1. INTRODUCTION

1.1. This Privacy Policy ("Policy") describes NEWBELASH TECHNOLOGY LTD's ("MoLoan", "we", or "us") policies regarding the collection, handling, processing, and distribution of personal information that you have voluntarily provided to us when you download and utilize our mobile application, "MoLoan: Personal Loan App," or make use of the services offered on www.moloan.top (hereinafter referred to as the "App" and together with the website, the "Platform").

1.2. MoLoan is dedicated to safeguarding your privacy and personal information. To learn about our policies and how we will handle your personal data, please carefully read the terms of the policy that follow. This Policy lays out the foundation for how we will process any personal information we get from you, learn about you, or that you give us.

1.3. By providing us with the consent to process your personal data, you acknowledge that we will collect, store, use, and disclose your personal data in accordance with this Policy.

2. THE DATA WE COLLECT ABOUT YOU

2.1. With your permission, we gather, transfer, and retain your personal information on our secure MoLoan server (https://www.moloan.top) in order to provide you with or in relation to the Services. To provide you with the Services, we only need to collect and process a small amount of your personal data. Such private information consists of:

Identity and profile-related data: This includes your first and last name, parents' name, date of birth, gender, photographs, educational qualifications, purpose of loan, house ownership, employment status, company name, contact information (including addresses, email IDs and phone numbers) and marital status.

KYC data: This includes identification documents issued by the government or other authorities, and includes details of or pertaining to your ID card.

Transaction data: This includes details of transactions that may occur through the Platform or in connection with the Services. For example, transaction data may include the services you have sought or availed through the Platform or confirmations of such services.

Data from SMSs: With your permission, we collect, transmit and store transactional SMS data from your phone on our secured MoLoan server (https://www.moloan.top) to verify and analyse your financial position, to determine your cash flow, credits, income, and spending pattern. We do not collect, read or store any personal SMSs account details etc.

Financial data: This includes your past credit history, income details, details of loans issued or otherwise applied for through the Platform, payments, and repayments thereof, bank account details, and bank account statements.

Device data: This includes your IP addresses, browser types and versions, time zone settings, operating systems, and device information. We collect, transmit, and store such data on our secured MoLoan server (https://www.moloan.top). This data is collected for the purpose of data analytics.

App data: We gather, send, and keep track of the data from the installed application on our safe MoLoan server (https://www.moloan.top). The package name of each installed application is the only information we need to determine creditworthiness and create personalized loan offers.

2.2. We do not access your mobile phone resources such as contact list, call logs, telephony functions, and files & media (except as disclosed above in order to enable you to upload documents). We do not collect your biometric data. However, we may access your camera, microphone, location (fine and coarse GPS data), or any other facility solely for the purpose of onboarding or KYC checks, after obtaining your explicit consent. We collect, transmit, and store above mentioned data on our secured MoLoan server (https://www.moloan.top).

2.3. In order to grant you access to the Platform and Services, we must gather your personal data. We may occasionally need to gather personal information as mandated by the Terms or the law. We won't be able to carry out our responsibilities under the agreement we have with you or are attempting to enter into with you if you don't give us such data when we ask for it (for example, to provide you with features of the Services). In this situation, we might have to restrict or terminate your use of the Services (or a portion of them).

3. HOW WE COLLECT DATA ABOUT YOU

3.1. We use different methods to collect and process personal data about you. This includes:

Details that you give us: This is the data that you voluntarily provide to us when you use our services or communicate with us (by chat, email, or other means) about identification, contact, KYC, finances, and device usage. It includes the data you submit when you utilize a platform feature, register to use the services, share data via the platform, or report an issue with the platform or our services. We shall maintain a record of the information exchanged during communication with us.

Information we collect about you and your device: Each time you visit the Platform or use the Services, we will automatically collect personal data through the use of tools like cookies.

Information we receive from other sources including third parties and publicly available sources: We will receive personal data about you from various third parties and public sources including our third parties, Google analytics for advertising and user analytics purposes, and other publicly available sources. This information is used for conducting fraud checks, improving the Services and offering the credit products most suitable to you.

3.2. Please note that we do not have any control over personal data that you may choose to make publicly available. For example, if you post reviews, comments, or messages on public sections of the Platform or on an application store (such as the Play Store), you do so at your own risk. We are not liable for third-party misuse of such data.

4. HOW WE USE YOUR PERSONAL DATA AND FOR WHAT PURPOSES

4.1. We will only use your personal data in accordance with the applicable law. Most commonly, we will use your personal data to provide you with the Services, or where we need to comply with a legal obligation.

4.2. By using our Services and opening an account on the Platform, you consent to receive communications from us, our associate partners, and affiliates via phone, email, or other means regarding the Services that we have provided to you. This includes, but is not limited to, informing you of the credit products that you can obtain, offering customer support, resolving complaints or disputes regarding the Service or the credit product that you have obtained, and in connection with the collection services that we provide to the Lender for the credit facilities that you have accessed.

