification. For any questions, suggestions, or complaints regarding the personal information of minors, please reach out to us using the contact details provided in the “How to Contact Us” section of this policy.
7. Your Personal Information Rights
In accordance with relevant laws and regulations in Uganda, we guarantee your rights to your personal information, including the following:
7.1 Access and Query Your Personal Information
You have the right to access your personal information, except in cases where exceptions are provided by law. If you wish to exercise your right to access, you can do so by:
- Accessing and viewing your account’s billing information by following the path “【Homepage】—【Billing】.“
7.2 Correct Your Personal Information
If you find any errors in the personal information we process about you, you have the right to correct it. You can contact us via customer service 0707746943, and we will verify and process your request within fifteen working days.
7.3 Change the Scope of Your Authorization or Withdraw Your Authorization
You can change the scope of your authorization for us to continue collecting your personal information by disabling certain device functions (such as SMS, contacts) through the following path: “【Homepage】—【Profile】—【Settings】—【Privacy Settings】—【Permission Management】.” You can also withdraw your authorization by canceling specific products or your Ezee Loan loan account. Please understand that each business function requires some basic personal information to be completed. After withdrawing authorization, we will not be able to continue providing the corresponding services. However, your decision to withdraw authorization will not affect previous personal information processing based on your authorization. If the services you use are not yet concluded, such as an outstanding loan, you may not be able to withdraw your authorization until the service ends.
7.4 Delete Your Personal Information
(1) If you need to change your bank card information, you can contact us via customer service 0707746943 to correct it.
(2) You can request the deletion of your personal information by contacting customer service if:
- Our processing of personal information violates laws and regulations;
- We collect or use your personal information without your consent;
- Our processing of personal information violates our agreement with you;
- You no longer use our products or services, or you have canceled your account;
- We terminate services and operations.
If we decide to respond to your deletion request, we will also notify the entities that have obtained your personal information from us to delete it unless otherwise provided by laws and regulations or authorized independently by you. Once you delete information from our services, it may not be immediately removed from backup systems, but it will be deleted during backup updates.
7.5 Cancel Your Ezee Loan Loan Account
You can cancel your account through the Ezee Loan loan app by following the path “【Homepage】—【My】—【Account and Security】—【Account Closure】” or by contacting customer service. We will verify and process your request within fifteen working days. After canceling your account, we will delete or anonymize your personal information, except for information that must be retained according to laws, regulations, or regulatory requirements. During the period of service use, we will continue to store and process information as required by law and cooperate with authorized bodies for inquiries.
7.6 Unsubscribe from Service Notifications
(1) To keep you informed about the status of Ezee Loan loan services, we will send you service reminders. You can unsubscribe by contacting customer service. For security and credit protection purposes, business notification messages cannot be unsubscribed.
(2) We may comprehensively analyze and process your information to improve our service quality and provide you with better services, or to help us evaluate, improve, or design products, services, and marketing activities. We may send you marketing notifications, commercial electronic information, or advertisements. If you do not wish to receive such information, you can unsubscribe by contacting customer service.
(3) In certain business functions, after notifying you and obtaining your consent, we may make decisions based solely on automated decision-making mechanisms, including information systems and algorithms. If you believe these decisions significantly affect your legitimate rights and interests, you have the right to raise your concerns through the contact methods provided in section 9 of this policy. We will respond to your request within fifteen working days.
7.7 Obtain a Copy of Your Personal Information
If you need a copy of your personal information, you can contact us through the contact methods provided in section 9 of this policy. After verifying your identity, we will provide you with a copy of your personal information in our services (including basic information and identity information), unless otherwise provided by laws and regulations or this policy.
7.8 Transfer of Personal Information
If you need to transfer your personal information to a designated personal information processor, you can contact us through the contact methods provided in section 9 of this policy. After verifying your identity, if the transfer meets the conditions specified by the national cybersecurity authorities, we will provide a means for transferring your personal information. We will also take necessary information management measures and technical means to ensure the safety of the transfer process, preventing leaks, damage, loss, or alteration of your personal information.
