PAYKIT PRIVACY POLICY

1. Introduction and General terms

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. 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 privacy policy (Policy) together with our Terms and Conditions and any additional terms of use applies to your use of:

1. PayKit mobile application software (App) available on our site OR hosted on the Google and Apple Store (App Site), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).

2. Any of the services accessible through the App (Services) or those available on the App Site or other sites of ours or other third-party Sites (Service Sites).

3. At PayKit we are committed to protecting and respecting your privacy and maintaining the confidence and trust of our customers.

4. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

1. Terms used in this Privacy Policy shall have the following meanings:

   1. “Authorities” includes any judicial, administrative, public or regulatory body, any government, any Tax Authority, securities or futures exchange, court, central bank or law enforcement body, or any of their agents with jurisdiction over PayKit.

   2. “Compliance Obligations” means obligations of PayKit to comply with: (a) Laws or international guidance and internal policies or procedures, (b) any demand from Authorities or reporting, disclosure or other obligations under Laws, and (c) Laws requiring us to verify the identity of our customers.

   3. “Customer” or “User” means any individual within the Republic of Kenya to which PayKit provides its products or services.

   4. “Customer Information” means your Personal Data, confidential information, and/or Tax Information, including relevant information about you, your transactions, your use of our products and services, and your relationships with PayKit.

   5. “Financial Crime” means money laundering, terrorist financing, bribery, corruption, tax evasion, fraud, evasion of economic or trade sanctions, and/or any acts or attempts to circumvent or violate any Laws relating to these matters.

   6. “Laws” include any local or foreign law, regulation, judgment or court order, voluntary code, sanctions regime, an agreement between any member of PayKit and an Authority, or agreement or treaty between Authorities and applicable to PayKit.

   7. “Personal Data” or “Personal Information” refers to the definition accorded to it in the Data Protection Act 2019

   8. “Sensitive Personal Information” refers to the definition accorded to it in the Data Protection Act 2019

   9. “Services” includes maintaining the App available on our site OR hosted on the App Site, once you have downloaded or streamed a copy of the App onto your Device.

   10. “Tax Authorities” means Kenyan or foreign tax, revenue or monetary authorities.

   11. “Tax Information” means documentation or information about your tax status.

2. “We”, “Our” and “Us” refer to PayKit.

3. Reference to the singular includes the plural (and vice versa).

Information we may collect from you

We may collect, use and share personal information when you interact with us and/or use our services. Sometimes, this information is provided to us by you – like when you register for the first time and when you make use of our products or get in touch with us. Sometimes third parties or publicly available sources provide us information about you and it may be generated or combined with other information available to us.

By uninstalling the app from your Device, you shall be deemed to have withdrawn your consent from PayKit accessing your Customer Information in the future. We may keep and share stored Customer Information after the point of uninstall for as long as necessary for the fulfilment of the purposes for which Customer Information was obtained or for the establishment, exercise or defense of legal claims, or for legitimate business purposes, or as permitted by law

We may collect and process the following data about you.

Information you give us about you (Submitted information)

1. This may include information:

• provided by filling in forms in the App or on the App Site (together Our Sites);

• provided by corresponding with us (for example, by e-mail or chat);

• provided by registering to use the App Site, downloading or registering the App, subscribing to any of our Services (such as applying for a loan), searching for an app or Service, sharing data via the App's social media functions, entering a competition, promotion or survey, and reporting a problem with the App, our Services, our App Site or any of Our Service Sites.

2. This information may include your name, address, e-mail address and phone number, the Device's phone number, SIM card details, age, username, password and other registration information, financial and credit information (including your mobile money account details, bank account details, and bank verification number, where applicable), personal description and photograph.

2. Information we collect about you and your device.

1. Each time you visit one of our Sites or use one of our Apps we may automatically collect the following information:

• technical information, including the type of mobile device you use, unique device identifiers (for example, your Device's IMEI or serial number), information about the SIM card used by the Device, mobile network information, your Device’s operating system, the type of browser you use, or your Device’s location and time zone setting (Device Information);

• information stored on your Device, including contact lists, call logs, SMS logs, Facebook friends, contact lists from other social media accounts, photos, videos or other digital content (Content Information);

• data from your use of any other third-party application on the Device or the Service Sites; and

• details of your use of any of our Apps or your visits to any of Our Service Sites; including, but not limited to, traffic data, location data, weblogs and other communication data (Log Information).

3. Location information.

We may also use GPS technology OR other location services to determine your current location. You can withdraw your consent to our collection, processing or use of this information at any time by logging out and uninstalling the App from your Device.

