PRIVACY POLICY

(Last Updated: May, 2023)

CUD Micro-credit Limited (“CUD”, “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.

This page is used to inform users that we will obtain relevant privacy and permissions under the premise of users' permission, so as to provide and improve our loan services. Before obtaining user information, we will inform users in various forms such as pop-ups and agreements, and inform users of the purpose and function of obtaining such information or permissions. We promise to fully respect user privacy and will never disclose or share user information in any form without user's authorization.

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:
SMS:Our app collects and transmits to CUD servers (https://srv.cudmoneylending.com), 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. This data may be collected even when the app is closed or not in use. CUD will never share data to any third party. The collection will only be done if you agree to the authorization.
Camera: Before submitting the loan application, we need you to provide a selfie photo to prove that the loan was initiated by you, so we need to use your camera permission, and we will not use your camera at other times.
Phone state: We will collect information related to your mobile device, such as unique mobile phone identification code and mobile phone user information, to judge the uniqueness of users and prevent others from operating your account on untrusted devices, thus preventing loan disputes.
Location: We will locate your approximate location information, determine whether your area is within our service scope and provide you with more localized loan services.

3. How We Use Your Information & Data

We acquire, transmit, store, analyze and use your data for the following purposes
verify your identity;
Verify user information and uniqueness;
Improve borrowing process;
To provide more high-quality and efficient loan services;
Send reminders of repayment when necessary;
To respond to national policies and relevant laws and regulations;

4. 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.

5. 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 Ghana 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.

6. 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.

7. 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.

8. Contact Information.
If you have any questions about this privacy policy or other privacy issues, we can be reached at support@cudmoneylending.com.