HOW YOUR PERSONAL INFORMATION IS USED AND MANAGED

‍About this Privacy Policy

‍Our privacy policy (this policy) sets out how Fingo Africa (each “we”, “us”) manage personal information, including credit-related information, we collect about you. This policy was prepared in August 2022. If you have any feedback on this policy, or you wish to contact us, please email us at privacy@fingo.holdings. We look forward to hearing from you. We may vary this policy from time to time. We will ensure that the most updated version is on our website. We invite you to check the policy on the website from time to time.

WHAT IS PERSONAL INFORMATION AND PERSONAL DATA

‍Personal information in Kenya

‍In Kenya, personal information is information, or an opinion about you or from which you can reasonably be identified.When we collect and use personal information about you in Kenya, we manage that personal information under this privacy policy, Privacy and Data Protection Policy 2018 and the Kenyan Data Protection Act, 2019 (the DPA).

WHY WE COLLECT PERSONAL INFORMATION

‍To provide services to you and manage our relationship

‍We collect personal information about you when we take a record of that personal information. We collect personal information about you only where we need to or where that personal information is related directly to your banking functions and activities with Fingo Africa. For example, we collect personal information about you so we can: supply banking or other services to you; manage our commercial relationship and arrangements with you; help us to understand your banking requirements and develop our products and services; offer you our products or other products as they become available and that may be of interest to you; make products available to you at your request; determine your ongoing ability to service any loan; improve the services and products we offer; and If you are a Fingo Africa customer, we may collect other personal information about you from dealing with you to help us conduct our banking activities efficiently.

WHAT PERSONAL INFORMATION DO WE COLLECT

‍The types of personal information we collect

‍We or our service providers may collect personal information about you including:

- identification information like your name, date of birth, address and contact details; - information you use or give us when you:

1. enquire about our products or services;
2. apply to open an account with us or to obtain other products or services;
3. use our website;
4. ask us, or accept our invitation, to participate in beta activities;
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- information we collect from supplying products or services to you;
- information we collect when you use our website like:

1. your IP address;
2. the user ID of logged in users; and o the username of login attempts;

- financial information like your income and expense particulars and your transaction data from other financial institutions when we consider credit applications by you or offers to guarantee credit obligations owed by others to us; and
- credit information like details about your credit history, credit capacity and credit worthiness.

‍How long do we keep personal information

‍We keep information while you are a customer with us and for only as long as we need it.

Generally we will keep your information for 7 years but sometimes we need to keep it for longer such as:

- if the law requires us to keep it for longer;
- to respond to any complaints

HOW WE COLLECT PERSONAL INFORMATION

‍Personal information you provide

‍Mostly, we collect personal information about you directly from you. We may collect personal information about you from other sources, like when:

- you use our website;
-you use our application
- if you apply for a loan from us, when we obtain a credit report about you to consider your loan application; or
- we access your transaction data from other financial service providers to assess both initially and on an ongoing basis whether you can afford a loan with us.

‍Personal information provided by others

‍Sometimes, we collect personal information about you that is available publicly or from others who:

- act for you, like your mortgage broker or another person who refers you to us;
- check information you give us, like confirming your income with your employer if you are applying for a loan from us;
- supply services (like identity verification or loan settlement services) to us;
- give us information to help us decide whether to make a product or service available to you (like credit reporting agencies and other credit and financial service providers) and whether you can continue to meet your repayment obligations; or
- help us manage our arrangements with you.

‍Cookies

‍We use cookies to personalise content and ads to make our website and our apps more appealing or easier for you to use. We also share cookie information with third parties to assist us to direct advertising to you and to analyse data relating to use of our website and our apps.

For more information on how we use cookies and tracking tags, please visit our Cookie Preference Centre on our website by clicking on the Cookie Settings (on the consent banner) and reviewing your cookie settings in there.

HOW WE PROTECT PERSONAL INFORMATION

‍Securing your personal information is important to us

‍We will take steps reasonably available to us to protect your personal information from:
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- misuse, interference or loss; and
- unauthorised access, modification or disclosure.

We will do this by ensuring that access to your personal information is password protected and available only to those of our employees that need to use, disclose or manage it under this policy.

Personal information that we can’t protect is personal information that you share with us on our social media channels such as email addresses and first and last names.

‍What happens when there is a data breach

‍If, despite our best efforts, a data breach occurs, we will take immediate steps to determine the breach, its cause and how to fix it.

We will advise you of the extent of the data breach (if known) and the most appropriate means of regaining control of that information. We will also notify the Office of the Data Protection Commissioner or any other regulator, if appropriate and comply with all other relevant legal requirements.