4.3. In general, we use your personal data for the following purposes and activities undertaken without direct human supervision or control:

To register you as a user of the Platform;

To provide you with the Services;

To communicate to you details of the products and services as requested by you or process queries raised by you on the Platform;

To facilitate your KYC as per the instructions of the Lender;

To facilitate your application to avail loan and otherwise in connection with your obtaining of credit facilities from regulated entities including our lending partners;

To manage our relationship with you, including notifying you of changes to any Services;

To administer and protect our business and the Platform, including troubleshooting, data analysis, system testing, and performing internal operations;

To send you communication, including through WhatsApp business messages, in relation to your use of the Platform or Services;

To conduct data analytics, monitor trends so we can improve the App and Services;

To improve our business and delivery models;

To perform our obligations that arise out of the arrangement we are about to enter or have entered with you;

To enforce our Terms;

To undertake marketing services, including sending you promotional messages in relation to Services that are offered by us presently or may be offered in the future;

To respond to court orders, establish or exercise our legal rights, or defend ourselves against legal claims;

5. HOW WE SHARE YOUR PERSONAL DATA

5.1. You agree and acknowledge that we may gather, compile, and share any information about you with third parties only with your express consent in order to provide the Services to you (that is, in connection with loan applications and your loan journey), whether or not you directly provide it to us (via the Services or otherwise). This includes but is not limited to personal correspondence like emails, instructions from you, etc. This may involve, but is not restricted to, consultants, attorneys, auditors, storage companies, data analytics companies, and lenders (as described in the Terms). We may also share this information with other entities in the MoLoan group in connection with the above mentioned purposes. If you fail to provide consent for sharing of such data when requested by us, we may not be able to perform our obligations under the arrangement we have with you or are trying to enter into with you. In this case, we may not be able to provide the Services to you.

5.2. You agree and acknowledge that by using our Services and creating an account on the Platform, you authorise us, our associate partners, and affiliates to contact you via email, phone, or otherwise. This is to ensure that you are aware of all the features of the Services.

5.3. You agree and acknowledge that we may share data where we are required by law, any court, a government agency, or authority to disclose such information. Such disclosures are made in good faith and belief that it is reasonably necessary to do so for enforcing this Policy or the Terms, or in order to comply with any applicable laws and regulations.

6. ACCESS AND UPDATING YOUR PERSONAL DATA

You hereby warrant that all personal data that you provide us with is accurate, up-to-date, and true. When you use our Services, we make best efforts to provide you with the ability to review and correct inaccurate or deficient data, subject to any legal requirements. We shall verify the accuracy of the new personal data you provided to us.

7. DATA SECURITY

7.1. We implement appropriate security measures and access controls to protect your personal data from unauthorised access, and follow technology standards prescribed by applicable law, including the Information Technology Act, 2000, Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 and by RBI ensuring up-to-date physical security, such as secure areas in offices; electronic safeguards, such as passwords, firewalls, and encryption; and secure development procedures. Our safety and security processes are audited by a third party cyber security audit agency from time to time.

7.2. In the scenarios where personal information collection is mandatory, for instance any information required to pull bureau report or for loan application, we encrypt the data with the latest security algorithms before transmitting the data. All such data is encrypted at rest.

7.3. Information you and Lenders provide and receive during the Services is transmitted through a secure sockets layer (SSL) transmission. We encrypt and store personal information wherever it is possible. No data is shared with any third party unless until it is a core feature to serve the end-user, in all such scenarios the user consent is taken.

7.4. We restrict access to your personal information only to those employees who are required to know such information in order to provide our Services to you. We train our employees on all our security procedures.

8. DATA RETENTION AND DESTRUCTION

For information about our retention and destruction practices, please refer to the Schedule to this Policy.

9. YOUR LEGAL RIGHTS

9.1. Under certain circumstances, you have the right to:

Request the erasure of your personal data: This enables you to ask us to delete or remove personal data. We shall comply with any request, subject to applicable laws and the terms of the loans that are sanctioned through the Platform.

Right to deny consent: This enables you to deny us the consent necessary to process your personal data. If you exercise this right, it may impact or restrict our ability to provide Services to you.

Right to revoke consent: This enables you to withdraw consent provided to us previously for specific use of information, storing of information, sharing your information with third parties and Lenders and consent to contact you. We shall comply with any request, subject to applicable laws and the terms of the loans that are sanctioned through the Platform.

Right to rectify: We disclaim all liability and responsibility for the authenticity of the information provided by you to Us. However, you have the right to review and correct, update and/or amend your information provided to us previously for it to be accurate, complete and up to date. However, kindly note that in a situation where you deny consent, withdraw consent, avail the right to be forgotten, or provide inaccurate information, you may not be able to avail the entire scope of our Services, and in such instance, we reserve the right to not provide you access to our Services or any part thereof.

