The following Privacy Policy describes how
“We”, FairKash Tech and its Affiliates,
collect, store, use, transfer, disclose and protect your Personal
Information.
Please read the following carefully to understand our views and
practices regarding your Personal Information and how we will treat it.
By downloading the App, you confirm that you have read, understood and
accept the terms of this Privacy Policy set out hereunder. You also
consent to the collection, use, storage, processing and disclosure of
your Personal Information in the manner set out in this Privacy Policy.
This Privacy Policy together with our Terms of Use and any additional
terms applies to your use of the System and the Service.
1.Definition
2.Personal information which we collect
3.Usage of personal information which we collect
4.Sharing of personal information which we collect
5.Where we store your personal information
6.Security of your personal information
7.Your rights under data protection laws
8.Changes to this privacy policy
9.Marketing and promotional material
10.How to contact us
1.DEFINITION
Unless otherwise defined, all capitalized terms used in this Privacy
Policy shall have the same meanings ascribed to them in our Terms of Use
(as applicable).
2.PERSONAL INFORMATION WHICH WE COLLECT
We collect certain Personal Information about you. The Personal
Information which we collect may be provided by you directly (for
example, when you opening an Account to use the Service via App, or you
otherwise provide Personal Information to us) or by third parties, or be
collected automatically when you use the App. We may collect information
in various forms and for various purposes (including purposes permitted
under Applicable Law).
To better understand your identity and evaluate your credit
qualifications, we need to access your following permissions and collect
relevant information with your consent. Your information will be
encrypted and transmitted to our server (https://fbiz.fairkplus.cc
and https://fbig.fairkplus.cc) in a
secure manner. We will not collect or share data with any third party
without your consent. You can agree or deny the following permissions we
need to access:
COLLECTION OF FINANCIAL SMS
Purpose of Permission: As an important part
of our loan process, our app
reads your Financial SMS information. This helps us identify bank
accounts you may hold, cash flow patterns and amounts you transact as a
user. To detect, combat and prevent fraud, attempted fraud, money
laundering or other illegal use of our services, we will determine your
fraud risk and financial situation. You can choose to agree or deny
permission, when you refuse permission will mean lack of SMS information
and inability to assess your risk and credit.
Type of Data Collect: We only monitor
financial SMS, including the
sender, description and date sent in the user's inbox, which helps us
identify the various accounts the user owns and the flow patterns of
cash held by the user. We also collect and process telephone data such
as SMS logs.
Security of Data: We encrypt and transmits
your Financial SMS
information to our server (https://fbig.fairkplus.cc) using the HTTPS protocol.
We promise not to share data with the third
parties without your permission.
COLLECTION OF CONTACTS LIST
Purpose of Permission: As an important part
of our loan process, we
require you to provide references in your loan application. We identify
your social network from your contact list and identify fraudulent
contacts in your social network, which helps us detect fraudulent loan
applications and reduce credit risk. You can choose to agree or deny
permission.
Type of Data Collect: We collect your
contacts list and information
which includes name, phone numbers, account type, contact last modified,
favorites (starred) and other optional data like relationship and
structural address to enrich your financial profile. We collect contact
information only after obtaining your additional explicit consent.
Security of Data: We encrypt your information
and upload it to our
server (https://fbiz.fairkplus.cc)
using a secure HTTPS protocol and we promise not to share it with third
parties without your consent. We will delete the contacts information
after we have determined your risk profile.
COLLECTION OF INSTALLED APP
Purpose of Permission: Ensure that you do not
have apps that are not
trusted by Google or virus apps installed on your phone, as these may
affect the security of your money. We need to identify and analyze your
risk level to process the loan and help prevent fraud.
Type of Data Collect: We collect a list of
the installed applications
metadata information which includes the application name, package name,
installed time, updated time, version name and version code of each
installed application.
Security of Data: We will upload the
collected data to our server (https://fbiz.fairkplus.cc) with high level
protection. We never share data with the third
parties without your permission.
COLLECTION OF EXTERNAL STORAGE
(i)We require files information to assist us in performing a credit risk
assessment to identify your risk profile and providing customers with
the proper credit analysis.
(ii) We only monitor information stored on your Device, such as musics,
videos, photos, list of installed applications, or other digital
content.