4. Information we receive from other sources (Third Party Information).

Due to the nature of the Services which we provide, we are required to work with a number of third parties (including debt collectors, credit reference agencies and mobile network providers) and we may receive information about you from them.

5. Unique application numbers.

When you install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.

3. Why we collect information

   1. We collect information for the following purposes, including but not limited to (“Purposes”):

• To process your transactions;

• To verify your identity;

• To disburse loans and collect payments for your use of the Service;

• To build the credit models and perform credit scoring;

• To analyze customer behavior;

• To allow our partners to fulfill their obligations to you;

• To allow us to fulfill our obligations to our partners;

• To troubleshoot problems with the Service;

• To comply with applicable laws, regulations, and rules, such as those relating to “know-your-customer” and anti-money laundering requirements;

• To detect and prevent fraud and other illegal uses of the Service;

• To send you marketing notices, service updates, and promotional offers; and

• To contact you by telephone using auto-dialed or pre-recorded message calls or text (SMS) messages (if applicable) as authorized for the purposes described in this Privacy Policy.

4. Tracking and cookies

We may use mobile tracking technologies and/or website cookies to distinguish you from other users of the App, App Site, or Service Sites. This helps us to provide you with a good experience when you use the App or browse any of the Service Sites and also allows us to improve the App and Our Service Sites.

5. Uses made of the information

We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this Policy for as long as it is combined.

Information collected by us shall be used for the purpose of determining whether or not to provide a loan to the customer, the amount of such loan and the terms and conditions applicable to such loan.

Save in compliance with an order of the Court, Arbitral Panel, Tribunal, Regulatory Directive or Order or any other legal or regulatory obligation, we do not disclose information about identifiable individuals to other parties, but we may provide them with anonymous aggregate information about our users (for example, we may inform them that 500 men aged under 30 have applied for a loan on any given day).

6. Disclosure of your information

We may disclose some or all of the data we collect from you when you download or use the App to debt collectors and credit reference bureaus.

We may disclose your personal information to any member of our subsidiaries, affiliates, our holding company and its subsidiaries.

We may also disclose your personal data to debt collectors in order to enforce the terms of the agreement between a customer and PayKit, in the event that the customer is in breach of the repayment terms.

We may disclose your personal information to third parties:

• in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;

• if PayKit or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;

• if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request; and/or

• in order to: enforce our Terms and Conditions and other agreements or to investigate potential breaches; report defaulters to any credit bureau or debt collectors or for the purpose of publishing statistics relating to the use of the App, in which case all information will be aggregated and made anonymous.

7. Where We store your personal data

The data that we collect from you may be transferred to, and stored at, a destination outside Kenya. It may also be processed by staff operating outside Kenya who work for us or for one of our suppliers. These staff members may be engaged in the fulfillment of your requests. 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 may also disclose your data to anyone we consider necessary in order to provide you with services in connection with an account.

Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Service Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to Our Service Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

8. Your rights

   1. You agree to inform us promptly, and in any event, within 30 days, in writing if there are any changes to Customer Information supplied to us or a member of PayKit from time to time, and to respond promptly to any request from us;

   2. Where:

• you fail to provide promptly Customer Information that we reasonably requested, or

• you withhold or withdraw any consents that we may need to process, transfer or disclose Customer Information for the Purposes (except for purposes connected with marketing or promoting products and services to you), or we have, or a member of PayKit has, suspicions regarding Financial Crime or an associated risk.

1. We may:

• be unable to provide new, or continue to provide all or part of the, Services to you and reserve the right to terminate our relationship with you;

• take actions necessary for us or a member of PayKit to meet the Compliance Obligations; and/or

• block, transfer or close your account(s) where permitted under the Laws of Kenya.

1. You agree that We shall not be liable for any loss or damage arising from or incidental to our use, collection, processing and sharing of Customer Information, and any action we have taken in relation to this Section.

2. Should we wish to use your information for marketing purposes, we will inform you prior to such use. You shall be entitled to prevent such usage by informing us, within 10 days of being informed of the proposed use, that you do not wish to disclose such information. You can also exercise the right at any time by contacting us at support@paykit.africa

1. Changes to privacy policy

Any changes we may make to this Policy in the future will be posted on this page and, where appropriate, notified to you when you next start the App or log onto one of the Service Sites. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App or the Services. In any event, by continuing to use the App or any Services after the posting of any changes, you confirm your continuing acceptance of this Policy together with such changes, and your consent to the terms set out therein.

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to support@paykit.africa