7.9 Responding to Your Requests
For any inquiries, suggestions, opinions, and complaints, you can contact our customer service through the customer hotline 0707746943. We will process your request after necessary identity verification, and the verification and processing will be completed within fifteen working days at the latest. For reasonable requests, we generally do not charge fees. However, according to relevant laws, regulations, and national standards, we will not be able to respond to your request in the following situations:
(1) Related to national security and defense security;
(2) Related to public safety, public health, and major public interests;
(3) Related to criminal investigations, prosecutions, trials, and judgments;
(4) There is sufficient evidence that you have subjective malice or abuse of rights;
(5) For the protection of your or other individuals’ life, property, and other significant legitimate rights and interests where it is difficult to obtain your consent;
(6) Responding to your request will cause serious damage to the legitimate rights and interests of other personal information subjects or individuals and organizations;
(7) Involving commercial secrets.
7.10 Your Right to Know
You have the right to know how your personal data is being shared. We will notify you in the following situations:
- Prior Notification: We will notify you in advance and obtain your consent before sharing your data with new types of third parties or using your data in new ways.
- Privacy Policy Update: If there are significant changes in our data-sharing practices, we will update this privacy policy and notify you through our app or other appropriate means.
7.11 Exercising Your Right to Refuse
You have the right to refuse the following processing activities of your personal data:
- Targeted Advertising: If you do not wish for your data to be used for targeted advertising, you can opt-out by contacting us.
- Data Sharing: You can refuse us from sharing your personal data with certain third parties, unless such sharing is necessary to provide services or required by law.
Methods to Exercise the Right to Refuse:
- By Email: You can send an email to ezeeloan20@gmail.com specifying the data processing activities you wish to refuse.
- By Phone: You can contact our customer support team by calling 0707746943 to submit your refusal request.
Commitment to non-malicious software
We prioritize your privacy and data security, and we want to assure you that our app is safe and free from malicious activities. Our app adheres to the following principles:
- No Data Collection Without Consent: We do not collect or store any personal data without your explicit permission.
- No Unauthorized Data Sharing: We do not sell, rent, or share your personal data with any third parties without your consent.
- No Malicious Activity: Our app does not engage in any harmful activities, including data theft, device damage, or displaying malicious ads.
We are dedicated to upholding the highest standards of security and privacy, ensuring you have a safe and trustworthy experience with our app.
9. How This Privacy Policy Is Updated
We may update this Privacy Policy as necessary. Please be aware that we may revise this policy periodically, and we will indicate the date of the latest update and make it effective following a public announcement. We will not reduce your rights under this policy without your explicit consent. For significant changes, we will provide more prominent notices, including email notifications detailing specific changes to the privacy policy for certain services. We recommend that you review this policy regularly to stay informed about the latest version.
Significant changes covered by this policy include, but are not limited to:
- Major changes to our service model, such as alterations to the purposes for which personal information is processed, the types of personal information collected, and how it is used.
- Substantial changes to our organizational structure, such as business adjustments, bankruptcy, mergers, or acquisitions that result in a change of ownership.
- Modifications in the primary recipients of personal information, including changes in sharing, transferring, or publicly disclosing personal information.
- Significant alterations to your rights and the methods by which you can exercise them concerning personal information processing.
- Changes in the department responsible for personal information security, including updates to contact information and complaint channels.
- High-risk findings from personal information security impact assessments.
10. How to Contact Us
If you have any questions, complaints, or comments about this policy or the handling of your personal information, please reach out to us through our customer hotline or by emailing our customer service team. We will review and address your concerns within fifteen business days.
Company: TERAVIK CASHPOINT SMC LTD
Address: PLOT 22,ENTEBBE RD,2ND FLOOR SUITE, KAJJANSI,JKALANZI
COMPLEX,P.O.BOX 980151,KAJJANSI
Customer Hotline:0707746943
Customer Service Email:ezeeloan20@gmail.com
Please feel free to reach out to us with any concerns or inquiries. We are here to help and ensure that your personal information is handled securely and appropriately.