Permissions Disclosure

At Zam Insambu, in accordance with the Zambia Data Protection Act No. 3 of 2021 and other applicable provisions, we are committed to transparency and safeguarding your privacy. To ensure an efficient loan approval process and assess your eligibility, we require specific permissions to access certain data from your device. All information collected is securely transmitted, stored, and used only to provide our services. Your data will not be shared with third parties without your explicit consent.

SMS Permissions

We require access to your SMS messages to better assess your loan eligibility. This enables us to review all of your SMS records, not just financial SMS data, including sender names, transaction descriptions, and amounts, in order to evaluate your creditworthiness. However, we will only transmit financial SMS data after filtering through a system, and no other data will be transmitted or processed. By analyzing this data, we can expedite loan approvals and enhance your likelihood of obtaining loans.

• How We Access and Use Your SMS Data:

• 1. Initial Access: Upon confirming this permissions page and authorizing SMS access, our app will initially review your SMS data. However, no data will be uploaded at this stage. This step is solely for a preliminary credit check.

• 2. Ongoing Access: The app will collect several months' worth of recent SMS data, with a limit of a few thousand messages, each time you click the "Apply" button to request pre-approval. It will focus on communications related to financial transactions.

• 3. Selective Upload: Only SMS messages that contain financial-related keywords will be uploaded for analysis. Previously uploaded messages will not be re-uploaded to avoid redundancy.

• 4. Local Storage: If you do not click the "Apply" button, your SMS data will remain on your device and will not be transferred to our servers.

All SMS data is transmitted securely using industry-standard encryption and stored on our servers. We prioritize your privacy and will never share your SMS data with third parties without your consent.

Notifications

We may send you push notifications for important account updates, payment reminders, and special offers. These notifications are optional, and you can decline them without affecting your app's functionality.

Emergency Contacts

For identity verification and fraud prevention, we request access to two emergency contacts. You can either manually enter these contacts or select them from your address book. We will only access the contacts you choose, and no other information from your address book will be collected without your permission. This data is securely transmitted over HTTPS and stored on our servers .

Device Information

To verify your identity and prevent fraud, we collect informatiion about your device each time you click to apply on the homepage. This includes the model name, settiings, and unique identifiers such as os Version, version, Code, brand, modelNo, IMEI, serialNo, isDevelopMMode, screen Width, defaultLangu age, timeZone, other device environment information, display arnd brightness settings, and CPU and performance details. We also gather information on apps installed on your device, but we limit our use of this data to specific financial apps. The details we collect include whether the app is a pre-installed system app, the app name, version number, first installation date, and last update date date This information serves to detect and assess potential risks, enabling us to avoid fraudulent software and safeguard the financial security of our accounts. Importantly, we do not utilize information from apps that do not belong to a specific financial category, and if you do not click to apply on the homepage, none of these data will be transmitted or processed. All collected data is securely stored on our servers and safeguarded against unauthorized access.

Network Information

1. ADID/GAID: We access your Google Advertising ID (GAID) to analyze ad data and improve your advertising experience.

2. ACCESS_WIFI_STATE: We access your Wi-Fi network details for risk assessment and to detect potential network anomalies.

3. ACCESS_NETWORK_STATE: We collect your network information, including IP address, connection status, and network type, to prevent data loss during network interruptions and to assess risk.

4. other information:networkType, simCountryIso, simOperator, macAddress and so on

KYC

• While using our services, we may ask you to provide certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:

• - Phone number

  - Email address

  - Name

  - Gender

  - Date of birth

  - ID Card Number

  - Educational information

  - Marital status

  - Occupational information

  - Address information

Application List

Purpose of Permission Usage: We use your mobile application list to evaluate your operating environment to prevent fraud and hidden virus software. Illegal software may steal your funds through virus intrusion. We need to identify and analyze your risk level to process loans and help prevent fraud.