9.2. Notwithstanding your right 9.1 (a) and (c), we reserve the right to retain information to the extent required for below mentioned purposes:

Comply with applicable laws;

Enforce our legal rights; or

To provide any information required by regulatory authorities investigating any fraud or illegal activities.

9.3 Nevertheless, if your application for a loan was submitted to a lender or if you have taken out a loan from one of our lenders, they may get in touch with you regarding the loan application and payment of dues. They will also keep processing your information until all loan obligations are satisfied. Your information may be kept by the lenders for as long as necessary to comply with applicable legal requirements. The lenders may also ask us to keep records if they have contracted us to handle any activities related to the loan product, like collecting payments. In those situations, we will have to hold onto Your information for the length of time the lender specifies.

9.4. If you wish to exercise any of the rights set out above, please write an email to the Grievance Officer, whose details are mentioned in Section 15 of this Policy, providing in as much detail as possible, the right(s) you wish to exercise. Please also include a description of the personal data you believe we hold or process about you, so that we may be able to locate such personal data. In the event that we need additional information from you, our Grievance Officer will contact you further.

9.5. We will be able to reply to your request(s) within 30 (Thirty) days of raising the request. In the event that we are not able to respond to or acknowledge your request within 30 (Thirty) days of receipt due to any reason, we will inform you.

10. TRANSFER OF PERSONAL DATA

10.1. We provide your information to lenders and other parties so they can get in touch with you about any loan products you show interest in, or so they can complete an application for a loan, get a KYC check, gather KYC documentation, authenticate a bank account, run employment checks, register NACHs, and handle loan repayment.

10.2. A list of our Lenders is available https://www.moloan.top and list of the key third party service providers that gain access to your information during the loan journey is provided [here],

11. LINKS TO THIRD PARTY WEBSITES

Periodically, our services might include connections to and from the websites of our affiliates, financial institutions, partner networks, service providers, and advertisers, as well as services offered by them ("Third Party Services"). Please be aware that the privacy policies of any Third Party Services that you may be able to access through our Services are their own. Regarding the policies or any personal information that might be gathered via such Third Party Services, we disclaim all liability. Before providing any personal information to these websites or using their services, please review their policies.

12. COOKIES

12.1. Cookies are small data files that are stored on your device. We use cookies and other tracking technologies to distinguish you from other users of the Services and to remember your preferences. This helps us provide you with a good experience when you use our Services and also allows us to improve the Services.

12.2. We identify you by way of using cookies. The cookies shall not provide access to data in your device such as email addresses or any other data that can be traced to you personally. The data collected by way of cookies will allow us to administer the Services and provide you with a tailored and user-friendly service. The cookies shall enable you to access certain features of the Services. Most devices can be set to notify you when you receive a cookie or prevent cookies from being sent. If you prevent cookies from being sent, it may limit the functionality that we can provide when you visit the Platform or try to access some of the Services.

12.3. Additionally, you may encounter cookies or other similar technologies on certain pages of the Platform that are placed by third parties. We do not control the use of cookies by such third parties.

13. BUSINESS TRANSITIONS

You agree and acknowledge that in the event we go through a business transition, such as a merger, acquisition by another organisation, or sale of all or a portion of our assets, your personal data might be among the assets transferred.

14. CHANGE IN PRIVACY POLICY

14.1. We keep our Policy under regular review and may amend it from time to time, at our sole discretion.

14.2. The terms of this Policy may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by email or phone number through SMS.

15. GRIEVANCE OFFICER

You may contact our Grievance Officer with any enquiry relating to this Policy or your personal data.

Address: Ghana, CENTRAL, Agona West Municipal, Swedru, 9 JUNCTION,HNO 9, AGONA SWEDRU NEAR FAN MILK DEPOT BUILDING

Email Address: service@moloan.top

16. GOVERNING LAW AND DISPUTE RESOLUTION

The provisions of governing law and dispute resolution mechanism as specified in the Terms shall be applicable to this Privacy Policy.

SCHEDULE
DATA RETENTION AND DESTRUCTION POLICY
1. OVERVIEW
This Data Retention and Destruction Policy describes MoLoan's policy on data retention and destruction.

2. HOW LONG DO WE STORE YOUR DATA
You understand and agree that we may continue to store and keep your personal information as long as it's needed to comply with legal requirements, comply with applicable regulations, or support you in any future legal disputes. After the loan is closed, the KYC, device location, and SMS data will be erased or converted into anonymized data, making them no longer considered personal data, within the legally mandated time frame. If you are not currently in the process of obtaining a loan or service, all additional information will be erased or converted into anonymized data at the customer's request. However, in some instances, we will be unable to facilitate requests for the deletion of your data in compliance with legal obligations, or in accordance with applicable laws, which may require us to store data for longer periods of time.

3. OUR DATA DESTRUCTION PROTOCOLS
Upon completion of the retention period for each category of personal data as described above, we shall delete or destroy, to the extent technically possible, personal data in our possession or control, or render the personal data into anonymised data, so that it no longer constitutes personal data.