How LionCash Works 1.1.   GROLA TECH LIMITED with its registered seat in Nairobi, Kenya (“LionCash”) is specialized in consumer lending. Our company provides you with a mobile application called “LionCash app” for which you can apply for a loan. 1.2.   LionCash app greatly simplifies the process of obtaining a loan by allowing you to borrow amount according with internal credit policy that you qualify for, within the allowed limits, from anywhere and wherever you may be. LionCash app does this by using your data as contained in your device and LionCash’s app algorithms to identify you, verify your identity, assess your creditworthiness, credit risk and create a credit score for you. 1.3.   The more you use LionCash app to apply for loans and pay on time, the higher your loan limit goes. Privacy Policy LionCash respects your right to privacy. This policy summarizes what personal information we may collect, how we may use this information, and other important topics relating to your privacy and data protection. It is LionCash’s policy to comply with all applicable privacy and data protection laws. This commitment reflects the value we place on earning and keeping the trust of our customers, business partners and others who share their personal information with us. This Policy applies to all Internet sites and mobile applications operated by or on behalf of LionCash and includes other entities worldwide affiliated with LionCash. It also applies to personal information LionCash may otherwise collect: (i) through our products and services; (ii) when you interact with us by means other than a LionCash Internet Site or App, i.e. in person, by telephone, or via other means of telecommunications; and (iii) from our employees, collectors, third party investigators, and other business partners (collectively “Business Partners”). The information obtained by LionCash will only be used for LionCash business needs relating to loans made by consumers / users of this application service, including but not limited to feasibility analysis of loan products, the need to process transactions, carry out court orders, applicable legal processes and process reports to the competent authorities.

1. LionCash Privacy Policy

LionCash is a mobile application software (“App”) available on the Google Play Store (“App”) which you have downloaded onto your mobile phone, cellphone or handheld device (Device). To the extent required by applicable law, whenever LionCash collects personal information, LionCash will:

• Provide timely and appropriate notice to you about our data practices;
• Collect your personal information only for specified and legitimate purposes. The information we collect will be relevant, adequate and not excessive for the purposes for which it is collected;
• Process your personal information in a manner consistent with the purposes for which it was originally collected or to which you have subsequently consented;
• Take commercially reasonable steps to ensure that your personal information is reliable for its intended use, accurate, complete, and, where necessary, kept up-to-date;
• Not use your personal information for direct marketing purposes without giving you an opportunity to “opt-out”; and
• Take appropriate measures, by contract or otherwise, to provide adequate protection for personal information that is disclosed to a third party or transferred to another country, including transfers within LionCash.

This Policy constitutes as an inseparable part of LionCash Credit Agreement.

2. Personal Information LionCash Collects

LionCash collects the following types of personal information: Information You Provide

• LionCash collects personal information you provide us, which may include: (i) contact information, such as your name, company name, job title, address, e-mail address, and phone number; (ii) additional information about you to help us get to know you better, such as your gender, age, date of birth, nationality, professional associations and registration numbers, information about how you use our products, and demographic information; (iii) comments, questions, requests and orders you may make; (iv) financial information needed to process loans and payments, such as Mobile money statements, credit card or account information or other banking information; (v) log-in information, including, if applicable, social media account information for login purposes, if applicable; (vi) information about your preferences, such as your preferred methods of communication and product types in which you are interested (vii) phone contacts in your device needed for collection purposes, if in case the information provided in the credit agreement is false, invalid or otherwise not responsive to our collection attempts.
• It is understood that when you have submitted your information to LionCash, you expressly guarantee the correctness of the data provided and expressly consenting to the collection and processing of such information for whichever purpose it may serve under the agreement.

Information Automatically Gathered from Your Device

• Device information. LionCash may collect technical information about your device, such as device type, browser type, IP address, operating system, and device identifier. LionCash collects this information automatically from your device and web browser through cookies and similar technologies subject to your consent.
• Information about how you interact with us. LionCash may collect technical data about your usage of the LionCash App and how you interact with our digital advertisements and promotions. LionCash collects this information using cookies and similar technologies subject to your consent.
• Location information. LionCash may collect location information, including precise real-time location information from your device and imprecise location information derived from, for example, your IP address. LionCash Apps will NOT access precise-real time location information from your device unless you grant permission to do so.  LionCash’s access to location is for the protection of LionCash as our services are only rendered for those who are located in the Kenya. LionCash’s location access is limited for the purpose of granting the loan application and other allied services, if applicable.

Information from Business Partners and other Third Parties

• LionCash may collect personal information through our Business Partners. This information may include contact information, such as name, company name, job title, address, e-mail address, and phone number for verification and validation purposes.
• LionCash may also obtain personal information from other third-party sources, including publicly and commercially available sources. We may combine the information we receive from our Business Partners and other third-party sources with information that we collect from you or your device, as described above.

