1. INTRODUCTION

1.1. This Privacy Policy ("Policy") describes how DANBED NETSYSTEMS LTD ("XLoan", "we", or "us") handles personal information that you have voluntarily shared with us. This information is stored, used, processed, and disclosed when you download and use our mobile application, "XLoan: Personal Loan App," or the services offered on www.xloan.top (the application is referred to as the "App" and the website and the app together as the "Platform").

1.2. At XLoan, we value your privacy and are dedicated to safeguarding your 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. We collect, transmit, and store personal data about you on our secured XLoan server (https://www.xloan.top) after obtaining your consent, to provide you with, or in connection with, the Services. Please note that we only collect and process a minimal amount of your personal data to provide you with the Services. Such personal data includes:

Data pertaining to your identity and profile: This comprises your first and last name, parents' names, birthdate, gender, photos, educational background, loan purpose, home ownership, work status, business name, contact details (phone numbers, emails, and addresses), 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 XLoan server (https://www.xloan.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 comprises operating systems, IP addresses, browser kinds and versions, time zone settings, and device details. We gather, send, and save this kind of information on our safe XLoan server (https://www.xloan.top). Data analytics is the reason behind the collection of this information.

App data: We collect, transmit, and store the installed application's information on our secured XLoan server (https://www.xloan.top). We only use the package name of each installed application to assess the creditworthiness and to provide customized 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 XLoan server (https://www.xloan.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 obtain from other sources, such as public and third-party sources: We may obtain personal information about you from public and third-party sources, such as our third-party providers, Google Analytics for user analytics and advertising, and other publicly accessible sources. In order to improve the Services, do fraud checks, and provide you with the best credit products, this information is used.

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. 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 in relation to the Services provided to you including but not limited to educating you of the credit products available to you, provision of customer support, resolving grievances/disputes in relation to the Service or the credit product availed by you and pursuant to the collection services offered to the Lender for the credit facilities availed by you.

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 expedite your KYC in accordance with the lender's recommendations;

To expedite your loan application and to assist you in acquiring credit facilities from regulated companies, such as 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 XLoan 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 accept and understand that you are giving us, our associate partners, and affiliates permission to contact you by phone, email, or other means by using our services and making an account on the Platform. This is to make sure you understand every element 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

By providing us with personal information, you hereby guarantee that it is truthful, correct, and up to date. Subject to any legal obligations, we try our best to give you the option to review and update incomplete or erroneous data when you use our services. We will confirm that the updated personal information you gave us is accurate.

7. DATA SECURITY

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

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 correct: We expressly disclaim all liability and obligation for the accuracy of the data that you have given Us. To ensure that the information you have given us is accurate, complete, and current, you do, however, have the right to examine, update, and/or modify it. Please be aware, though, that you might not be able to utilize the full range of our services if you refuse consent, withdraw consent, exercise your right to be forgotten, or give false information. In such cases, we reserve the right to refuse you access to all or part of our services.

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 If your application for a loan was sent to a lender or if you have taken out a loan from one of our lenders, they will still process your information and may get in touch with you regarding the loan application and payment of any outstanding balances. Your information may be kept by the Lenders for the period of time specified by applicable legislation. The lenders also have the right to demand that we hold onto information if they have contracted us to handle any activities related to the loan product, such collecting payments. In such a scenario, we will have to keep Your information on file 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.xloan.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

Our Services may, from time to time, contain services provided by or links to and from the websites of our partner networks, service providers, financial institutions, advertisers, and affiliates ("Third Party Services"). Please note that the Third Party Services that may be accessible through our Services are governed by their own privacy policies. We do not accept any responsibility or liability for the policies or for any personal data that may be collected through such Third Party Services. Please check their policies before you submit any personal data to such websites or use their services.

12. COOKIES

12.1. Cookies are little files of data that are kept on your system. To set you apart from other Service users and to store your preferences, we employ cookies and other tracking technologies. This enables us to better serve you and make sure you have a positive experience using our services.

12.2 We use cookies to determine who you are. Cookies are not allowed to access any personally identifiable information stored on your device, including email addresses. We will be able to run the Services and give you a customized, user-friendly experience thanks to the data that cookies collect. You will be able to use some of the Services' features thanks to the cookies. The majority of devices have settings that let you control whether cookies are transmitted to you or not. The functionality we can offer when you visit the Platform or attempt to use certain of the Services may be restricted if you disable cookies.

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 periodically evaluate our Policy and, at our sole discretion, may make changes.

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，GREATER ACCRA，ACCRA，SPINTEX ROAD，BLOCK NUMBER B, 3RD FLOOR, DBS BUILDING

Email Address: service@xloan.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 XLoan's policy on data retention and destruction.

2. HOW LONG DO WE STORE YOUR DATA
You agree and acknowledge that your personal data will continue to be stored and retained by us as required or permitted by applicable laws or regulatory requirements, or as required for defending future legal claims. The details relating to KYC, device location and SMS data will be deleted or rendered into anonymised data, so that it no longer constitutes personal data, within such time as legally prescribed, post closure of the loan. All the other details will be deleted or render the data into anonymised data upon the request of the customer for the deletion of the data, provided there is no active loan or service being availed by you. 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.