• How Data is Used:

• We will collect the version number of the installation package, the app name, installation time, last update time, and package name to prevent your personal information from being illegally obtained, to more accurately prevent fraud, protect account security, and identify whether you are a real natural person user.

• How Data Security is Ensured:

• The collected information will be highly encrypted and securely uploaded via HTTPS server . Without your permission, your data will not be shared with any third party.

Data Storage and Security

All collected data is securely transferred to our servers using state-of-the-art encryption and security protocols. Your data will not be shared with any third party without your explicit consent. However, if you do not click to apply, none of the data will be uploaded.

We collect personal information such as your phone number, name, device model, and operating system. Additionally, we gather address, SMS, and device activity logs. To enhance our credit assessment, we may supplement our data with information from credit bureaus and financial institutions. By using our services, you consent to this data collection, processing, and secure storage.

Data Usage

• We obtain your personal information through the following two channels:

• 1. Information you provide directly: We may collect and store the information you provide when using our financial services, including the information you provide when filling in online forms, applying for products and/or services, participating in feedback, resolving disputes, or contacting us regarding our financial services, and the information generated about your transactions and activities during your use of our services. Usage data is collected automatically while using the service.

• 2. Information we collect proactively: When you use our’s website, app, and related services, we collect information sent by your computer, mobile phone, and other access devices.

• How We Use Your Data

• The data we collect helps us:

• - Verify your identity.

  - Build credit scoring models.

  - Determine loan offers and manage credit reports.

  - Monitor collections and payment behavior.

This data may be used, among other purposes described in the section below, to assess the risk inherent in your request for credit, to verify your identity, to assess and qualify your credit worthiness and for statistical purposes.

Data Sharing and Transfer

• Zam Insambu may share or transfer personal data under the following conditions:

• 1. Zam Insambu Group Companies, Subsidiaries, or Affiliates:

  Reason: For product development, performance evaluation, statistical analysis, and service improvement.

• 2. Unrelated Third Parties (Service Providers):

  Reason: To assist in providing credit-related services.

• 3. Government, Judicial, or Administrative Authorities:

  Reason: To comply with legal or judicial orders.

• 4. Risk Management, Information Security, or Software Providers:

  Reason: For fraud prevention and security purposes.

• 5. Commercial Affiliates:

  Reason: For advertising purposes.

By using the Zam Insambu you acknowledge and agree to the data collection, usage, and sharing practices outlined in this disclosure. Your consent enables us to provide efficient, transparent, and secure loan services tailored to your financial needs.

To safeguard your privacy, the following are our regulations on data collection and usage.

1. WHAT HAPPENS TO A COMMON USER

• 1.1 Detailed Background Data

• The goal of Zam Insambu ("Zam Insambu", "we", "us", or "our") is to provide the highest caliber of service. We have always placed a high priority on protecting your privacy and personal information.

• 1.2 Why is this privacy statement being evaluated?

• Our privacy statement and our Terms of Use provide more information about how to create and use your Zam Insambu account (your "Account"), how to handle any personal information you provide to us or that you submit through the Zam Insambu applications (the "Apps"), and how to use our lending services (collectively, the "Services," which include the Apps and your Account). I have no doubt that you will complete the reading.

• To make sure you fully understand our rules and procedures regarding your personal data and how we will use it, it is highly advised that you read the literature that goes with it.

• Please see our Terms of Use for details on the general usage policies of the services.

• For any questions or issues regarding our privacy practices or policy, please do not hesitate to contact us directly at please@zaminsambu.com or via the Apps.

• 1.3 News and Current Affairs

• To ensure that your personal data is treated in the most secure way possible, we regularly review the terms of this policy and our privacy policies.

2. INFORMATION YOU ARE ALLOWED TO DISSEMINATE

A certain amount of your personal information must be gathered, saved, shared, examined, and managed in order to offer you the services. The information we will collect about you and the conditions under which it will be used are fully explained in this section of the policy.