3. LionCash’s Usage of Personal Information

LionCash may use your personal information to: Develop and manage our relationships with you and our Business Partners. This may include: (i) delivering services or carrying out transactions that you or our Business Partners have requested; (ii) providing information about LionCash products, services, and transactions, and advertisements, that may be of interest to you; (iii) providing you and our Business Partners a more consistent experience in interacting with LionCash, including by learning more about you and how you use and interact with LionCash Internet Sites, Apps, products, and services; and (iv) planning, managing, and performing under our contractual relationships with our Business Partners. Communicate with you. This may include: (i) informing you of LionCash products, services, and promotional activities that may be of interest to you; (ii) providing information about relevant LionCash products, services, and transactions, including, for example, pricing, information about product or service improvements; (iii) responding to questions or inquiries that you make, including customer service requests; and (iv) inviting you to participate in, or informing you of the results of, customer satisfaction or market research surveys. Provide and improve our Internet Sites, Apps, products, and services. This may include: (i) customizing them to your preferences or interests, making them more compatible with your technology, or otherwise making them easier to use; (ii) maintaining the security of and otherwise protecting them; and (iii) and developing new LionCash Internet Sites, Apps, products and services. Address legal issues. This may include: (i) complying with our obligations to retain certain business records for minimum retention periods; (ii) establishing, exercising, or defending legal claims; (iii) complying with laws, regulations, court orders, or other legal process; (iv) detecting, preventing, and responding to fraud, intellectual property infringement, violation of our contracts or agreements, violations of law, or other misuse of LionCash Internet Sites, Apps, products or services; and (v) protecting LionCash’s rights or property, or yours or others’ health, safety, welfare, rights, or property. LionCash may also use your personal information for other uses consistent with the context in which the information was collected or with your consent. LionCash may anonymize or aggregate any of the information we collect and use it for any purpose, including for research and product-development purposes. Such information will not identify you individually.

4. Sharing of Personal Information

LionCash will not disclose your personal information except as described here:

• LionCash may share your personal information with third parties we hire to perform support services for us such as but not limited to collection services, background investigation, and skip tracing among others. These third parties are required to use the personal information we share with them only to perform services on our behalf and to treat your personal information in compliance with all applicable privacy and data protection laws.
• In some cases, LionCash may share your personal information with third parties who partner with us to provide products and services to our customers. If so, we will require our Business Partners to use that information in a manner consistent with this Policy, any applicable Specific Privacy Statements, and all applicable privacy and data protection laws.
• LionCash may share your personal information with third parties when we have a good faith belief that disclosure is necessary: (i) to comply with a law, regulation, court order, or other legal process; (ii) to detect, prevent, and respond to fraud, intellectual property infringement, violation of our contracts or agreements, violation of law, or other misuse of LionCash Internet Sites, Apps, products or services; (iii) to protect LionCash rights or property or yours or others’ health, safety, welfare, rights, or property; or (iv) under similar circumstances. If such an event occurs, we will take appropriate steps to protect your personal information.
• LionCash may share your personal information with third parties in connection with the sale, purchase, merger, reorganization, liquidation or dissolution of LionCash or a LionCash business unit, or under similar circumstances. If such an event occurs, we will take appropriate steps to protect your personal information.
• Kindly note, by signing this form, you allow LionCash to share your credit information, both positive and negative with Credit Reference Bureau, and also to check your credit report for credit appraisal purposes.
• LionCash may share your information with your permission or at your request.

LionCash may share anonymized or aggregated information internally and with third parties for any purpose. Such information will not identify you individually.

5. Security Safeguards

Your personal information will generally be stored in LionCash databases maintained by our service providers. Many of these databases are stored on servers located in Kenya. LionCash takes appropriate measures, by contract or otherwise, to provide adequate protection for personal information that is disclosed to a third party or transferred to another country, including transfers within LionCash. LionCash maintains reasonable safeguards to protect the confidentiality, security and integrity of your personal information. Although we use security measures to help protect your personal information against unauthorized disclosure, misuse, or alteration, as is the case with all computer networks linked to the Internet, we cannot guarantee the security of information provided over the Internet and will not be responsible for breaches of security beyond our reasonable control. LionCash shall not be held accountable or legally liable for any data breach, misuse, disclosure or unlawful sharing due to the fault of its users’ failure to protect and secure their username and password or some other form of negligence.

6. Revision of Privacy Policy

Changes to this Privacy Policy will be posted on the LionCash website and app, along with information on any material changes. LionCash reserves the right to update or modify this Policy and any Specific Privacy Statements at any time and without prior notice. Any modifications will apply only to the personal information we may have collected and those we will collect after the posting. The user agrees that he/she is responsible for ensuring that he/she is aware of all changes to the Privacy Policy by visiting the website and app pages from time to time. Each amended provision applies immediately and effectively legally binds the use of the Application by the User without requiring further approval so that if the User continues to use, access or utilize the Application, the User is deemed to have known, understood and agreed to the changes.