Privacy Policy

Update Date： September 6, 2024.

Introduction
Definitions
How we collect your personal data
How we use your personal data
Retention of your Personal data
Transfer of your personal data
Disclosure of personal data
Security of personal data
Privacy of minors
Links to other websites
Your rights
Changes to this Privacy Policy
Contact Us

Introduction：

This Privacy Policy describes all of our policies and procedures for collecting, using, and disclosing information about you when you use our Services, and tells you about your privacy rights and how the law protects you. If you do not agree with our policies and practices, you may choose not to use our Services. This policy may change from time to time (see section 12 ‘Changes to this Privacy Policy’).

We use your personal information to provide and improve the services. By accessing or using the Services, you consent to the collection and use of information in accordance with this Privacy Policy.

Definitions

“You” means the individual accessing or using the Services.
“Account” means a unique account created for you to access our Services or portions of our Services.
“Device” means any device that can access the Services, such as a computer, mobile phone or digital tablet.
“Personal data” means any information relating to an identified or identifiable person.
“Usage data” refers to data that is collected automatically, whether generated through the use of a service or from the service infrastructure itself (e.g., the duration of a page visit).
“Cookies” are small files that a website places on your computer, mobile device or any other device that contain details of your browsing history on that website and its many uses.
“Service” means an application or a website, or both.
“Website” means Sunlit Loan, which can be accessed at: https://www.sunlitloan.club
“Application” means the software programme provided by the Company called Sunlit Loan that you download on any electronic device.
“Company” (referred to in this Agreement as ‘Company’, ‘we’, ‘us’ or ‘our’) means TERAVIK CASHPOINT LTD
“Affiliate” means an entity that controls, is controlled by or is under common control with a party, where ‘control’ means ownership of 50 per cent or more of the shares, equity interests or other securities that entitle one or more persons to elect directors or other managerial powers.
“Service provider” means any natural or legal person who processes data on behalf of the company. It means a third-party company or individual hired by the company to facilitate the services, to provide the services on behalf of the company, to perform services related to the services or to assist the company in analysing the way in which the services are used.
“Third Party Social Media Services” means any website or any social networking site where Users can log in or create an account to use the Services.
“Country” means：Uganda

How we collect your personal data

Personal Data：

While using our service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify You. Personally, identifiable information may include, but is not limited to: name、idcard、birthday、gender、occupation infornation、income infornation、marital infornation、education information、emergency contacs information

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device.

If You decide to grant us access to a Third-Party Social Media Service, We may collect with your consent Personal data that is already associated with Your Third-Party Social Media Service’s account, such as Your name, Your email address and Your activities .

You will also have the option of sharing additional information with the Company through Your Third-Party Social Media Service’s account. If You choose to provide such information and Personal Data, during registration or otherwise, You are giving the Company permission to use, share, and store it in a manner consistent with this Privacy Policy.

Information Collected When Using Our Application:

Sunlit Loan collection and processing of contact details on your device is only used for credit assessment and fraud detection. We only collect the metadata required to fulfil these specific purposes. This data is collected in strict compliance with the Uganda Data Protection and Privacy Act, 2019 and the General Data Protection Regulation (GDPR) where applicable.

We ensure transparency in our practices by informing users about the data we collect, the reasons for its collection, and how it will be used. Explicit consent is obtained from users before any contact information is collected. We also conduct regular reviews and updates of our privacy practices to ensure ongoing compliance and the protection of your data. Additionally, we implement robust security measures to safeguard the contact information we collect against unauthorized access or misuse.

We use this information to provide features of Our Service, to improve and customise Our Service. The information may be uploaded to the Company’s servers and/or a Service Provider’s server or it may be simply stored on Your device. You can enable or disable access to this information at any time, through Your Device settings. We will never communicate with any person from your contact list. In case you are nominating a person as your guarantor, you are also confirming that you have sought approval from the named person with regards to processing their data (name and contact details) and that they are willing to act as a guarantor for this loan facility.

3.4.1. Device Permissions for Personal Data access Depending on the User’s specific device, we may request certain permissions that allow it to access the User’s device data as described above.

By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.

The exact procedure for controlling app permissions may be dependent on the User’s device and software.

Please note that the revoking of such permissions might impact the proper functioning of the Application.

Below is the specific data we need to request permissions from the user’s phone

SMS:

Collection of content：When you authorise the relevant permissions, we will collect your mobile phone SMS data and encrypt it for uploading to our servers(https://app.sunlitloan.club), the data collected includes the SMS content, sender number, sender name and the time of sending.

Data Usage: We read, screen, and analyse a user’s finance-related text messages only if we are assessing their fraud score line as well as their credit rating.

Data Security： The data will be encrypted and uploaded to our dedicated server (https://app.sunlitloan.club) using the HTTPS protocol. We will never share this data with third parties without your permission.

Call Log:

Collection of content: When you authorise the relevant permissions, we will collect and encrypt your call data and upload it to our servers (https://app.sunlitloan.club). The data collected includes the type of call, the duration of the call and the number of the call.

Data Usage: We collect your call logs to verify that you have installed and are using our application on the same device. By making calls and using voice verification, we ensure that your device is secure and effective.

App List:

Collection of content：When you authorise the relevant permissions, we collect and encrypt data from third-party applications installed on your phone and upload it to our servers (https://app.sunlitloan.club). The data collected includes package name, app name, date of installation, source of installation, app signature information, etc.

