- Your name and surname / company name and registration number;
- financial history (e.g. income, expenses, obligations, assets and liabilities or buying, investing, lending,
- marital status (married, single, divorced); national origin; age; language; birth; education;
- identifying number (e.g. an account number, identity number or passport number);
- email address; physical address (e.g. residential address, work address or physical location); telephone number; and
- insurance, banking and money management behaviour or goals and needs based on, amongst others, account transactions);
A juristic person (a company, trust or association for example) may also have personal information protected in law and may be processed in terms of this Notice.
We may process personal information relating to the juristic person’s directors, officers, employees, shareholders, members, representatives, guarantors, sureties, spouses of sureties, other security providers and other persons (“Related Persons”).
In the event of You providing personal information of a Related Person, You warrant that the Related Person is aware that they are sharing their personal information with the Us, and that the related person has consented to it.
We will process the personal information of Related Persons as stated in this Notice; thus, references to You in this Notice will include related persons with the necessary amendments. - The purpose for which personal information is being collected
We collect personal information to:
The supply of personal information by You to Us is voluntary and not mandatory.
If You do not provide Us with the personal information that We require, We cannot provide any Solution to You.
Legal basis for processing your data
We process Your personal information for these purposes for Our legitimate business interests and in order to allow You to enter Our Platform and/or to enter into a contract with You, with Your consent, and in order to comply with our legal obligations.
This Privacy Policy is governed by the laws of the Republic of Rwanda . You agree to submit the personal and exclusive jurisdiction of the courts located within Rwanda.- Sources we use to collect personal information
We collect personal information from the following sources:- directly from You;
- from public sources (such as company registers, online search engines, deed registries, public posts on social media);
- from technology, such as a customer’s access and use including both assisted and unassisted interactions; and
- from third parties that the We interact with to conduct Our business (such as partners, online partners, credit bureaux, regulators and government departments or service providers).
How long do we keep your personal information
We keep Your personal information for as long as:
- the law requires Us to keep it;
- a contract between Us requires Us to keep it;
- you have consented to Us keeping it;
- we are required to keep it to achieve the purposes listed in this Notice;
- we require it for statistical or research purposes;
- we require it for lawful business purposes.
We may keep Your personal information even if You no longer have a relationship with Us and despite Your request for Us to delete or destroy Your personal information if the law permits or requires Us to keep this information.
Use of personal information for marketing purposes
We will use Your personal information to market other solutions to You.
You can at any stage request Us to stop sending marketing communications to You.
Use of personal information to make automated decisions
An automated decision is made when Your personal information is analysed without human intervention in that decision-making process.
An example of automated decision making is the approval or declining of an application when You apply for one of Our Fundable services.
You have the right to query any such decisions made, and We may provide reasons for the decisions as far as is reasonably possible
How do we store your personal information
We take all reasonable and appropriate measures to ensure that Your Personal Information is safeguarded and secure.
We have reasonable standards of technology and operational security in place to attempt to prevent loss or misuse of any Personal Information.
Any of our authorised employees who are responsible for the maintenance of any special Personal Information submitted by You are requested to maintain the confidentiality of such information unless You have consented to disclosure.
Whenever We employ third parties to assist Us, We will bind them to our privacy policies as far as they may be required to have access to Your personal information to perform such services.
Our Website may contain links to or from other sites. We try to link to sites that share our high standards and respect for privacy, We are however not responsible for the content or the security or privacy practices employed by other sites.
The transmission of information via the internet is not completely secure, however, and we cannot guarantee the security of the information You transmit to Our Website or Platform.
Transmission of your information to ourwebsite is at your own risk.
Once We have received your information, We will use strict procedures and security features to prevent unauthorised access.
We will keep your personal information for only a reasonable amount of time, to enable Us to use it for the purposes described in this policy and under applicable law.
How your information is used and disclosed
We may use the information (including personal information) We hold about You in these ways: - to ensure that content from Our Website is presented in the most effective manner for You and for your computer;
- in aggregate and de-identified form, for internal business purposes such as generating statistics and developing Our strategic and marketing plans;
- to determine how You interact with the Website and the Platform and based on this information to market Our Solutions to You;
- to allow You to participate in interactive features of Our Platform when You choose to do so;
- to carry out any contracts that We conclude with You;
- to respond to any queries You make;
- to notify You about changes to Our Solutions;
- To monitor user activity such as keyword searches or new postings, and more effectively manage traffic on Our Website;
- to provide customer services and create and manage user accounts; and
- to assist You with technical difficulties.
Also, we may share with third-party service providers certain information, such as your browser capabilities or operating system, that we have collected to understand better which advertisements and services may interest you.
We may block users in certain countries from using Our Website.
We will not disclose personal information to anyone outside Our company or Our third parties service providers without Your permission unless: - We are compelled to do so by law or in terms of a court order;
- it is in the public interest to do so;
- it is necessary to protect Our rights.
We may retain certain personal information for as long as required to fulfil Our business objective and as permitted by law, even after your account is terminated.
Right to access and rectify personal information
You have the right to access Your Data through Our Platform or other customer support channels.
You may make changes to or correct inaccurate personal information that You provide Us. It is Your responsibility to ensure all information provided is accurate.
Any requests for changes or corrections will be actioned as soon as reasonably possible.
Right to objection
You may object on reasonable grounds to the processing of Your personal information where the processing is in Your legitimate interest, Our legitimate interest or in the legitimate interest of another party.
You must inform Us of Your objection in the prescribed manner.
We will not be able to give effect to Your objection if: - the processing of Your personal information was and is permitted by law;
- You provided consent to the processing, and the Our processing was conducted in line with Your consent; or
- the processing is necessary to conclude or perform under a contract with You.
Right to withdraw consent / Right to be forgotten
Where You have provided Your consent for processing your personal information, including any consent in respect of Related Persons, You may withdraw Your consent and request Your personal information to be deleted If You withdraw Your consent, We may not be able to provide the Funding Solutions to You. We will action your request as soon as reasonably possible and to the extent permitted by law.
Right to complain
You have the right to file a complaint with the Rwanda Information Regulator about an alleged infringement of the protection of Your personal information. - Assess and and process your fundable status
- Conduct affordability assessments, credit assessments and credit scoring;
- To facilitate account creation and the logon process for any platform that we may create to help with your funding journey.
- manage and maintain Your account;
- To verify your identity where required;
- Communicate with You and carry out instructions and requests;
- Respond to enquiries and complaints;
- Enforcing any agreement if You are in breach of the agreement;
- Disclose and obtain personal information from credit bureaux regarding Your credit history;
- Comply with Our record-keeping obligations;
- Conduct market and behavioural research;
- Run customer satisfaction surveys, promotional and other competitions;
- Comply with Our legal and regulatory obligations; and
- any other related purposes.
Privacy policy changes
This policy is reviewed regularly and any changes will be posted clearly on Our website. We reserve the right to change, modify, add or remove portions of these terms at any time. Data protection officer / Information officer Our appointed Data Protection Officer, can be contacted at dp@afcfta24