• 2.1 Identity Verification Conditions for Activating an Account

• During the initial setup of your account, you will have limited access to services. As required by law, we must first confirm your identification before we can fully activate your account and provide you access to all services. For this purpose, we need your Zambian ID together with any further paperwork that could be required. We want to remind you that it is your obligation to contact us right away if your personal information changes. You might need to re-verify your identification, depending on the situation.

• 2.2 Information about transactions

• When you use our services to borrow money or complete any other service-related transaction, we obtain information regarding the lending transaction and your creditworthiness. Your personal information, employment and income details, credit history, debt-to-income ratio, collateral details, loan purpose, amount, and terms, bank account details, residential details, references, and any information about co-signers or guarantors are just a few examples of the kinds of information that might be included.

• 2.3 The Character's Background

• For instance, we will gather details about your job, income, and bank account to decide which account to debit and whether to offer credit. Before giving you more credit through the Apps, we will evaluate your name, phone number, emergency contact details (including name, relationship to you, and phone number), bank account details, and repayment history of previous credit. If you don't pay the credit or follow the terms and conditions of the service, we might also give your information to third parties, like debt collection agencies.

• 2.4 Preferences of Customers

• Depending on your settings, we may use your consent to send you emails or other marketing materials. We can gain a deeper understanding of your preferences by tracking how you interact with and react to our marketing messages. Your consent can be withdrawn at any moment.

• 2.6 Service provider data makes automated decision-making possible.

• As stated before, verification experiments are supported by a third party. Please be aware that personal data generated during the verification process may be sent to us. During verification evaluations, our company and its partner use automated decision-making. Could you please provide me with more details regarding this? As part of the automated decision-making process, your identity is assessed by looking at your relevant personal data. If your identification cannot be sufficiently verified by the automatic decision-making process, account authorization will be refused.

• 2.7 Details about applications, cookies, and technical problems

• We collect information on your usage trends, including the kind and frequency of services and/or apps you use. Therefore, we are taking this action to better understand how our users view the services and applications, and how they are attractive and repulsive. These could include your IP address, platform, operating system, browser plug-in versions and kinds, and, if relevant, your registration information.

• 2.8 While the appliance is in use

• The user must enter technical details and unique identifiers, including their mobile device's IMEI number, MAC address, or phone number, in order to use the application. Furthermore, you must disclose details about your device's operating system, mobile browser type, mobile network, and time zone. Other needs include call and text message logs, emergency contacts, and any additional digital content you choose to include.

3. OUR APPROACH TO THE ADMINISTRATION OF YOUR PERSONAL DATA

This section provides a thorough explanation of the legal defenses we utilize and the justification for using your personal information, including local data protection laws. The fact that we only process your personal information in accordance with the law must be emphasized.

• 3.1 To make the Services and Website accessible to users

• 3.1.1 To protect your personal data, the following procedures are used:

• (1) Connect your account to a third-party website to increase its worth.

  (2)Verify the programs' accessibility.

• 3.1.2 When processing your information, the following legal justifications are applied:

• (1)In accordance with all applicable laws, obligations, and regulations, we are permitted to sell our services to you and other users, administer and improve the Services and Apps, offer lending-related services, and rapidly update our records.

  (2)Is it necessary to complete a contract with you and meet your needs before you sign it?

  (3)Fulfilling identification verification and other associated processes in accordance with our legal responsibilities.

• 3.2 To safeguard your funds, accounts, and services

• 3.2.1 The following techniques are applied to monitor your personal data:

• (1)To recognize risks and stop and control misconduct. The usage of personal data ensures that your identity, finances, and personal information are protected. It also helps us meet our legal responsibilities for financial violations, such as fraud.

  (2)We do internal and external operational verifications to guarantee the safety and security of our services. To make sure you are not breaking the law or our terms of service, we retain the right to look into any questionable behavior or suspected violations.

• 3.2.2 When processing your information, the following legal justifications are applied:

• (1)Protecting our services, our linked companies, your account funds, any required third parties, and ourselves against potentially harmful security-related attacks is something we legitimately care about.

