1.GENERAL
At U Wallet , we are committed to providing you with the best service possible. Paramount to this is protecting and respecting your privacy and personal data which we are, and always will be, committed to doing.
The registered name of U Wallet is UNITED AFRICA TECH VILLAGE LIMITED
You should read this policy carefully because it sets out the basis on which any personal data we collect from you, or that you provide to us, through the U Wallet application , and any products or services (the Services ) which may be offered or made available to you via the U Wallet application from time to time (the App ) , your creation and use of your U Wallet Account (your Account ) and your use of our credit services (together with the App, and your Account, the Services as further defined in this privacy policy and our Terms of Use) will be processed by us. This policy also sets out the basis upon which we collect personal data from you when you visit our website (the Website ).
We strongly encourage you to read the following information to fully understand our views and practices regarding your personal data and how we will treat it.
Updates
At all times, we keep our privacy practices and the terms of this policy under review to ensure your personal data is processed as securely as possible. This policy was last updated on the date given above. Any changes to this policy will be posted online, within the App and, where reasonably practicable , emailed to you.
2. INFORMATION WE MAY COLLECT FROM YOU
To provide you with the Services, we must collect, store, transfer, analyse and otherwise process certain of your personal data. This section of the policy explains what information we will collect about you and under what circumstances.
The personal data we process includes:
When you register for a U Wallet account, we collect your mobile phone number. This information is collected to help you complete account registration and protect the security of your account. If you do not provide such information You may not be able to use our services normally.
When you use the U Wallet service, to ensure normal use of our service. Maintain the normal operation of our services. Improve and optimize our service experience and protect the security of your account. We collect the device brand, device information such as version, screen resolution, ROM/RAM size, CPU core number, and a list of installed applications. We will provide more stable personalized service according to your device.
Authorizes the application to access your current location information to validate if your loan application falls within our service area.
3. HOW WE USE YOUR PERSONAL DATA
In this section, we explain how we use your personal data and the reasons for such use, and we also explain the lawful grounds under certain data protection legislation that we rely on to do so. Please note we only ever process your personal data when it is lawful for us to do so.
3.1 To provide the Services and the Website
We process your personal data:
to verify your identity and create your U Wallet Account;
to provide you with, and operate, the Services ; ;
to create an account connection between your U Wallet Account and a separate third-party account or platform used to add value to your account;
to perform creditworthiness and other financial standing checks, evaluate applications, and compare information for accuracy , verification and payment/repayment collection purposes; and
to provide the Website.
We process your information for the purposes set out above on the following lawful grounds:
our legitimate interest in providing payment related Services, operating and improving U Wallet , marketing our products and services to you and others and being as efficient as we can about complying with legal duties, obligations and regulations that apply to us and keeping our records up to date;
where it is necessary for the adequate performance of a contract with you and to take steps requested by you prior to you entering into a contract with us; and
compliance with legal obligations to which we are subject, for example in relation to carrying identity validation and other checks.
3.2 To perform obligations arising from the contract we have in place with you
We process your personal data:
to perform the purpose of the Terms of Use, namely to provide the Services to you.
We process your information for the purposes set out above on the following lawful ground:
where it is necessary for the adequate performance of a contract with you and to take steps requested by you prior to you entering into a contract with us.
3.3 To secure your Account and your money, and us and our Services
We process your personal data:
for anti-fraud and risk identification and management purposes. We use your personal data to comply with legal obligations relating to fraud and other financial crimes, and to ensure you, your personal data and your finances are protected; and
to verify activity, and to promote safety and security on and off our Services. Should we believe you have breached our Terms of Use, or are acting suspiciously, we may conduct an investigation to ensure you are not breaching the Terms of Use or breaking the law.
We process your information for the purposes set out above on the following lawful grounds:
given our legitimate interest in ensuring the safety and securing your Account, your money, our Services, us, our group companies, and any necessary third parties, and to secure us from harmful security related breaches;
where it is necessary for the adequate performance of a contract with you and to take steps requested by you prior to you entering into a contract with us;
compliance with legal obligations to which we are subject, for example in relation to money laundering; and
to protect yours or another individual’s vital interests, for example if we have to investigate harmful acts.
3.4 To communicate with you
We will process your personal data:
to communicate with you about your Account, including with respect to any potential fraudulent activity or any queries you have raised.
We process your information for the purposes set out above on the following lawful grounds:
our legitimate interest in ensuring the safety and securing your Account, your money, our Services, us, our group companies, and any necessary third parties;
where it is necessary for the adequate performance of a contract with you and to take steps requested by you prior to you entering into a contract with us; and
compliance with legal obligations to which we are subject, for example in relation to carrying identity validation and other checks.
3.5 To market to you
We will process your personal data:
to send you marketing materials, including in relation to other products and services provided by us and/or our group companies.
We process your information for the purposes set out above on the following lawful grounds:
if you provide is your consent to do so; and
in certain circumstances, given our legitimate interests in marketing our products and services to you and others.
3.6 To customise , improve and enhance our Services and/or Website
We will process your personal data:
to analyse your use of the Services so we can learn more about what you like or don’t like about our Services. We may also analyse your behaviour when using the Services to ensure you do not miss out on any offers or opportunities. In doing so, we will use the information we collect to communicate with you, for example, if you have not logged into the App for a while or if you have not completed a transaction with one of our e-commerce merchants;
to respond to any of your queries; and
to improve and customise our Services and/or Website.
We process your information for the purposes set out above on the following lawful ground:
our legitimate interest in providing payment related Services and/or Website, operating and improving U Wallet and/or Website, marketing our products and services to you and others and being as efficient as we can about complying with legal duties, obligations and regulations that apply to us and keeping our records up to date.
4. SECURITY OF YOUR PERSONAL DATA
We take your privacy very seriously and work hard to protect your data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have put in place appropriate security measures to prevent this from happening, for example we use encryption tools to protect the content of your messages and calls.
In addition, we limit access to your personal data to those employees, volunteers, agents, contractors and other third parties (as listed above) who have a need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
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 through our Services; 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 your data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
5. HOW LONG WE KEEP YOUR PERSONAL DATA FOR
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
With this in mind, we have determined that:
as required by applicable law, particularly those that relate to anti-money laundering, we will store your financial data for ten years from the date of the transaction, or longer if subject to the below retention period; and
upon cancelling your Account, we will store all data related to your Account, including personal data and transaction data, for up to five years from the date of cancellation before permanently deleting it
6. YOUR RIGHTS
In certain circumstances and subject to certain jurisdictional restrictions, you may have the right 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.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in certain scenarios.
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.
Withdraw consent at any time where we are relying on consent to process your personal data.
Complain to the appropriate regulator for any data protection issues. We would, however appreciate the chance to deal with your concerns before you approach the regulator so please contact us in the first instance.
If applicable to you, t o exercise one of the above rights, please contact us using the details provided above.
We may need to request specific information from you to help us confirm your identity and ensure you are able to exercise the right you wish to exercise. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.