PRIVACY POLICY

Last Updated: 02 June 2017

Introduction

Any reference to "we" or "us" in this document shall mean Modality Apps (Pty) Ltd. and any reference to “you” shall mean the user of Mobiloan. This privacy policy applies to Mobiloan, which is owned and operated by Modality Apps (Pty) Ltd.  We believe you deserve the utmost respect when it comes to the security and use of your personal information, so we have described how we look after your information as clearly as possible.

Our privacy policy applies indefinitely to information shared with us or collected and stored by us through the use of our software. Our privacy policy is regularly reviewed to make sure that we continue to serve your privacy interests. We reserve the right to update this privacy policy from time to time. We encourage you to periodically review this policy for the latest information on our privacy practices. We are committed to keeping your information confidential and will not share or disclose any of your information with any other 3rd party or users not belonging to your organization.  

If you have questions or complaints regarding our privacy policy or practices, please contact us at info@modalityapps.com.  For the purpose of the The Protection of Personal Information Act, No 4 of 2013 (POPI), the data controller is Modality Apps (Pty) Ltd.

Security

We recognise how important it is to protect and manage the information you share with us. We use computer safeguards such as firewalls and data encryption and we only authorise access to those employees who require it to fulfil their job responsibilities. When you share data with us through Mobiloan, that information is protected by secure socket layer (SSL) encryption. Our security systems meet or exceed industry standards and we are constantly monitoring internet developments to ensure our systems evolve as required.

Collecting your information

We collect information about you in a number of ways:

• Information you provide to us through the Mobiloan App and Mobiloan Dashboard
• Information you provide through communications with us
• From integration partners such as credit bureaus and payment service providers.

In addition to the personal and financial information you submit (or we collect), we may collect information about your computer including, where available, your IP address, operating system and browser type, for the purposes of system and loan administration and product improvement.

Use of your information

Information we hold

We will hold and store the following details for your sole use and benefit:

• Your users’ and clients’ names, ID numbers, addresses, phone numbers, email addresses, employment, affordability, references, banking, financial details, images, signatures and uploaded documents
• Passwords are stored in an encrypted format and are not viewable or directly accessible by the staff or any users of Mobiloan
• The information you generate through Mobiloan from credit reference bureaus
• Details of the loans and transactions you perform through Mobiloan. Such information may be held within a database and/or electronic documentation
• Any other information which we reasonably need in order to operate your account or fulfil our regulatory obligations.

We commit to holding your data on our systems for the duration of your service agreement with Mobiloan plus 6 months thereafter, whereafter it will be removed from our servers and returned to you at your request in the most practical digital format. All your information is always available to you though the Mobiloan App or Mobiloan Dashboard.

Information we share

We will keep your information confidential and only share it with others for the purposes explained in this policy. We have trusted relationships with carefully-selected third parties who perform services on our behalf. All service providers are bound by contract to maintain the security of your information and to use it only as prescribed in their respective privacy policies.

Currently information is shared with the following service providers:

• Amazon.com, Inc. Mobiloan stores all electronic documentation and payment responses generated through Mobiloan using Amazon EC2 web services. https://aws.amazon.com/privacy
• Journey Mobile, Inc. The Mobiloan platform runs on the Journey mobile app container which synchronizes all information on the app’s local database with their central cloud database hosted in South Africa. http://journeyapps.com/privacy-policy.html
• Compuscan Information Technologies Ltd. Mobiloan submits client specific information required by Compuscan when you request credit reference information https://www.compuscan.co.za/privacy-policy
• Information Technology Consultants (Pty) Ltd (Intecon). Mobiloan facilitates the creation and management of payment services provided by Intecon by using Intecon’s web services https://intecon.co.za/privacy-policy.php

In addition to the above we may share your information with:

• Any person to whom we sell or transfer (or enter into negotiations to sell or transfer) our business or any of our rights or obligations under any agreement we may have with you. If the transfer or sale goes ahead, the transferee or purchaser may use your information in the same way as us
• With regulatory and governmental authorities or ombudsmen, or other authorities, including tax authorities, if we are requested by them to do so.

How we use your information

Your data is for your sole use and benefit and we will not use or disseminate it without your written knowledge or consent.

Notwithstanding the above, your data will be used to:

• Allow you to operate and manage your Mobiloan application and its related services
• For us to manage any application, agreement or correspondence you may have with us
• Carry out, monitor and analyse our business
• Contact you by email, SMS, letter or telephone about our products and services, unless you tell us that you prefer not to receive marketing from us
• To form a view of you as an end user and to identify, develop or improve products, that may be of interest to you
• Carry out market research, business and statistical analysis
• Carry out audits
• Perform other administrative and operational tasks, including the testing of systems.

Your data may also be used for other purposes for which you give your permission, or where we are permitted to do so by law, or where it is otherwise permitted under the terms of the The Protection of Personal Information Act, No 4 of 2013 (POPI).