Last updated: 01 December 2022
This privacy policy (“Privacy Policy”) applies to the personal information that Pay 24 Financial Services Limited processes in connection with the Azima app(s), website(s), software and related services (the “Platform”), that link to or reference this Privacy Policy.
Your personal privacy and the privacy of your data is paramount to us at MeWe. We have prepared this Privacy Policy to clearly explain how we protect you and your data at MeWe.
We are uncompromising about trust, respect and integrity.
We collect your information in three ways: Information You Provide, Automatically Collected Information, and Information From Other Sources. More detail is provided below.
Information You Provide
Profile Information. We collect information that you provide when you register for a loan, such as your date of birth, full name(s), mobile number, government-issued identity number (such as National Identity Number [NIN], National Identity Card Number [NID Card No.], passport number, driving license number, etc.) address, and login pin. We also collect additional information in the form of photographs submitted by you of your self (selfie), and the front and rear of your government-issued identity document.
Your Contacts. In the event that we are unable to reach you in relation to the Loan Agreement, we use this information to contact your next-of-kin that was chosen/submitted by you.
Information When You Contact Us. When you contact us, we collect the information you send us, such as proof of identity, alternate contact number(s), email address(es), social media IDs/handles, feedback or inquiries about your use of the Platform or information about possible violations of our Terms of Service (our “Terms”), Loan Agreement (our “Loan Agreement”), or other policies.
Automatically Collected Information
Technical Information. We collect your device model when you access the Platform.
Location Information. With Location Services enabled, we automatically collect information about your approximate location from your device. When Location Services is turned on, we will receive your approximate location from your device’s GPS data. The approximate location information Pay 24 receives from your device is an area of at least 3 square kilometers from your actual location. The area may be larger, depending on the operating system type and version that is running on your device. Note: Due to manufacturer issues, some Android devices may prompt you to turn on precise location.
Cookies. We do NOT use cookies and similar tracking technologies to operate and provide the Platform.
Information From Other Sources
Third Party Platforms and Partners. Third party platforms provide us with logistical support for hosting, authentication, data storage, marketing and usage monitoring. Our partners (such as Amazon Web Services, Google Analytics, Google AdSense, and AppsFlyer) have all implemented strict measures to maintain the integrity of our user’s (your) privacy. We ensure that all our service providers minimize PII (Personal Identifiable Information). You can read more about their respective policies at these links:
Payment Integrators and Telecommunication Service Providers. We may receive information about you from our payment integration partners and telecom providers in order to verify your mobile money wallet registration information, identity and related data.
Others. We may receive information about you from others, for example, where you are included or mentioned in a complaint, appeal, request or feedback submitted by a user, law enforcement or third party, or if your contact information is provided to us by a user.
We use your information to operate, provide, develop, and improve the Platform, including for the following purposes. You can find more detail in “Our Legal Bases and How We Process Your Information”.
Service Providers
We engage service providers that help us provide, support, and develop the Platform and understand how it is used. They provide services such as cloud hosting, content delivery, customer and technical support, identity verification, marketing, analytics, text messaging services, online payment and mobile money services. We share Information You Provide, Automatically Collected Information, and Information From Other Sources with these service providers as necessary to enable them to provide their services.
Partners
Third Party Platforms and Partners. We share limited information which may include Information You Provide, Technical Information, and Usage Information with third party platforms and partners whose platform or services are integrated with the Platform. We do this to give you a seamless experience, access your account anywhere when you connect to the internet, and enable us to authenticate users.
Measurement and Data Partners. We also share Technical Information and Usage Information with third party measurement providers who help us measure the performance of the app.
Our Head Office
The Platform is supported by certain entities (“employees”, “agents”) within or in cooperation with our corporate office. These entities process Information You Provide, Automatically Collected Information, and Information From Other Sources for us as necessary to provide important functions, such as verification, loan approval, collections, storage, content delivery, security, research and development, analytics, online payments, customer and technical support, and content moderation.
Others
We share your information in other limited scenarios as follows:
Corporate Transactions. Your information may be disclosed to third parties in connection with a corporate transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control, or acquisition of all or a portion of our business.
Legal Obligations and Rights. We may access, preserve, and share the information described in “What Information We Collect” with law enforcement agencies, public authorities, or other third parties if we have good faith belief that it is necessary to:
We may only use your information when we have a “legal basis” to do so. We use different legal bases depending on why we use your information (in other words, the “purpose” of our processing). These legal bases are contractual necessity, legitimate interests (ours, yours or those of another party), consent, compliance with a legal obligation, performing a task in the public interest, and protection of vital interests.
Here we explain the legal bases we rely on when we process your information. This section also describes why we use your information, how this information is processed, the categories of information involved, and the associated rights (which always includes the right to access your information). For more information on how to exercise any of your rights, please check out the “Your Rights and Choices” section.
Contractual Necessity
We use Information You Provide, Automatically Collected Information, and Information From Other Sources where it is necessary to perform the contract you enter into (our Terms) when you register for, access, or use the Platform. This means we use your information to:
Your Rights: Whenever we use your information on the basis that it is necessary for the contract or agreement we have with you, you have the right to update the information you have provided to us.
We use your information where this is necessary to achieve legitimate interests – whether belonging to us, you, or a third party – provided these interests are not outweighed by your interests or fundamental rights. We use the information we collect to:
Ensure the safety of our Security (refer “Loan Agreement”) and Product.