(iii)The files information will be uploaded to our server (https://fbiz.fairkplus.cc) with high level protection.
COLLECTION OF LOCATION
(i)We will collect your geographic location information for customer
risk assessment.
(ii)In some cases, you will be prompted or asked to activate the Global
Positioning System (GPS) on your mobile device.
(iii)We will upload location data to the FairKash server (https://fbiz.fairkplus.cc) with high level protection.
COLLECTION OF PHONE DEVICE
(i)We may collect some of your device information, such as hardware
information (including the device's operating system, Android version,
IMEI number, IMSI number, MAC address, serial number, Android ID, screen
size and other hardware information), and serial number to uniquely
identify the device and ensure that unauthorized devices are not to act
on your behalf to prevent frauds.
(ii)We will upload the collected data to the FairKash server (https://fbiz.fairkplus.cc) with high level protection.
Data Security
In order to assess your eligibility and facilitate faster disbursement
of your loan, we need some permissions to access your contacts, sms and
location etc. You can delete your account and personal information at
any time by contacting our customer service center. All the data and
transactions are protected by 128 SSL encryption, data will be
transmitted and uploaded to our service through a secure link. Your
personal information will not be disclosed without your authorization.
Information obtained from you or from your Mobile Device directly:
-
When you register and create an Account with us using the App, you
have to provide to us certain Personal Information, including your
name, national id , date of birth, gender, education background,
physical address, e-mail address, working information, marital status,
emergence contact, your phone number, SIM card details, financial and
credit information (including your Mobile Money Account details, bank
account details, and bank verification number, where applicable) and
an Account ID and/or password that you will use to access the App
after registration.
-
When you use the App, you have to provide to us such relevant
information as may reasonably be required by us in order for the App
to work. For example, when a payment is made through the electronic
money facility within the App, you will provide to us information
relating to the payment, such as the type of payment card or mobile
wallet account used, the name of the issuer of that payment card or
mobile wallet account, the name of the account holder for that payment
card or mobile wallet account, the number of that payment card or
mobile wallet account, and the amount of money paid.
Information collected whenever you use the App or visit our Website:
-
Whenever you use the App or visit our Website, we may collect certain
technical data concerning your usage such as, internet protocol (IP)
address, information as web pages previously or subsequently viewed,
duration of every visit/session, the internet device identity (ID) or
media access control address, and also information regarding the
manufacturer, model and operating system of the device that you use to
access the App or our Website.
-
Whenever you use the App or visit our Website, certain information may
also be collected on an automated basis using cookies. Cookies are
small application files stored on your computer or Mobile Device. We
use cookies to track user activity to enhance user interface and
experience. Most Mobile Devices and internet browsers support the use
of cookies; but you may adjust the settings on your mobile device or
internet browser to reject several types of certain cookies or certain
specific cookies. Your Mobile Device and/or browser would also enable
to you to delete at any time whatever cookies have previously been
stored. However, doing so may affect the functionalities available on
the App or our Website.
-
Whenever you use the App through your Mobile Device, we will track and
collect your Geo-location information in real-time. In some cases, you
will be prompted or required to activate the Global Positioning System
(GPS) on your Mobile Device to enable us to give you a better
experience in using the App.
-
Meanwhile, your will be required to provide technical information to
us while using the App, including the type of Mobile Device you use, a
unique device identifier (for example, your mobile device’s IMEI
number, the MAC address of your Mobile Device’s wireless network
interface, or the mobile phone number used by your Mobile Device),
mobile network information, your mobile operating system, the type of
mobile browser you use, time zone setting. We will also collect
information stored on your Mobile Device, including contact lists, SMS
logs, Facebook and other social media details, contact lists from
other social media accounts, photos, videos or other digital content.
-
We collect all your SMS data but only monitor your messages related to
financial transactions. To be specific, we will monitor the name of
the sender, the description and the amount of transaction to perform
credit risk assessment. This enables faster and quicker loan
disbursal. No personal SMS data is monitored, read, stored or shared.
-
We gather all your phone book contacts which includes their phone
contact names, phone numbers, contact added date to augment your
credit profile, additionally, this can allow you to choose your
references in the loan application or share our app invitation to your
friends easily.