Data Usage:

Help us assess your credit score. This information is used to understand your financial behaviour and spending habits.
To ensure the security of your account, we may check the apps on your device to identify and prevent applications that may compromise security.
We may analyse your spending preferences based on the apps you have installed in order to recommend the most suitable loan products and personalised offers for you.
For fraud prevention purposes, we may collect and analyse apps on your device to identify potentially risky behaviour.

Emergency Contacts:

Collection of content：Before you provide emergency contact information, please ask the emergency contact for permission. We require you to provide emergency contact heart have including name, phone number, and relationship to you. We collect your emergency contact data and encrypt it, then upload it to our server (https://app.sunlitloan.club).

Data Usage:

We use emergency contacts to help when users are unreachable or face unexpected situations (e.g. facing potential fraud).
Emergency contacts may be contacted to find out about a user’s situation when the user fails to make repayments by the due date or when fraud is suspected.

Mobile Phone Device Information

Collection of content：When you authorise the relevant permissions, we collect and encrypt information about your phone’s settings and upload it to our servers (https://app.sunlitloan.club). The data collected includes device identifiers (device ID, serial number), hardware information (device make and model, processor, memory, storage, battery status), operating system and software version (OS version, firmware version), network and connectivity information (SSID, carrier, network type, IP address), and so on.

Data Usage: This permission is used to collect device information, including hardware specifications, operating system version, and unique device identifiers. This information enhances service experience, helps detect and prevent fraud, ensures account security, identifies genuine users, and provides effective technical support and troubleshooting.

Album Pictures：

Collection of content: The SDK used in our apps may request access to your photo albums or media library to enable you to upload relevant images when you submit feedback or report an issue. We will only access this data with your explicit consent and we will not scan all the photos in your albums unless you actively choose to upload them.

Data Usage: When you upload images in your feedback, the images will only be used to diagnose and address the issues you report. These images will help our technical team to identify the problem and provide a solution faster. We will not use these images for any other purpose such as advertising, data analysis or third party services.

Data Security：

In order to optimise our image processing services, we may share the images you choose to upload with our image processing service providers, but these third parties will not use this data for any other purpose.
In order to protect your uploaded images, we use advanced encryption technology to ensure the security of the data during transmission and storage. Image data is only stored for the duration of the issue and will be deleted as soon as the issue is resolved or the user requests it to be deleted.

Tracking Techniques And Cookies.

We use cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyse Our Service. The technologies we use may include:

Cookies or Browser Cookie :. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept cookies, you may not be able to use some parts of our service. Unless you have adjusted your browser setting so that it will refuse Cookies, our Service may use Cookies.

We use both Session and Persistent Cookies for the purposes set out below:

1.Necessary / Essential Cookies

Type: Session Cookies Administered by: Us Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.

1.Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies Administered by: Us Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

1.Functionality Cookies

Type: Persistent Cookies Administered by: Us Purpose: These Cookies allow us to remember choices you make when you use the Website, such as remembering your login details or language preference. The purpose of these cookies is to provide you with a more personal experience and to avoid having to re-enter your preferences every time you use the Website.

For more information about the cookies, we use and your choices[1] regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

How we use your personal data

The Company may use Personal Data for the following purposes:

To provide and maintain our Service, including to monitor the usage of our Service.
To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
To manage Your requests: To attend and manage Your requests to Us.
For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share your personal information in the following situations:

With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You. You authorize Sunlit Loan to store and share your phone number with third-party providers and credit-scoring institutions for verification purposes . You understand that your phone number will be collected and stored securely by Sunlit Loan and will not be sold.
For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.
With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal data

We will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy, which will normally be three years. You have the right to request the deletion of the data we have collected about you. However, we will retain and use your personal data to the extent necessary to fulfil our legal obligations (for example, if we are required to retain your data to comply with applicable law), resolve disputes and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analyses. Usage data is generally retained for a short period of time, with the usual duration usually being less than 15 days, unless the data is used to enhance security or improve the functionality of our services or we are legally obliged to retain the data for a longer period of time.

Transfer of your personal data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Disclosure of your personal data

7.1 Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

7.2 Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

7.3 Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to: Comply with a legal obligation Protect and defend the rights or property of the Company Prevent or investigate possible wrongdoing in connection with the Service Protect the personal safety of Users of the Service or the public Protect against legal liability

Security of your personal data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Privacy of minors

Our services are not directed to anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and become aware that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from anyone under the age of 18 without verifying parental consent, we will take steps to delete that information from our servers. If you believe that we might have information from or about anyone under the age of 18, please contact us using the information provided in the ‘Contact Us’ section below.

If we are required to obtain your consent as a legal basis for processing your information and your country requires parental consent, we may obtain your parents’ consent before collecting and using that information.

Links to other websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Your rights

You have rights under data protection laws in relation to your personal data. These include rights to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. 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 erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party). You also have the right to object to 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 restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios If you want us to establish the data’s accuracy Where our use of the data is unlawful but you do not want us to erase it Where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen , your personal data in a structured, commonly used, machine readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a 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 a time when you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us using the information provided in section 13.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

In addition to your existing rights under applicable law, if you would like to raise concerns about any breach of this Privacy Policy, you can contact us via section 13.

Changes to this Privacy Policy

We may update our privacy policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

Before the changes take effect, we will notify you via email and/or a prominent notice on our Services and update the ‘Update Date’ on the left at the top of this Privacy Policy.

We recommend that you check this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when posted on this page.

Your continued use of the Service after we have made changes is deemed acceptance of those changes.

Contact Us

By email: support@sunlitloan.club

By Call: +256 (0)707218266, +256 (0)760490638

By visiting this page on our website: https://www.sunlitloan.club

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