Cashpal

Privacy Policy

1.Scope and Purpose

This privacy policy applies to all services and features provided by our company and its product Cashpal, including any personal information you provide or that is generated while using this application. The purpose of this policy is to ensure that, in the process of collecting, using, and handling your personal data, we comply with relevant laws and regulations applicable in Ghana and safeguard your privacy and data security.

We are committed to processing your personal information in a lawful, fair, and transparent manner, in accordance with the terms of this privacy policy and applicable privacy protection laws and regulations, ensuring that your privacy is respected and protected.

2. Access to Sensitive Data and Permissions

When you use the Cashpal application, We may request access to certain sensitive permissions on your device to collect relevant information and upload it to our servers for credit evaluation. This is to ensure the proper functioning of our services and enhance your user experience. The permissions we may request and their descriptions are as follows.

Phone:

Upon your authorization, we may request access to phone status information to collect device-specific data, such as the brand, model, and system version. Additionally, we may collect other device-related information, such as battery level, IMEI, and MAC address. This information helps us verify your identity, prevent unauthorized account access, and optimize our service to ensure compatibility with a broader range of devices.

SMS:

We will request access to your SMS permissions upon your explicit consent. We have a filter to collect your SMS messages to identify financial transactions or information. Only the related SMS sender, content, and timestamp will be collected and uploaded to our server https://app-tz.mbcashpal.com. This data helps us assess your financial capacity and determine your eligibility for our loan services. You may choose to decline this permission, but doing so may affect your credit evaluation results. We guarantee that your SMS messages will only be used for credit analysis purposes and will not be shared or used for any other purposes.

Location:

With your authorization, we will collect your IP address to verify that your location is within our service area and to ensure account security, preventing unauthorized use of your information.

Calendar:

We will request access to your calendar permission upon your explicit consent to remind you of upcoming loan due dates, helping you avoid late payments that could negatively impact your credit score.

App List:

We may access and collect your list of installed apps to assess whether any potentially harmful or unauthorized applications are installed that could compromise your financial security. We will only collect the names, version numbers, and installation dates of the apps.

App Usage:

We will request access to your app usage access permission upon your explicit consent. We may collect data such as your last app launch time, total usage duration, foreground and background status, and app installation and uninstallation to assess your credit risk and recommend an appropriate credit limit. In addition, it will help prevent fraudulent activities. You can revoke this permission at any time ("Settings" → "Apps" → "Special App Access" → "Usage Access", selecting this app, and disabling the permission), but doing so may affect your credit evaluation results. We guarantee that app usage data will only be used for credit analysis purposes and will not be shared or used for any other purposes.

All data will be encrypted and securely uploaded to our server https://app-tz.mbcashpal.com. We will only collect and use these sensitive permissions with your explicit consent and solely for the purposes mentioned above. You can manage or revoke these permissions at any time through your device settings.

3. Categories of Data Collected

When you use the Cashpal application, We may collect and process the following categories of personal data. The collection of this data is aimed at gaining a comprehensive understanding of our users' financial status, conducting credit risk assessments, and ensuring that we provide you with appropriate financial services:

3.1.Identity Information:

This includes your name, identification number, gender, and date of birth. This information is necessary for user identity verification, ensuring compliance, and preventing fraudulent activities. By accurately verifying your identity, we can ensure that only legitimate users access our services and effectively prevent identity theft.

3.2.Contact Information:

This includes your phone number, email address, and residential address. We also collect 2 emergency contacts including relationship, phone number and contact name. This information is used to maintain timely communication with you, send loan-related notifications, repayment reminders, service updates, and other necessary communications. This helps to maintain effective communication between you and us, ensuring that you receive important service-related information in a timely manner.

3.3.Employment Information:

This includes your employment status, years of employment, and income level. This data is used to assess your financial capability, helping us better understand the stability and source of your income. Such information is critical for conducting credit assessments and determining your borrowing capacity, enabling us to offer more suitable loan products and repayment plans.

3.4.Household Information:

This includes your marital status and the number of family members. This information helps assess your financial responsibilities and stability. Marital status and family structure directly impact an individual's financial obligations, and understanding this allows us to more accurately evaluate your financial situation and risk profile, thus providing more personalized and appropriate lending solutions.

All data collected is strictly protected and will be used lawfully in accordance with applicable laws and regulations to ensure the privacy and security of your information.

4. Legal Basis and Purposes of Processing

We collects and processes your personal data based on the following legal grounds, in accordance with applicable laws and regulations:

Contractual Performance: We process your personal data to fulfill the contractual relationship between you and us, particularly in the provision of financial services. We need to collect and process your identity, contact, and financial information in order to provide loan services and ensure the smooth processing of repayments.

Legitimate Interests: In certain cases, we process your personal data to protect our legitimate interests. This includes preventing fraudulent activities, ensuring the security of our services, assessing credit risk, and improving our products and services. We ensure that such processing does not unnecessarily affect your fundamental rights and freedoms.

Legal Obligations: In some instances, we are required to process your personal data to comply with legal obligations. This may include adherence to anti-money laundering regulations, tax reporting requirements, or other regulatory obligations.

Consent: In specific cases, we process your personal data based on your explicit consent, such as when you authorize us to access sensitive permissions on your device or process certain sensitive data. You have the right to withdraw your consent at any time, but this will not affect the lawfulness of processing based on consent before its withdrawal.

The purposes of processing your personal data are to provide you with secure and compliant financial services, conduct credit risk assessments, verify your identity, and ensure the security and reliability of our services. We may also use this data to improve our products and user experience.

