This Privacy Policy (the “Policy”) provides an overview of how IFIN collects, uses, and processes your personal data when you use IFIN’s mobile app (the “App”). IFIN is committed to safeguarding the confidentiality and privacy of any information entrusted to it, including any personal information collected from you. Please read this Policy carefully, as it becomes legally binding when you use our App.

1. The purpose of Collecting Personal Information

IFIN may ask you to provide personal information so that it may submit it to the relevant financiers to process your finance applications and/or to allow you to interact with it.

2. Data we collect about you

We will collect and process the following data about you:

2.1 Information you give us.

You may give us information about you when you sign up to use our App, e.g. when you provide us with personal details like your name, address, ID number, mobile number, email address, personal description and photograph; and it may include financial information (including credit card, debit card, or bank account information, salary and employment details). This also includes information you provide through your continued use of our App, your participation in discussion boards or other social media functions on our website or App, through entering a competition, promotion or survey, and by reporting problems with our App.

2.2 Information we collect about you.

When you use our App, we may automatically collect the following information:

details of the transactions you carry out when using our App, including geographic location from which the transaction originates;
technical information, including the Internet protocol (IP) address used to connect to the internet, your login information, your mobile device type, model and number;
information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our App (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer support number.

2.3 Information we receive from other sources.

We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties and may receive information about you from them. For example:

the banks you apply to will provide us with your basic personal information, such as your name and address, as well as your financial information such as your bank account details, salary and any information your bank may get from the credit bureau or credit agency;
business partners may provide us with your name and address, mobile number, as well as financial information, such as card payment information;
advertising networks, analytics providers and search information providers may provide us with general information about you, such as confirming how you found our App;

2.4 Sensitive data

We process a limited amount of sensitive data when we carry out verification of identity documents that contain biometric data. Such processing of biometric data (including monitoring the way you login and interact with our App) allows us to validate your identity and to support the detection of fraudulent or suspicious attempts to access your IFIN Account.

2.5 Children’s data

Our products and services are directed at adults aged 18 years and over, and not intended for children. It is IFIN’s policy never to knowingly collect or maintain information about anyone under the age of 18.

3. How we protect your personal information

3.1 We take the safeguarding of your information very seriously, and take a number of steps to ensure it stays secure:

Communication over the Internet between you and IFIN servers is encrypted using strong asymmetric encryption. This makes it unreadable to anyone who might be listening in.
We update and patch our servers in a timely manner.
Our technical security team proactively monitors for abnormal and malicious activity in our servers and services.
Most of the sensitive information you gave us will encrypted. This means it’s unreadable from server hard-drives without the decryption key.

3.2 We restrict access to your personal information to those employees who need to know such information due to the nature of their jobs. We continuously educate and train our employees about the importance of confidentiality and privacy of customer personal information. We maintain physical, electronic and procedural safeguards that comply with the relevant laws and regulations to protect your personal information from unauthorised access.

4. Ways we use your information

4.1 We use your information to:

carry out our obligations relating to your finance application and to provide you with the information, products and services;
comply with any applicable legal and/or regulatory requirements;
notify you about changes to our services;
administer our App and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
improve our services and to ensure that they are presented in the most effective manner;
allow IFIN partners to communicate with you about your applications or transactions with such partners;
measure or understand the effectiveness of advertising we serve and to deliver relevant advertising to you;
allow you to participate in interactive features of our App;
provide you with information about other similar goods and services we offer or offered by our partners.

5. Disclosure of your information

5.1 We may share your information with selected third parties including:

affiliates, business partners, suppliers and subcontractors for the processing of any finance application you submit through our App and/or our website to ensure performance and execution of any contract we enter into with them or you;
advertisers and advertising networks solely to select and serve relevant adverts to you and others with your consent;
analytics and search engine providers that assist us in the improvement and optimisation of our site; and
our group entities or subsidiaries

5.2 We may disclose your personal information to third parties:

such as affiliates, business partners, suppliers and subcontractors for the processing of any finance application you submit through our App and/or our website to ensure performance and execution of any contract we enter into with them or you;
in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce any agreement or contract you have with us; or to protect the rights, property, or safety of IFIN, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
to assist us in conducting or co-operating in investigations of fraud or other illegal activity where we believe it is reasonable and appropriate to do so;
to prevent and detect fraud or crime;
in response to any disclosure of information ordered by the law or law enforcement agencies;
to assess financial and insurance risks;
to recover debt or in relation to your insolvency; and
to develop customer relationships, services and systems.

6. Sharing and storing your personal data

6.1 We will not transfer or store your data at a destination outside your country of residence. However, our own staff that might be located outside your country of residence may be engaged, among other things, in the fulfilment of your finance application and the provision of support services. By submitting your personal data, you agree to allow us to share your date with our staff when needed. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.

7. Profiling and Automated Decision Making

7.1 We may use some elements of your data to customise our services and the information we provide to you, and to address your needs and we only use general data wherever possible.

7.2 We may use Automated Decision Making (ADM) to improve your experience, or to help fight financial crime. For example, so that we can provide you with a fast and efficient service, we may use ADM to verify your identity documents, or to confirm the accuracy of the information you have provided to us (such service might be provided by one of our partners).

8. Data Retention

8.1 As we work with regulated financial institutions, we are required by law to store some of your personal and transactional data beyond the closure of your account with us. We only access your data internally on a need to know basis, and we’ll only access or process it if absolutely necessary.

9. Your rights

9.1 Subject to applicable laws, you may have the right to access information we hold about you. Your right of access can be exercised in accordance with the relevant data protection legislation. If you have any questions in relation to our use of your personal information, contact us. Under certain conditions, you may have the right to require us to:

provide you with further details on the use we make of your information;
provide you with a copy of the information that you have provided to us;
update any inaccurate, incorrect, or out of date personal information we hold;
delete any personal information that is no longer necessary, or no longer subject to a legal obligation to which we are subject to;
where processing is based on consent, you can withdraw your consent and we will stop that particular processing;
cease direct marketing to you, by contacting us;
restrict how we use your information whilst a complaint is being investigated

9.2 Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g., the prevention or detection of crime) and our interests (e.g., the maintenance of legal privilege). If you exercise any of these rights, we will check your entitlement and respond in most cases within a month

10. Third-party links

10.1 Our services may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility for them. Please check these policies before you submit any personal data to these websites.

11. Changes to our privacy policy

11.1 To keep up with changing legislation, best practice and changes in how we process personal information, we may revise this Policy at any time without notice by posting a revised version on our App. To stay up to date on any changes, check back periodically.

12. Contact

12.1 You may contact us regarding this privacy policy at info@ifin-services.com

12.2 If you feel that we have not addressed your questions or concerns adequately, or you believe that your data protection or privacy rights have been infringed, you can complain to any supervisory authority or other public body with responsibility for enforcing privacy laws.