Ensure the security and stability of the Platform.
Review, improve, promote and develop the Platform.
Share your information with third parties.
Your Rights: Whenever we use your information on the basis that it is necessary for legitimate interests, you can request clarification on such usage.
We ask for your consent to access or use your information for specific purposes. If we do, you’ll always be able to revoke your consent through your device permissions or in-app settings. It is important to understand that when you revoke certain permissions, we may not be able to product with access to our products and/or services, as the case may be.
Compliance with a legal obligation
We may use your information including your Profile Information or User Content where it is necessary to comply with a legal obligation. This includes situations where we have obligations to take measures to comply with terms of the licensing authority in the country or comply with a valid legal request such as an order from law enforcement agencies or courts. We generally use Information You Provide and Automatically Collected Information, although it depends on the specific situation.
To perform a task in the public interest
We may use your information where it is necessary to perform a task in the public interest, including undertaking research, preventing and detecting crime, safeguarding our financial accounts, and promoting public safety, security, and integrity as laid down by applicable law. We generally use Information You Provide and Automatically Collected Information, although it depends on the specific situation.
To protect someone’s vital interests
We may use your information where it is necessary to protect your or someone else’s life, physical integrity, or safety. This could include providing law enforcement agencies or emergency services with information in urgent situations to protect health or life. We generally provide Information You Provide and Automatically Collected Information, although it depends on the specific situation.
You have rights and choices when it comes to your information. Some of these rights apply generally, while others will only apply in certain circumstances. Depending on the scenario, these rights may be subject to some limitations. Pay 24 Financial Services Limited will be responsible for responding to your request within the gamut of the law.
Access your information. You can ask us to confirm what information we process about you, to provide certain information about the processing, and for a copy of your information.
Delete your information. You can delete or ask us to delete some or all of your information. This request can be fulfilled provided your information is not needed to meet our legal and/or regulatory obligations.
Rectify your information. You can change or ask us to change or correct your information where that information is not accurate. You can change or correct much of your information through the in-app controls and settings.
Object to the processing of your information. You also have the right to object to the processing of your information in certain circumstances. This right applies when we are performing a task in the public interest or pursuing our legitimate interests or those of a third party. In submitting an objection request, please provide all relevant information, including the processing activity you are objecting to, why you want to object and how the processing activity affects you, and any additional information that you think will help us review your request. We will stop the particular processing if we don’t have compelling legitimate grounds to continue that processing or don’t need it for legal claims.
Restrict the processing of your information. You have the right to request the restriction of the processing of your information where (a) you are challenging the accuracy of the information, (b) the information has been unlawfully processed, but you are opposing the deletion of that information, (c) where you need the information to be retained for the pursuit or defence of a legal claim, or (d) you have objected to processing and you are awaiting the outcome of that objection request.
To exercise any of the above rights, please contact us. Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details or provide additional information so that we can understand your request.
We encourage you to “Contact us” if you are not satisfied with how we have responded to any of your rights requests. You also have the right to lodge a complaint with the Personal Data Protection Office | PDPO of Uganda (Pay 24 Financial Services’data protection supervisory authority in Uganda).
Security of your information is important to us. We maintain appropriate technical, administrative, and physical security measures that are designed to protect your information from unauthorised access, theft, disclosure, modification, or loss. We regularly review our security measures to consider available new technology and methods.
We retain information for as long as necessary to provide the Platform and for the other purposes set out in this Privacy Policy. We also retain information when necessary to comply with contractual and legal obligations, when we have a legitimate business interest to do so (such as improving and developing the Platform, and enhancing its safety, security and stability), and for the exercise or defence of legal claims.
The retention periods will be different depending on the type of information and the purposes for which we use the information. For example, when we process your information to provide you with the Platform, we keep this information for as long as you have an account. This information includes your Profile Information, Identity Information, and Transactional Information. If you violate our Loan Agreement or Terms, we may remove your Profile Information and/or User Content from third-party view immediately but keep your information as is necessary to process the violation.
We store the information described in What Information We Collect in secure servers operated by Amazon Web Services (AWS).
Certain entities (“Employees”, “Agents”), located in or outside your country of residence, are given limited remote access to this information so they can provide certain functions, as described in the Our Head Office section in How We Share Your Information. This access is limited, secure and only granted where necessary under strict security controls and authorisation approval protocols.
We share What Information We Collect with service providers, partners and other third party entities, as described in How We Share Your Information. These third parties may or may not be located outside your country of residence. These entities commit to processing information in compliance with applicable privacy laws and to implementing appropriate security measures to protect your information.
We maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of your personal user data and other information transmitted to us. For example, we encrypt your personally identifiable information (PII), and most, if not all requests from you to the server are created over a secure connection (HTTPS).
However, no data transmission over the Internet or other network can be guaranteed to be 100% secure.
You must be at least 18 years old to use the Platform. If you believe that there is a user who is below this minimum age, please contact us using the details set out in the “Contact Us” section below.
We may amend or update this Privacy Policy from time to time. We will notify you of any material changes to this policy by a notice provided through the Platform or by other means. The “Last Updated” date at the top of this policy reflects the effective date of such policy changes.
You can contact us about this Privacy Policy through the following means:
You can reach Pay 24 Financial Services’ Data Protection Officer by email: dpo@azima.app
