Please read carefully before using this service.

PRIVACY POLICY

(Last Updated: August 2023)

TopLoan Tech Limited (“we” or “us”) takes your privacy seriously. This privacy policy explains why we collect data, what data we collect, how we store and transfer that data as well as who we may share the data with. By downloading the App, you confirm that you have read, understood and accept the terms of this 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 Policy.

1.Purpose of Collection
In order to offer you the Services, we are required to conduct identity and credit worthiness verification. You expressly permit us to analyze your smartphone data to verify your identity and create a personalized credit scoring models to determine what Loans can be offered to you. We also use this data for purposes of collections and credit reporting.

2.Data we collect
When you register for the Service, we will collect your basic information as per the below:
• Location access: We require access to your location in accordance with our anti-money laundering policies. As a responsible corporate entity, we take every measure to ensure that the use of our services is for legitimate and legal purposes only. In order to ensure the legality of the use of our Services we require access to your location to verify that you are access the services from within the borders of Uganda and to ensure that the repayment of any loaned amounts emanate from within Uganda and the funds are legitimate in nature.
• SMS logs: Our app collects and transmits to TopLoan servers (url https://srv.toploan.biz), your SMS data which helps us in identifying the various bank accounts that you may be holding, cash flow patterns, description and amount of the transactions for the purpose of performing a credit risk assessment. This credit risk assessment enables us to perform a quicker loan disbursal. TopLoan will never share data to any third party. The collection will only be done if you agree to the authorization.
• Calendar access: You agree that we must be granted access to your smartphone’s calendar in order to input reminders pertaining to repayment dates of your loan. We will not extract nor view any information in your calendar and limit our actions to setting reminders.
• Camera: Allow camera permissions to be used to take a live ID photo and a live selfie photo during loan application. The two photos will be uploaded to our secured server (url: https://srv.toploan.biz) to do facial recognition for the purpose of anti-fraud. Only applications passed the facial recognition check can be given the loan.
• Our use of the foregoing data will all times be subject to our Privacy Policy as detailed below.

3.Data storage and Transfer
The data that we collect from you may be transferred to, and stored at, a destination outside Uganda. While we strive to use global best practice commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. It may also be processed by staff operating outside Uganda who work for us or for one of our suppliers. We will only process your data that is necessary for us to render the Services to you. By submitting your Personal Data, you agree to this transfer, storing or processing of data. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. We will undertake reasonable and necessary steps to ensure the safety and integrity of your data.

4.Service Discretion
You acknowledge that your entitlement to receive a loan from us at our sole discretion and we will not be liable in the event of your loan application being rejected or if we provide you a loan of a lesser amount.

5.Service Fees
We may offer you the opportunity to apply for Loans in certain amounts. However, if we accept your application and grant you a Loan We will charge a processing fee which is payable to us on top of paying back the borrowed amount (“Processing Fee”). The Processing Fee payable is stated together with the loan amount at the time you apply for each Loan. The Loan shall be credited into your TopLoan Account less deduction of the applicable Processing Fees and which deduction you hereby agree consent to.

6.Loan Due Date or rollover
You agree to repay the Loan by the date specified when you take the Loan (“Due Date”). If you fail to repay the Loan and Processing Fee on the Due Date, we will automatically rollover your Loan for a period of time ("Rollover Period") and charge you an additional fee ("Rollover Fee") in the amount. You must then repay the loaned amount, Processing Fee and Rollover Fee by the end of the Rollover Period. You hereby irrevocably agree that we may rollover your Loan and charge the Rollover Fee for so long as your Loan remains unpaid.

7.Default
If you still have not repaid the Loan amount and fees, by the end of the Rollover Period, you will be in default. You agree that any default may be shared by us to third party lending institutions and platforms within twenty (20) days of your default, or such other time period as required/permitted in terms of the law, and such report may affect your ability to borrow money with digital lending platforms in the future. Overdue amounts will be rounded up to the nearest whole Ugandan shilling. You will become responsible for all costs we or our suppliers may incur in collecting the payment in accordance with applicable law.

8.Recovery of Loans and Costs
You expressly agree and authorise us to debit the amount of the Loan, Processing Fee, Rollover Fee or any other applicable fees from any of your accounts, identified by you, which has your name and exclusively belongs to you as necessary for the payment due in respect of the Loan on the Due Date or, before or after the Rollover Period. You expressly agree to pay any bank charges relating to the aforesaid deduction.

9.Personal Data Sharing
We may share your data with third parties in certain circumstances. We may, for example, share data with:
(i)credit bureaus, in requesting credit histories or reporting loan defaults;
(ii)collections agencies, in seeking to collect overdue Loans;
(iii)government bodies and law enforcement agencies, to comply with the law;
(iv)professional advisers, to enforce or defend our legal rights;
(v)or with a purchasers or sellers in connection with a corporate event such as a merger, business acquisition or insolvency situation.

10.Location Services
You acknowledge and agree that we require access to your GPS location when using our Services. We require access to your GPS location in order to ensure that you are utlising our services within the borders of Uganda only, as required by our license conditions. We furthermore require your GPS location as part of our anti-money laundering and anti-terrorism practices. Failure to authorise use of your GPS location will disqualify you from using our Services. Geolocation services are provided by Google LLC. By using the service, you accept Google’s Terms of Service available at https://policies.google.com/terms.

11.Changes To Privacy Statement
We reserve the right to modify our Privacy Policy at anytime at our sole discretion. Any amendments to our Privacy Policy will be displayed this first time you login into the App after the changes have taken effect and which changes you shall be required to read and accept to keep using the Services. Should you not accept the amendments to our Privacy Policy your access to the Services will be prevented and/or your account suspended.

12.Right to Withdraw Consent
You have the right to withdraw consent to receive promotional messages by following the process stated in the Terms and Conditions.

13.Contact Information
If you have any questions about this privacy policy or other privacy issues, we can be reached at: support@toploan.biz