  (2)If proper completion of a transaction with you necessitates that we follow your directions before the contract is executed;

  (3)Meeting our legal responsibilities, including the requirement to make amends for financial misconduct;

  For instance, in order to protect the interests of you or another person, we might be required to look into risky behavior.

• 3.3 I would be grateful for the chance to speak with you and am excited to build a relationship with you.

• 3.3.1 We'll protect the confidentiality of your personal data:

• (1) This letter is intended to address any recent questions you may have submitted or to alert you to any possible fraudulent activity connected to your account.

• 3.3.2 When processing your information, the following legal justifications are applied:

• (1)We are still able to protect your account, your money, our services, our business network, and any relevant third parties.

  (2)If it is necessary to satisfy your requirements and carry out a contract with you in a reasonable way before it becomes legally binding; and

  (3)We must receive identity validation and other forms of verification in order to meet our legal obligations.

• 3.4 To distribute commercials

• 3.4.1 We'll protect the confidentiality of your personal data:

• (1) To give you promotional materials, such as details about the additional services that our businesses or we ourselves offer.

• 3.4.2 When processing your information, the following legal justifications are applied:

• (1)If you have given permission for something to happen, then

  Our justifiable goal of promoting you and others to our services is immediately at odds with two situations.

• 3.5 Improve, adapt, and upgrade our apps and services

• 3.5.1 We'll protect the confidentiality of your personal data:

• (1) In order to learn more about your preferences for our services and applications, we would want to examine your usage habits. Additionally, we might keep an eye on how you use the apps and services to make sure you don't miss any deals or promotions. For example, we might contact you if you haven't used the Apps in a long time or if you haven't used the data we've gathered to communicate with one of our web businesses.

  (2)In order to answer any queries you might have, and

  (3) To improve and customize our applications and services.

• 3.5.2 The following sources provide legal justification for using your information to achieve the above indicated goals:

• (1)In accordance with all applicable laws, duties, and regulations, we genuinely commit to providing lending-related services and/or applications, managing and improving these services and/or applications, advertising our services to you and others, and keeping accurate records.

4. NOTICE ABOUT THE PRIVACY OF PRIVATE DATA

Only the following situations may result in the disclosure of your personal information:

4.1 The sharing of your personal information requires your consent.

4.2 To guarantee that you both get the most out of the services we offer, we retain the right to share your personal information with other service users. Furthermore, our services make it easier for you and other Service users to share personal information.

4.3 By adding your personal information to your public profile on the Apps, you give other Apps users permission to view and use it publicly.

4.4 To enable the delivery of services including transaction management, in-app services, verification checks, and money transfers, our organization may share your personal information with particular service providers, partners, or group companies. Depending on how well they perform, we might occasionally be forced to provide a partner access to your whole account and financial data.

4.5 In order to assess the services and make the required modifications to guarantee the highest quality for you and others, we may grant access to your personal information to particular service providers or group companies.

4.6 In order to comply with a legal requirement or to address the valid claims or legal proceedings of law enforcement, regulatory bodies, officials, or other entities, we might be obliged to divulge your personal information.

4.7 In the case of a merger, acquisition, or other restructuring, we might give your personal information to a third party in charge of processing it.

In accordance with Zambian consumer protection laws and finance industry regulations, your transaction and other account information will be kept in Zambia. We will make sure that the applicable data privacy regulations are respected if any of the previously described situations necessitate the legitimate transfer of your personal information to a nation other than the one from which it was initially acquired. In addition to discussing the possibility of cross-border data sharing and the countries' engagement, we will outline the legal framework for the transmission of personal data. Regardless of where you are now, we promise that your personal information will be protected to the same extent.

5. YOUR PERSONAL INFORMATION SECURITY

We are dedicated to protecting your data from accidental loss or damage, as well as from unauthorized access, alteration, disclosure, and use. Protecting your privacy is our top priority. To stop this, the necessary security measures have been put in place.