5. Disclosure of Personal Data

We are committed to disclosing your personal data only when it is lawful and necessary to ensure the smooth operation of our services. We may share your personal data with third parties that provide services on our behalf, such as payment processors, credit assessment agencies, and cloud storage providers. These third parties will only have access to your data to the extent necessary to provide their services, and we ensure that they comply with applicable privacy laws and implement necessary security measures to protect your information.

In certain instances, we may be required by law to disclose your personal data to law enforcement agencies, regulatory authorities, or other government bodies. For example, when complying with anti-money laundering regulations or tax reporting obligations, we are obligated to provide relevant information. Additionally, to prevent fraudulent activities and ensure system security, we may share information with partners involved in risk management and security assessments.

If we undergoes corporate restructuring, merger, acquisition, or sale of assets, your personal data may be transferred as part of that transaction. In such cases, we will take appropriate measures to ensure the protection of your privacy rights and notify you before any data transfer takes place.

We will only disclose your personal data when it is necessary, based on legal obligations, legitimate interests, or with your explicit consent. We do not sell or rent your personal data to any third parties.

6. Data Retention and Security Measures

We retains your personal data in accordance with applicable laws, regulations, and our business needs. We will only retain your personal information for as long as it is necessary to fulfill the purposes for which it was collected or to comply with legal obligations. Once these purposes have been fulfilled or the maximum retention period allowed by law has been reached, we will securely delete or anonymize your personal data unless we are required by law or have a legitimate reason to retain it.

To ensure the security of your personal data, we implement strict technical and organizational measures to prevent unauthorized access, loss, alteration, or disclosure. These security measures include, but are not limited to, data encryption, access controls, firewalls, and regular security audits. Additionally, our systems and servers are housed in secure facilities that comply with industry standards and are continuously monitored by professional personnel to maintain their security.

While we employ industry-standard security measures, no system is completely free of risk. Therefore, we encourage you to take necessary precautions to protect your account information, such as using strong passwords and avoiding the disclosure of sensitive information on public networks.

We are committed to continuously updating and improving our security measures to address new threats and challenges, ensuring that your data is fully protected within our systems.

7. Rights of Data Subjects

We respects your privacy and ensures that you have the following rights regarding your personal data:

Right of Access:

You have the right to request access to the personal data we hold about you and obtain a copy of this data. We will provide the relevant information as required by law to ensure transparency.

Right to Rectification:

If your personal data is inaccurate or incomplete, you have the right to request that we correct or update it. We encourage you to keep your personal information accurate to ensure that our services accurately reflect your needs.

Right to Erasure:

In certain circumstances, you can request that we delete your personal data, such as when the data is no longer necessary for the purposes for which it was collected or when you withdraw your consent. We will process your request in accordance with legal requirements, unless we are legally obligated to retain the data.

Right to Restrict Processing:

Under certain conditions, you have the right to request that we restrict the processing of your personal data, for instance, if you contest the accuracy of the data or object to how it is being processed.

Right to Data Portability:

You have the right to request that we provide the personal data you have supplied to us in a structured, commonly used format, or that we transfer this data directly to another data controller, where applicable.

Right to Object:

You have the right to object to the processing of your personal data for specific reasons, particularly if the processing is based on legitimate interests or for direct marketing purposes. If you object, we will stop processing your data unless we have compelling legal grounds to continue.

Right to Withdraw Consent:

If we process your personal data based on your consent, you have the right to withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of processing based on consent before its withdrawal.

If you wish to exercise any of these rights or have any questions regarding the processing of your personal data, you may contact us at any time. We will respond to your request within a reasonable timeframe and take appropriate actions in accordance with applicable laws and regulations.

8. Use of Third-Party Services and Processors

In providing the Cashpal application, We may rely on third-party service providers or data processors to assist us in processing your personal data and delivering our services. These third parties include payment processors, credit assessment agencies, cloud storage services, and technical support providers. Additionally, we have integrated Google’s Advertising ID and Adjust to optimize ad targeting, analyze user behavior, and assess conversion rates.

Google’s Advertising ID is an anonymous identifier used to track ad performance and conduct user behavior analysis, helping us deliver more personalized ad experiences to you. Users can manage or reset their Advertising ID through their device settings to ensure ads are tailored to their interests.

Adjust is a tool designed to analyze user conversions, enabling us to understand user behavior patterns, optimize ad campaigns, and enhance user experiences. Through Adjust, we collect and analyze user interaction data to ensure continuous improvement in our marketing strategies and service offerings.

We have entered into strict agreements with all third parties, ensuring they process your personal data only in accordance with our instructions and in compliance with relevant data privacy laws and regulations. These third parties will have access to user data only to the extent necessary to provide their services and are required to implement reasonable technical and organizational security measures to protect the integrity and confidentiality of the data.

We regularly review the security practices of these third-party service providers to ensure they take appropriate measures to safeguard your data and prevent unauthorized access, alteration, or loss.

We remains responsible for all third-party data processing activities, ensuring that they process your personal data in accordance with this privacy policy and applicable privacy laws.

9. Data Protection for Minors

We do not knowingly collect or process personal data from individuals under the age of 18. Our services are not intended for minors, and we require that users confirm their age during registration. If we become aware that we have inadvertently collected data from a minor, we will take immediate steps to delete the information. If you believe a minor has provided us with personal data, please contact us to ensure its removal.

10. Amendments to this Privacy Policy

We reserves the right to update or modify this privacy policy at any time. Any changes will be posted within the application or on our website, and, where appropriate, notified to you via other communication channels. We encourage you to review this policy periodically to stay informed about how we are protecting your personal data. Continued use of our services after any amendments constitutes your acceptance of the updated policy.

11. Contact Information

Email: helptz@mbcashpal.com

Website: https://www.mbcashpal.com