Privacy Policy

Thank you for using Flypesa. We are committed to protecting your personal privacy and data security. This Privacy Policy describes how we collect, use, disclose, process, and protect your personal information. Please read the following information carefully to understand our Privacy Policy.

By using Flypesa, you agree to the collection, use, disclosure, and processing of your personal information in accordance with this Privacy Policy. If you do not agree with this Privacy Policy, please do not use our services.

We may update this Privacy Policy from time to time in accordance with legal requirements and business needs. We will post updated versions on this page and recommend that you check back regularly. If we make significant changes to this Privacy Policy, we will notify you through appropriate means, such as by posting a notice on our website.

This Privacy Policy applies to all of our services and products, including websites, mobile applications, and other online or offline services.

1.Definitions

1.1 “Personal Information” refers to any information that can be used to identify an individual, either directly or indirectly.

1.2 “Affiliates” refers to any company or organization that is affiliated with our company.

2.Personal Information We Collect

2.1 Personal Information

Flypesa will collect some information from users, but all information will only be collected for the loan service.

• Your mobile phone number. Used to register for a Flypesa account and subsequent contact with you for our loan approval and recovery.

• Your personal information relating to you. Contains information such as gender, age, faith, and income, which is used for credit scoring and to confirm access to loan products.

• Your emergency contact. You agree that Flypesa can contact emergency contacts via SMS, or the information you filled in. With the emergency contact list you provide, Flypesa can make a legitimate loan approval or loan recovery if you can not be contacted in person.

• Your collection account information. So that once the loan is approved, you will receive the loan funds promptly.

2.2 Sensitive Information

Flypesa requires your consent to obtain the following sensitive information.

• Installed Applications. When you use the Application, we may collect and store information about third-party applications installed on your device. This information includes information such as the application name, version number and date of installation. We collect this information for the purpose of conducting your credit analysis and to ensure that there are no extraordinary applications installed on your device outside of the Google Play Store.

• Emergency Contact Information. When using the Application, you may be required to provide emergency contact information. This information may include the emergency contact’s name, phone number and relationship to you. We will strictly protect this information and only use it in an emergency or with your express consent.

• Location. Flypesa requests location access to obtain the user’s actual location, which will be used for anti-fraud investigations.

• Phone. Flypesa requests phone access to collect information about the device (such as hardware model, operating system and version, unique device identifier, user profile information, Wi-Fi information, mobile network information, etc.), which will be used for anti-fraud and credit investigations.

• SMS. To ensure the safety and security of funds. Flypesa require SMS permissions (including the SMS subject, content, and whether it has been read) in order to appraise the user reputation and anti-fraud prevention analysis. We collect any of your SMS data, but only analyse your messages related to financial transactions. We understand that SMS messages can contain sensitive information and take our users’ privacy seriously. The collected SMS information will be encrypted and will never be disclosed or shared with any third party.

• Call log. Once you grant us permission to read the call logs, we will reach out to you via a voice call. The purpose of collecting call records is to verify whether you have installed our application and received our dynamic password verification on the same device. Specifically, we will verify your device through a phone call and check your call history to confirm if the call was answered. This helps enhance the reliability of your credit and enables quicker access to loan services. We assure you that we will not monitor, read, store, or share any private call data. Only with your explicit consent will we upload and transmit it to the Flypesa server (https://app.pesafly.com).

2.3 Other Information

• Information from external sources, such as credit bureaus and customer service providers, to help us make customer verification and credit-related decisions.

3.How We Use Your Personal Information

3.1 The information we collect shall be used to determine whether financial services or products are offered to customers, the amount of such risks and the terms and conditions applicable to such services or products.

3.2 We may also use a third-party payment service provider or payment processing company to process payments and repayments, transfer money to your operating account or any other user account, process other payments, and provide additional products and services, and therefore may disclose your information to such third-party payment service provider.

3.3 We use your information to power our services and improve your experience and interaction with Flypesa. We use your information to provide, support, improve, protect, analyze, and bill for our products and services; to communicate with you about your services, products or applications; to promote our products and services; to detect and avoid fraud; for advertising; and for research purposes. When you purchase products or services from us, sign up for our newsletters, respond to surveys or marketing newsletters, browse the website or Flypesa app. If you sign up for an online account with us, download and register on one of our apps or use certain other website features, we may use the information we collect from you in the following ways.

a. Personalize your experience so that we can provide the types of content and products you are most interested in.

b. Improve our website/application to serve you better.

c. Enables us to better serve you and respond to your customer service requirements.

d. Manage contests, promotions, surveys, or other site features.

e. Request ratings and reviews of services or products; and

f. Follow up after communication (live chat, email or phone inquiries).

3.4 This means we can:

a. Record details of the products and services you use or order from us.

b. Send you product or service information (We may send you information to confirm your order and inform you of any changes that may affect your service, such as when we have an infrastructure work plan or need to fix something).

c. Let’s you create and log in to an online account we run.

d. Charge you and ensure that your payment reaches us; and

e. Provide information to others (if we need to provide information for the products or services you ordered), or provide it to another communications provider, if you purchase some services from them and us.