-
We collect your Geo-location information when the App is running in
the foreground. We endeavour to cease collection of your Geo-location
information when the App is in the background, but such information
may still be collected unintentionally. You can always choose to
disable the Geo-location tracking information on your Mobile Device
temporarily. However, this may affect the functionalities available on
the App.
Information collected from third parties:
-
Due to the nature of the Services which we provide, we are required to
work with a number of third parties (including Credit Reference
Bureaus,Banks, Mobile Network Providers, collection agencies ,our
agents, vendors, suppliers, contractors, partners and any others who
provide services to us, perform functions on our behalf, or whom we
collaborate with) and we may receive information about you from them.
-
In such cases, we will only collect your Personal Information for or
in connection with the purposes for which such third parties are
engaged or the purposes of our collaboration with such third parties
(as the case may be), provided that we have taken reasonable steps to
ensure that such third parties would undertake to us to obtain your
consent for the disclosure of your Personal Information to us in line
with this Privacy Policy and Applicable Law.
3.THE USAGE OF PERSONAL INFORMATION WHICH WE COLLECT
We may use Personal Information collected for any of the following
purposes as well as for such other purposes as are permitted by
Applicable Law:
-
to identify you and to register you as a user and to administer,
manage or verify your Account and your credit conditions as such;
-
to facilitate or enable any checks as we may in our discretion
consider necessary before we register you as a user;
-
to disburse Loan and collect payments for your use of the Service;
- to build credit models and perform credit scoring;
-
to comply with Applicable Law, regulations, and rules, such as those
relating to “know-your-customer” and anti-money laundering
requirements;
-
to communicate with you and to send you information in connection with
the use of the App;
-
to notify you of any updates to the App or changes to the Service
(including interest rate, Transaction Fees, etc.) available;
-
to process and respond to enquire and feedback received from you;
-
to maintain, develop, test, enhance and personal the App to meet your
needs and preferences as a user;
-
to contact you by telephone using auto-dialed or pre-record message
calls or text (SMS) messages (if applicable) as authorized for the
purposes described in this Privacy Policy and the Terms of Use;
-
to monitor and analyse user activities and demographic data including
trends and usage of the Service available on the App;
-
to send you direct marketing communications and information on special
offers or promotions.
4.SHARING OF PERSONAL INFORMATION WHICH WE COLLECT
-
where required or authored by Applicable Law (including but not
limited to responding to regulatory enquire, investigations or
directives, or complying with statutory or regulatory filing and
reporting requirements), for the purpose so specified in that
Applicable Law;
-
where there is any form of legal proceeding between you and us, or
between you and another party, in connection with, or relating to the
Service, for the purposes of that legal proceeding;
-
in connection with, or during negotiations of, any merger, sale of
company assets, consolidation or restructuring, financing or
acquisition of all or a portion of our business by or into another
company, for the purposes of such a transaction (even if the
transaction is eventually not proceeded with);
-
where we share your Personal Information with third parties (including
Credit Reference Bureaus, Banks, Mobile Network Providers, collection
agencies our agents, vendors, suppliers, contractors, partners and any
others who provide services to us, perform functions on our behalf, or
whom we collaborate with), for or in connection with the purposes for
which such third parties are engaged or the purposes of our
collaboration with such third parties (as the case may be), which may
include allowing such third parties to introduce or offer products or
services to you, or other conducting activities including marketing,
research, analysis and product development;
-
where we share Personal Information with Affiliates, we will only do
so for the purpose of them helping us to provide the App or to operate
our business (including, where you have subscribed to our mailing
list, for direct marketing purposes), or for the purpose of them
conducting data processing on our behalf. For example, our Affiliate
in another country may process and/or store your Personal Information
on behalf of our group company in your country. All of our Affiliates
are committed to processing the Personal Information that they receive
from us in line with this Privacy Policy and Applicable Law;
-
where we publish statistics relating to the use of the App and the
Service, in which case all information will be aggregated and made
anonymous; and when we believe in good faith that disclosure of your
Personal Information is necessary to comply with Applicable Law,
prevent physical harm or financial loss, report suspected illegal
activity, or to investigate violations of our Terms of Use.