HOW WE USE PERSONAL INFORMATION

‍Using your personal information to benefit you and keep things safe

‍We may use personal information about you to:
- consider any requests or applications you make to us or to our service partners;
- help us to understand your banking requirements;
- assess your ongoing ability to repay any loans; and
- refine and develop our products and services;

We may also use your personal information to tell you about our products and services or products and services from our service partners that may be available to you. That may include telling you about competitions or other promotional events in which we invite you to participate. That correspondence is called direct marketing.

You can tell us to stop sending you direct marketing at any time. Please see below for our contact details.

We may also use personal information about you to:
- identify you and manage our arrangements with you;
- prevent or investigate conduct that may be fraudulent or criminal;
- assist us to develop and improve our banking products and services;
- assist with any other purpose you consent to or at your direction.

HOW AND WHEN CREDIT INFORMATION IS USED

‍We collect and use credit information for specific purposes

‍If you:
- apply for, or have, a loan from us; or
- offer to guarantee or guarantee obligations owed by others to us,

we may exchange personal information about you with credit reporting bodies.

Information that we may obtain and exchange about you may include:

- identification information such as your name, date of birth, address and driver’s licence number;
- consumer credit liability information such as credit providers who gave you credit, the types of credit and the maximum amounts of credit available under those arrangements;
- the history of whether you made loan repayments and when repayments were made; requests that have been made for access to the credit file the credit reporting body holds about you;
- the types of credit for which you have applied;
- ongoing credit bureau scores;
- when you are at least 60 days overdue on a payment and when you have made those payments or entered into new payment arrangements;
- court judgments relating to you and credit you obtained;
- information about arrangements with creditors and whether you are bankrupt;
- publicly available information about your credit worthiness; and
- in a credit provider’s opinion, you have committed a serious credit infringement such as:

- obtaining or seeking to obtain credit fraudulently; or
- you have acted in a way that led your credit provider to believe you no longer wish to comply with your credit obligations and your credit provider has been unable to contact you.

We may use information we get about you from a financial institution or credit reporting body or information we derive from that information to assess your application for credit from us or to assess your ongoing ability to repay a loan or to invite you to apply for another product or service from us.

HOW WE USE GOVERNMENT IDENTIFIERS

‍Only as permitted by Law

‍We do not use Government related identifiers (such as KRA PIN or National ID) to identify you in our records. We may collect and use some of your Government related identifiers, but only for reasons required and permitted by Proceeds of Crime and Anti-Money Laundering Act, 2009, the Proceeds of Crime And Anti-Money Laundering Regulations, 2013 Privacy and Data   Protection Policy   2018 and   the DPA.  For example, we  may  use those  identifiers to  help  us to  check your identity before we make banking products available to you or for tax reasons.

WHEN DO WE DISCLOSE PERSONAL INFORMATION

‍Who we share your personal information with

‍We may exchange personal information about you with:
- Financial Service partners such as Ecobank;
- credit reporting bodies, if you apply for, guarantee or obtain a loan or any other credit product from us;
- any guarantors or possible guarantor of your obligations to us;
- suppliers that help us to conduct our business. Amongst other suppliers, that may include suppliers that help us to:

- understand your banking requirements;
-improve our products or services;  
- verify your identity;
- settle loans we make available;
- provide services to help us run our business;
- take appropriate action about suspected unlawful activity or serious misconduct;

Those suppliers may:
- disclose your personal information to contractors that assist those suppliers to perform services for us;
- track your use of our products, services or website for us; or

‍What we use your personal information for

‍Our arrangements with suppliers will limit use of your personal information to the services they supply to us. We will ask suppliers to in turn ensure their arrangements with contractors limit those contractors’ use of your personal information to help the suppliers perform services for us.

We will require suppliers or their subcontractors to return, destroy or de-identify personal information about you that they hold when they cease performing services for us. If you want information on how those suppliers manage your personal information, please email us at privacy@fingo.holdings

Suppliers we share personal information with include:
- your employer to verify employment related information you give us;
- other financial institutions you deal with;
- mortgage brokers that introduce you to us and any mortgage aggregator that supplies services to your mortgage brokers;
- any person who refers you to us to obtain services from us;
- regulators or law enforcement bodies;
- dispute resolution bodies or services, to assist with resolving any complaint you make about our products or services or any dispute you may have with us;
- any entity that proposes to take an interest in our business or any of our loans or other assets. That may include entities that are involved in securitising any loan we made available to you; and
- any person at your request or with your consent.

‍Yes, we use Google Analytics

‍We use Google Analytics services to improve and analyse our website and app experiences.

We may share information with Google for that purpose.  When you use:

- our website, that information may include the URL of the webpage that you’ve visited and your IP address. Google may also set cookies on your browser or read cookies that are already there; and

Google uses the information Fingo Africa shares with them to help us understand how you engage with Fingo’s website and app. Also, Google may use that information for

other purposes. Please read Google’s Privacy Policy (https://policies.google.com/privacy) to learn more about how Google uses and processes data.