3.5 In addition, we use the following information to provide products and services and to manage your account.

a. Your contact information and other information to confirm your identity and your communication with us. This includes your personal information and other relevant credentials.

b. Your payment and financial information.

c. Your communication with us, including emails, web chats and phone calls. We will also keep a record of any settings or communication preferences you choose; and

We need to obtain information from cookies placed on your connected device so that we can provide services.

3.6 We may disclose some or all of the data we collect from you when you download or use the Flypesa platform to connect to a mobile wallet provider, credit bureau or other partner financial institution. We may disclose your personal information to any member of our Group, which means our subsidiaries, our ultimate holding company and its subsidiaries.

3.7 We may disclose your personal information to any local or international law enforcement officer or competent regulatory or governmental agency and believe in good faith that such disclosure is reasonably necessary to enforce any of the terms and conditions and/or this Policy to assist in the prevention, detection, investigation or prosecution of criminal activity or fraud.

3.8 We will use your data to compile statistics relating to our user base or financial products or services and may disclose such information to any third party for such purposes, but such information will remain anonymous at all times.

3.9 We may use other third-party companies to analyse website traffic, and in some cases, these companies may store customer information. In the case of our use of other organizations, we still control your personal information, and we have strict control measures to ensure that it is properly protected.

3.10 We may also disclose or transfer your personal information to third parties under the following circumstances.

a. Flypesa involves a merger, bankruptcy, acquisition, restructuring, or sale of assets, in which case we may disclose your personal information to a potential seller or buyer of that business or asset.

b. Personal data held by Flypesa, or most of its assets, about its customers, will be one of the assets to be transferred when it is acquired by a third party.

c. Flypesa is responsible for disclosing or sharing your personal data in order to comply with any legal or regulatory obligations or requirements; or

d. To enforce our terms and conditions and other agreements, or to investigate potential breaches; to report defaulters to any credit agency, or to publish statistics related to the use of the Flypesa platform. In this case, all information will be aggregated and become anonymous.

4.How we share, transfer and publicly disclose your personal information

4.1 With any firm, organization, or person we use to help us operate our lending business, to collect payments and recover debts, or to provide a service on our behalf;

4.2 With any firm, organization, or person who provides us with products or services or to whom we provide products and services to;

4.3 With any person who has told us and who we reasonably believe to be your parent, carer, or helper, when the proof is presented that you are unable to handle your own affairs because of mental incapacity or other similar issues;

4.4 With any payment system we may use;

4.5 Certain authorities in order tonumberafestivitieserrorism (including authorities outside Uganda);

4.6 With any person to whom we sell or transfer (or enter into negotiations to sell or transfer) our business or any of our rights or obligations under any agreement we may have with you. If the transfer or sale goes ahead, the transfer or purchaser may use your rational information in the same way as us;

4.7 With regulatory agencies and government authorities (including but not limited to, the Bureau of Internal Revenue, the Natl Bureau of Investigation, the Office of the Ombudsman), including those overseas, where we are requested by them to do so;

4.8 With credit bureaus or any similar organization which provides a centralized application matching service that collects information from and about mortgage and/or credit applications, for the purpose of preventing and detecting fraud. We may also provide information to third parties to help them to make decisions about whether to lend to you, allow you extended payment terms or otherwise do business with you.

5.Cross-Border Transfer of Personal Information

Your Personal Information may be transferred to, stored, used and processed in a jurisdiction other than your home nation or otherwise in the country, state and city in which you are present while using any Service provided by us (“Alternate Country”), to companies Flypesa under Our group which are located outside of your home nation or Alternate Country and/or where Our Flypesa group’s servers and/or service providers and partners are located outside of your home nation or Alternate Country.

In such a case, we shall ensure that such personal information remains subject to a level of protection comparable to what is required under the Uganda Laws (and, in any event, in line with our commitments in this Privacy Policy).

You understand and hereby consent to the transfer of your Personal Information out of your home nation or Alternate Country as described herein.

6.Personal Information Retention

We will retain your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy or as required by law.

7.Access and Correction of Personal Information

You have the right to access, update, or correct your personal information. Please contact us to make such requests.

8.Where We Store Your Personal Information

8.1 The Personal Information that we collect from you may be stored at, transferred to, or processed by third party service providers. We will use all reasonable endeavours to ensure that all such third party service providers provide a level of protection that is comparable to our commitments under this Privacy Policy.

8.2 Your Personal Information may also be stored or processed outside of your country by personnel who work for us in other countries, or by our third party service providers, suppliers, contractors or affiliates, to the extent permitted under applicable law. In such a case, we will ensure that such personal information remains subject to a level of protection comparable to what is required under the laws of your country (and, in any event, in line with our commitments to this privacy policy).

9.Security of Your Personal Information

We take appropriate technical and organizational measures to protect your personal information from unauthorized access, use, disclosure, or destruction.

10.Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the updated policy on the App.

11.Language

This Privacy Policy is written in English. In case of any inconsistency between the English version and any translation, the English version shall prevail.

By using the App, you confirm that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described herein.

13.Marketing and Promotional Materials

By providing your personal information, you consent to receive marketing and promotional materials from us and our affiliates.

