Privacy Policy

Vuna Now is committed to protecting your privacy (hereinafter referred to as "we", "us", or "our"). We understand the importance of personal information to you. This Privacy Policy is intended to explain how we collect, use, store, share, and protect your personal information when you access or use the Vuna Now mobile application and related services (collectively referred to as the "Services").

Operator: PAYNACLE DIGITAL LIMITED | D-U-N-S Number: 850395197

Before downloading, registering, or using the Services, please read and understand this policy carefully. By starting to use the Services, you acknowledge that you fully understand and agree to the entire content of this policy.

1. Information We Collect

We collect information based on the principles of legality, justification, and necessity through the following methods:

1.1 Information You Actively Provide

When you register an account or apply for financial services, we may collect:

• Identity Information: Full name, date of birth, gender, and government-issued identification details.
• Contact Information: Mobile phone number and email address.
• Background Information: Occupation, income status, marital status, and educational background.
• Financial Details: Bank account information, mobile money details, and any other information you submit related to financial products.

1.2 Device and Technical Information

To ensure account security and implement preventive measures, we automatically record the following when you use the Services:

• Device Characteristics: Device model, manufacturer, operating system version, unique device identifier, and IP address.
• Network Information: Mobile network operator, connection type, and Wi-Fi status.
• Log Data: App version, login records, clickstream data, session duration, and diagnostic data.

1.3 Emergency Contact Permissions

We do not access your full communication records. You only need to voluntarily provide the names and phone numbers of your emergency contacts. This data is used exclusively for identity verification and risk assessment.

1.4 Cookies and Tracking Technologies

Purpose of Use: We utilize cookies and similar technologies to analyze user behavior and optimize service functions. These technologies help us enhance your user experience and ensure the proper functioning of the website.

Self-Management: You can change your cookie preferences at any time through your browser or device settings. You may choose to accept, reject, or delete specific tracking technologies.

1.5 Information from Third Parties

To the extent permitted by law, we may obtain supplementary information about you from the following channels:

• Credit reference bureaus (for creditworthiness assessment).
• Identity verification service providers and payment service platforms.
• Affiliated companies and business partners.

1.6 SMS Permission (SMS Permission Service Description)

Scope and Filtering Logic: To ensure the security of your loan and effectively prevent fraudulent activities, with your explicit authorization, our app will locally detect SMS messages containing financial or fraud-related keywords (primarily from banks and service providers). We only process SMS messages related to financial or fraud analysis; all non-financial SMS data, personal social privacy, or verification codes (OTPs) will be directly filtered out and not retained.

Purpose of Use: We will use this information to analyze your spending habits, assess credit risk, verify loan repayment confirmations, or identify suspicious transactions through SMS for credit risk modeling and anti-fraud identification.

Data Security and User Consent Mechanism: When you first use a feature that requires this permission, a clear prompt will appear on the screen explaining the reason for requesting the permission and seeking your consent. The collected financial data (including the sender, date, and content of the SMS) will be transmitted via secure HTTPS encryption and stored on our secure server at https://api.vunanow.com.

Revocation and Consequence: You may disable the SMS reading feature at any time in your device's permission management settings. However, please be aware that once you disable or revoke this permission, we will be unable to access SMS data for credit assessment, which may result in us being unable to approve your loan application or provide you with full loan services. We are committed to complying with all applicable laws and regulations, and will never share your SMS content with any third party without your consent.

2. How We Use Your Information

We collect information to provide you with stable, secure, and personalized financial services. Purposes include:

• Identity Verification and Management: Creating and maintaining your account and verifying your true identity.
• Credit Assessment: Evaluating your eligibility for services and performing credit analysis and risk pricing.
• Transaction Processing: Completing disbursements, processing repayments, and related financial settlements.
• Security and Anti-Fraud: Identifying potential money laundering, fraud, and illegal activities to protect account security.
• Customer Service: Responding to your inquiries and complaints and providing technical support.
• Legal Compliance: Fulfilling applicable laws, regulations, regulatory directives, and court judgments.
• Service Optimization: Improving product functions and conducting data analysis and market research.

3. How We Share Your Information

We undertake to maintain the confidentiality of your information. However, we may share your information in the following specific circumstances:

• Service Providers: Sharing with third parties that support our business, including cloud storage infrastructure, third-party payment institutions, and identity verification or risk control agencies.
• Credit Bureaus: Reporting relevant credit records to credit reference bureaus in accordance with regulatory requirements.
• Legal Requirements: Responding to subpoenas, court orders, law enforcement investigations, or other legal processes.
• Corporate Changes: In the event of a merger, acquisition, bankruptcy liquidation, or asset sale, your information may be transferred as part of the assets.
• Affiliated Companies: To provide you with consistent services, we may share necessary information among our internal affiliates.

Note: We strictly prohibit the sale of your personal information to any third party for their independent commercial purposes.

4. International Transfer and Storage

Your personal information may be transferred to, stored, or processed on servers located outside your country of residence. Regardless of where the information is stored, we will implement legally recognized security safeguards (including signing standard contractual clauses) to ensure your data receives a level of protection equivalent to that required by local laws.

5. Data Retention

We retain your personal data only for the period necessary to achieve the purposes described in this Privacy Policy (including providing financial services and risk control assessments).

During Retention: Your identification information, loan agreements, and credit history assessment data will be retained until the expiration of the relevant legal statute of limitations. This ensures that records are available for review in the event of legal or contractual disputes.

Legal Compliance Obligations: In accordance with the laws and regulations of Uganda (including but not limited to tax audits and anti-money laundering requirements), even if you have canceled your account or stopped using Vuna Now services, we are obligated to securely store transaction records and core financial data for the mandatory statutory period.

Expiry Processing: Once your personal information exceeds the statutory retention period or is no longer necessary for our business operations, we will take strict security measures to permanently delete or de-identify the information to ensure it cannot be re-identified or restored.

6. Data Security Safeguards

We implement multi-layered technical and administrative measures to ensure your personal information is strictly protected throughout its lifecycle.

• Secure Transmission Protocols: To prevent data interception during internet transmission, we use industry-standard encrypted communication protocols.
• Encrypted Storage and Privacy Commitment: Your sensitive data is protected by advanced encryption technology during static storage to prevent unauthorized access, leakage, or tampering.
• Authorization Control and Withdrawal: We fully respect your right to control your personal information. By default, we only begin collecting specific data after obtaining your active authorization. You can manage permissions at any time through your mobile device's system settings.

7. Your Rights and Choices

You have the following rights regarding your personal information:

• Access and Correction: You may view and update your personal profile.
• Withdrawal of Consent: You may withdraw permissions (including location or camera) through system settings at any time, though this may result in certain functions becoming unavailable.
• Account Cancellation: You may apply to cancel your account. Once canceled, we will cease providing services to you.

8. Children's Privacy

The Services are restricted to adults aged 18 (or the legal age of majority in your jurisdiction) and above.

9. Policy Updates

We may revise this Privacy Policy from time to time. For major changes, we will notify you via in-app pop-ups, announcements, or emails. Your continued use of our services after such changes take effect constitutes your acceptance of the revised policy.

10. Contact Us

If you have any questions or complaints regarding this policy, please contact us via:

• Official Email: paynacledigital@vunanow.com