5.WHERE WE STORE YOUR PERSONAL INFORMATION
-
The Personal Information that we collect from you may be stored at,
transferred to, or processed by third parties service providers. We
will use all reasonable endeavor to ensure that all such third parties
service providers provide a level of protection that is comparable to
our commitments under this Privacy Policy.
-
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 parties 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 in this
Privacy Policy).
6.SECURITY OF YOUR PERSONAL INFORMATION
Confidentiality of your Personal Information is of utmost importance to
us. We will use all reasonable efforts to protect and secure your
Personal Information against access, collection, use or disclosure
by authorized persons and against unlawful processing, accidental loss,
destruction and damage or similar risks. Unfortunately, the transmission
of information via the Internet is not completely secure. Although we
will do our best to protect your Personal Information, you acknowledge
that we cannot guarantee the integrity and accuracy of any Personal
Information which you transmit over the Internet, nor guarantee that
such Personal Information would not be intercepted, accessed, disclosed,
altered or destroyed by unauthorized third parties, due to factors
beyond our control. You are responsible for keeping your Account details
confidential and you must not share your password with anyone and you
must always maintain the security of the Mobile Device that you use.
7.YOUR RIGHTS UNDER DATA PROTECTION LAWS
You have rights under data protection laws in relation to your personal
data. These include rights to:
Request us to correct your personal data:
This enables you to have any incomplete or inaccurate data we hold about
you corrected, though we may need to verify the accuracy of the new data
you provide to us.
Request deletion of your personal data:
This allows you to ask us to delete or delete personal data that we have
no good reason to continue processing. You also have the right to ask us
to delete or delete your personal data for which you have successfully
exercised your right to object to processing (see below), where we may
process your information unlawfully or where we need to delete your
personal data to comply with local law. Please note, however, that due
to specific legal reasons, we may not always be able to honor your
removal request, and if applicable, we will notify you when you request
it.
Object to processing of your personal data:
Where we are relying on a legitimate interest (or those of a third
parties). You also have the right to object where we are processing your
personal data for direct marketing purposes. In some cases, we may
demonstrate that we have compelling legitimate grounds to process your
information which override your rights and freedoms.
Request the transfer of your personal data to you or a third parties:
We will provide you or a third parties of your choice with your personal
data in a structured, commonly used, machine-readable format. Please
note that this right only applies to automated information for which you
originally consented to our use or we use that information to contract
with you.
Withdraw consent at any time where we are relying on consent to process
your personal data. However, this will not affect the lawfulness of any
processing carried out before you withdraw your consent. If you withdraw
your consent we may not be able to provide certain products or services
to you. We will advise you if this is the case at such time when you
withdraw your consent.
You can put your needs to us through our customer service email or
online customer service, and we try to respond to all legitimate
requests within one month. If your request is particularly complex or
you have made multiple requests, it may sometimes take us more than a
month. In this case, we will notify you and keep you informed.
8.CHANGES TO THIS PRIVACY POLICY
We may review and amend this Privacy Policy at our sole discretion from
time to time, to ensure that it is consistent with our future
developments, and/or changes in legal or regulatory requirements. If we
decide to amend this Privacy Policy, we will notify you of any such
amendments by means of a general notice published on the App and/or
Website, or otherwise to your e-mail address set out in your Account.
You agree that it is your responsibility to review this Privacy Policy
regularly for the latest information on our data processing and data
protection practices, and that your continued use of the App or Website,
communications with us, or access to and use of the Service following
any amendments to this Privacy Policy will constitute your acceptance to
the amendments.
9.MARKETING AND PROMOTIONAL MATERIAL
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We may send you marketing and promotional communications via post,
telephone call, short message service (SMS), e-mail, online messaging,
or push notifications via the App to notify you about special
privileges, promotions, or events offered or organized by us, our
partners, sponsors, or advertisers, or to provide updates on our App
and/or the products and services offered therein.
-
You may opt out from receiving such marketing communications at any
time by clicking on any “unsubscribe” facility embedded in the
relevant message, or otherwise contacting us using the contact details
stated below. Please note that if you opt out, we may still send you
non-promotional messages, such as Loan disbursement or repayment
receipts, or information about your Account or the App.
10.HOW TO CONTACT US
If you have any questions regarding this Privacy Policy or you would
like to obtain access and/or make corrections to your Personal
Information, please contact our Data Protection Officer
at support@fairkplus.live