14.Third-Party Websites

14.1 The App and Website may contain links to websites that are operated by third parties. We do not control nor accept liability or responsibility for these websites and for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties. Please consult the terms and conditions and privacy policies of those third party websites to find out how they collect and use your Personal Information.

14.2 Advertisements contained on our App or Website operate as links to the advertiser’s website and as such any information they collect by virtue of your clicking on that link will be collected and used by the relevant advertiser in accordance with the privacy policy of that advertiser.

15.Liability and Limitation

Our liability for any breach of this Privacy Policy is limited to the extent permitted by law.

16.How to Contact Us

If you have any questions or concerns about this Privacy Policy or our privacy practices, please contact us at app-customer-service@pesafly.com or 0757760178.

Permissions

Phone Number

To ensure the security and convenience of logging into your account and managing your account, we need to obtain permission to use certain information from your phone. We need to access information from your device, such as the IMEI number, SIM number, and serial number. This information will be used to identify your device and ensure that it is you who is attempting to log into your account. Your phone number will be used to verify login and ensure it is not a virtual number. Your data will be encrypted and transmitted through HTTPS protocol to our dedicated server (https://app.pesafly.com).

SMS

Collection and Access: We need your consent for this license that allows us to collect and access your relevant SMS data information.

Purpose: We will only collect financial SMS messages relevant to credit assessment. We will not monitor, read, store, or share any financial personal data that is irrelevant to credit assessment. Doing so will help us correctly identify you and verify if you are eligible for our loan service risk assessment and make correct loan decisions, so as to better help you plan your budget and evaluate your payment capability.

Data Storage and Transmission: We will adhere to strict user data confidentiality policies and will not use your data for any other purposes or share it with third parties. Your data will be encrypted and transmitted through HTTPS protocol to our dedicated server (https://app.pesafly.com).

LOCATION

Collect information about the location of your device for customer risk assessment and scoring. We will upload location data to the server (https://app.pesafly.com) in a secure network environment.

MOBILE PHONE(DEVICE)

Collect specific information about your device including your device name, model,region and language settings, device identification code, device hardware and software information, status, usage habits, unique device identifiers like IMEI and serial number to uniquely identify the device and ensure that unauthorized devices are not to act on your behalf to prevent frauds. In addition, we will collect your installed application detailed list to assess your borrowing propensity and your debt situation. We will upload the collected data to the server (https://app.pesafly.com) in a secure network environment.

Call Logs

Collection and Access: We need your consent for this license that allows us to collect and access your relevant Call Log data information. We will collect data such as address book ID, call duration, dialed number, and contact number in the call log data.

Purpose: Once you grant us permission to read the call logs, we will reach out to you via a voice call.The purpose of collecting call records is to verify whether you have installed our application and received our dynamic password verification on the same device. Specifically, we will verify your device through a phone call and check your call history to confirm if the call was answered. This helps enhance the reliability of your credit and enables quicker access to loan services.

Data Storage and Transmission: We will adhere to a strict user data confidentiality policy and will not use your data for any other purpose or share it with third parties. We assure you that we do not monitor, read, store, or share any private call data. Only with your explicit consent will your data be encrypted and transmitted to our dedicated servers via the HTTPS protocol(https://app.pesafly.com)。

App List

We need to access your app list for specific apps that satisfy our app’s manifest declaration on your device. In order to prevent virus applications from threatening your account and tampering with user information, we need this permission to ensure that your use environment is secure.These specific apps will help us to know if your device has apps installed with related features such as fraud or cloning (e.g. fake location information, cloned email id and contact information). So that we can judge the authenticity of your information and make a correct judgment on your credit risk.We will upload the collected data to the server (https://app.pesafly.com) in a secure network environment.

Album Pictures

Our apps may request access to your photo albums or media library to allow you to upload images when providing feedback or reporting issues. We will only access these images with your explicit consent and will not scan your entire album unless you choose to upload specific photos. Uploaded images will be used solely to diagnose and resolve reported issues and will not be used for advertising or other purposes. We share uploaded images with trusted image processing providers only for improving our services. We employ advanced encryption to secure your data during transmission and storage. Images are stored only as long as necessary to address the issue and are deleted once resolved or upon your request.

Data storage

Regarding all the collected information, we will store it on the server (https://app.pesafly.com) with high level protection and will not be shared with any third party.

How do we use your data

We collect certain data to be able to provide the Service to you. We also collect data for use in verifying your identity and creating credit scoring models to determine what loans can be offered to you. We also use this data for the purposes of collections and credit reporting.

The data we collect

When you register for this service, we will collect your bank number and phone number, and may also collect your name, age, email address or other contact information. With this information, we will cross-check your identity with third parties (including emergency contacts you provide). We will also collect data from your device for our credit scoring system. This includes information related to your device, such as device manufacturer and model, operating system, installed software applications, and unique user identifiers. We also collect your email and information related to device activity, such as SMS logs and GPS location information. To supplement this information, we also collect data from third parties, such as credit bureaus and other financial institutions. Through the registration service, you authorize the collection and processing of the aforementioned data.

We will ensure that your data is protected to a strict standard.

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