‍You can turn Google Analytics off

‍If you don’t want Google Analytics to be used in your browser, you can install the Google Analytics browser add-on(https://tools.google.com/dlpage/gaoptout).

Also, please read Google’s Privacy Policy (https://policies.google.com/privacy) to learn more about how Google uses and processes data.

‍DATA TRANSFER LIMITATION

‍We may transfer your personal data outside the Republic of Kenya if the transfer is necessary for one of the other reasons set out in the DPA including the performance of a contract between us and yourselves, reasons of public interest, to establish, exercise or defend legal claims or to protect your vital interests and where you are   physically or legally incapable of giving consent and, in some limited cases, for our   legitimate interest.

WHAT THE LAW REQUIRES US TO DO

‍We collect and use personal information when required by law

‍We may collect personal information about you because the law requires us to do so.

For example, the law requires us to collect personal information about you to:

- identify you under the Proceeds of Crime and Anti-Money Laundering (POCAML) Regulations before we open an account for you or make a loan to you.

HOW TO STOP RECEIVING DIRECT MARKETING

‍How to tell us to stop sending you direct marketing information

‍You can ask us any time to stop sending you direct marketing information. When we email you with direct marketing, you can respond by clicking unsubscribe and we will stop sending you direct marketing. We do not charge you a fee for asking us to stop direct marketing.

HOW TO ACCESS YOUR PERSONAL INFORMATION

‍Asking for access to personal information

‍You can ask for access to personal information we hold about you anytime. We may ask you to detail the information you require if you want only some of that personal information.

If you want to access the personal information we hold about you, please email us at privacy@fingo.holdings .

You may also want to access personal information (including credit-related personal information) we have disclosed about you to third parties or to make a complaint to those third parties. The privacy policies of those third parties will tell you how you can make an access request or a complaint to them.

‍What information we can and cannot share

‍Generally, we will give you access to the information you request. There may be some circumstances, permitted by the APPs, in which we will not give you that access. For example, we may not give you access to information where:

- giving access would have an unreasonable impact on the privacy of others;
- we reasonably believe the request is frivolous or vexatious;
- the information relates to actual or possible legal proceedings between us and you and we would not have to produce that information under orders a court may make in those proceedings;
- giving access would prejudice our interests relating to negotiations we are having with you or investigations we are making into unlawful activity or misconduct of a serious nature;
- the law or a court or tribunal order prevent us from giving you access; or
- giving access would reveal certain information we generate internally relating to a commercially sensitive decision-making process.

We will give you written reasons if we refuse to give you access to personal information you request, unless there are reasonable grounds (such as confidentiality obligations we owe) for not giving you those reasons. In any case, we will give you an explanation if we do not give you access to information because of a commercially sensitive decision-making process.

‍How we will respond to requests for personal information

‍We will give you access to the information you request in the manner you request (for example, by email), if we are reasonably able to do so. If we are not able to do so or if we have a reason for not giving you access to all the information you request, we will try and work with you to give you access to personal information we hold about you in a way that meets your needs and our needs.

We will respond to any request you make for access to personal information we hold about you within a reasonable time after you make the request. The time it takes will depend on the amount of information you seek and whether we have to make more enquiries of you to clarify your request. We expect to respond to any request you make for access within 30 days after we receive your request.

‍Is there a cost to accessing personal information?

‍Depending on the amount of information you request, we may charge you a fee for organising the information you request from us. We will give you an estimate of the fee before we organise the information. Then, we can work with you to check whether you wish to limit your request to reduce the charges.

HOW PERSONAL INFORMATION IS KEPT UP-TO-DATE

‍Correcting your personal information

‍We take steps, reasonably available to us, to ensure that the personal information we hold about you is accurate, up-to-date and complete. To assist us, we ask that you contact us and update the personal details we hold about you (for example, your name, address and contact details), if those details change. You can contact us by email to privacy@fingo.holdings.

You may consider that the personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading. You can request us to correct the personal information we hold about you by email to privacy@fingo.holdings.

If we receive your request to correct information but consider that the information does not need correcting, we will give you a written notice setting out our reasons. Also, we will give you details of how you can:

- ask us to associate a statement to the information you consider to be incorrect; or
- make a complaint about us refusing to correct information.

We will respond to any correction request you make within a reasonable time after you make the request.

We will not charge you for correcting or associating a statement to personal information at your request.

HOW TO MAKE A COMPLAINT

‍If you have a complaint start with us, but there are other ways

‍If you have a complaint about the way we manage the personal information we hold about you, please email us at privacy@fingo.holdings.

If we cannot resolve your complaint in a manner that is satisfactory to you and within 30 days of receiving your complaint, you can reach out to the office of the Data Protection Officer. Website at www.odpc.go.ke.