Additionally, as previously stated, we limit access to agents, contractors, workers, volunteers, and other pertinent third parties. They are responsible for safeguarding your personal data and will only use it in ways that align with our rules.

I hate to notify you that there is no absolute guarantee that data communicated over the internet will be secure. The security of any personal information you provide through our services cannot be guaranteed, no matter how hard we try. You are accountable for the data you send. As soon as we get it, we will put strict security measures in place to guard against unauthorized access, disclosure, use, and alteration of your data.

6. THE TERMS THAT GOVERN HOW YOUR PERSONAL INFORMATION IS STORED

Your information will be kept for the specified amount of time in order to satisfy the purposes for which it was gathered, including reporting, accounting, tax, and legal requirements. To determine the proper retention period for personal data, we consider the following factors: volume, nature, sensitivity, potential harm from unauthorized use or disclosure, the purposes for processing the data, whether those purposes can be accomplished through alternative means, and any applicable legal, regulatory, tax, accounting, or other prerequisites.

We have found that:

6.1 As allowed by relevant laws, including anti-money laundering rules, we will keep your financial information for a maximum of six years from the date of your most recent transaction, or for a longer length of time if it falls within the retention term listed below.

6.2 Six years after the cancellation date, all relevant data, including transactional and personal data, shall be permanently erased.

Regarding our relationship with you and/or your use of the Services, your personal information may be kept for a long time if there is a complaint or if there are reasonable suspicions of impending legal action or other regulatory enforcement action.

7. YOU UNDERSTAND YOUR RIGHTS

This can be achieved by meeting certain requirements and abiding by jurisdictional restrictions:

7.1 To obtain access to your personal information, submit an application. By taking this step, you can get a copy of the data we presently have on file for you and verify that we are processing your personal information legally.

7.2 In response to your request, kindly ask us to amend the personal data we currently have on file. This gives you the opportunity to update any incomplete or erroneous information we may have about you, but any new information you provide might need to be verified.

7.3 If you are not in debt, you have the right to ask that your personal information be deleted. You have the right to ask that your personal information be deleted from our systems if there is no valid reason why it should be kept. If you have successfully exercised your right to object to processing (see below) or if we may have processed your information unlawfully, you have the right to request that we erase or delete your records in accordance with local legislation.

7.4 If you feel that the processing of your personal data violates your basic rights and freedoms due to circumstances that are unique to you, you have the right to object. In this instance, we will base our choice on the justifiable interests of a third party or ourselves. You also have the right to protest when your personal data is used for direct marketing.

7.5 Ask that the use of your personal data be restricted. In some situations, you have the right to ask that we stop processing your personal information.

7.6 Request the transfer of your personal information to you or another individual. You or a specified third party will receive your personal data in a structured, machine-readable format.

7.7 If we use your personal information for any reason, you can withdraw your consent at any time.

7.8 If there are any issues about data protection, a complaint should be made to the relevant authorities. To address your issues before submitting them to the regulator, we urge you to get in touch with us as soon as possible. We would be really grateful for that.

Please use the information above to get in touch with us in order to exercise any of the aforementioned privileges.

We may ask for certain information from you to confirm your identity and ensure that you are able to exercise your rights. This is put in place as a security safeguard to stop unauthorized people from learning personal information. We could get in touch with you to get further details, which would enable us to take action sooner. Please keep this in mind.

We try to reply to valid questions within a month. Sometimes it will take more than a month to review requests that are extremely complicated or have been submitted more than once. We will ensure that you receive information consistently and that you are kept updated on any developments.

8. INTERNAL LINKS WITH OTHER ENTITY

Our website and services may contain plug-ins, apps, and linkages to websites run by third parties. By tapping on these links or enabling these connections, third parties are given permission to gather and distribute personal data about you. Please remember this. Since we have no control over these third-party websites, plug-ins, or programs, we cannot be held accountable for their privacy policies. Please go through the privacy policies of each website or application you use or visit before leaving them.