GraceLoan Privacy Policy
GraceLoan highly values your privacy. This Privacy Policy details what personal information we collect, with whom we share such information, and how you (as a user of the service) can prevent us from sharing certain information with specific third parties. By downloading the GraceLoan application, you consent to GraceLoan collecting and processing your personal information for legitimate business purposes, including but not limited to assessing your credit rating and providing loan services. Once you accept all the terms of this Privacy Policy, you acknowledge and agree to all the information processing practices described herein.
Please read this Privacy Policy carefully and completely. If you have any questions or need further clarification, please contact us via the email address provided in this policy: [email protected].
SACCO Membership Notice:
1. Upon registration or use of our app services, you will automatically become a member of GRACE SAVINGS AND CREDIT COOPERATIVE SOCIETY (a Savings and Credit Cooperative Organization, SACCO).
2. GRACE SAVINGS AND CREDIT COOPERATIVE SOCIETY is the corresponding SACCO non-profit organization dedicated to providing financial services to its members.
definition
This Privacy Policy applies to the following areas:
Once you download the GraceLoan mobile application software (“App”) to your mobile device (“Device”), the App can be used through our official website or accessed through the “App Website” hosted on the Google Play Store;
"Compliance obligations" refer to the legal obligations that GraceLoan is required to fulfill under local and international laws, internal policies and procedures.
The specific meanings of the terms used in this Privacy Policy are as follows:
All services available through this application can be found on the application's website or our other official websites ("Services Website").
"Personal data" refers to various types of information that can directly or indirectly identify a specific individual; specifically, it can be identified through identifying information such as name, ID number, location data, online identifier, or through personal physical characteristics, physiological conditions, genetic information, psychological characteristics, economic status, etc., regardless of whether such information is recorded in physical form.
"Consumer information" refers to various types of information related to consumers, including but not limited to consumers' personal data, confidential information, tax information, transaction records, usage of GraceLoan products and services, and information on the consumer's historical partnership with GraceLoan.
"Consumer" or "user" refers to any natural person for whom GraceLoan provides products and services;
“We,” “Our,” and “Us” all refer to the GraceLoan;
"Services" refers to the various related services provided by GraceLoan during the establishment of a partnership with its clients, especially through the GraceLoan App;
"Sensitive consumer personal data" refers to data that can reflect sensitive information about natural persons, including but not limited to race, health status, identity information, ethnicity, social origin, conscience, belief, genetic data, biometric data, property details, marital status, family information (including the names of children, parents, and spouse), gender, and sexual orientation.
"Consent" means your explicit and clear expression of agreement to allow us to process your personal data. Consent is effective only if it is voluntary, specific, informed, and unambiguous. You may withdraw your consent at any time by sending an email to [email protected].
The information we collected
GraceLoan primarily collects two types of data: one is system data obtained by GraceLoan with user authorization, for details of which can be found in section 1.1 of this policy; the other is information actively filled in and submitted by the user, including but not limited to the user's name and other relevant data, for details of which can be found in section 1.2 of this policy.
1.1 User Authorization Data
1.1.1 SMS Permissions
The content we monitor and collect: With your explicit authorization, we will use a "filtering" mechanism to access only financially related SMS records on your device, including but not limited to loan repayment reminders, bank transfer notifications, and credit card billing notifications. We will never access or collect your private chats, irrelevant notifications, or other non-financial SMS content, and we will adhere to the principle of minimum necessity throughout the process.
Purpose of data collection: To analyze and assess your credit risk profile, understand your repayment ability and financial transactions, and thus match you with the most suitable loan products. This also assists in the credit review process, ensuring the compliance and security of loan services and effectively reducing credit risk. We will only access such financially related SMS messages for one year; access will automatically cease after this period.
Data storage instructions: We only collect SMS messages related to finance. Such messages will be encrypted using HTTPS and uploaded to our dedicated server https://www.graceloan.cc, where they will be stored with the highest level of security. We promise never to share this data with any third party, strictly protecting your SMS privacy.
1.1.2 Coarse Location Permissions
What we monitor and collect: With your authorization, we only collect the approximate location information of your device, i.e., the general area (such as city or region level). We do not collect your precise location coordinates, track your location trajectory, or associate your personal identification information for location analysis.
Purpose of data collection: For risk control, identifying abnormal logins and cross-regional operation risks, and avoiding account security issues caused by operations performed by someone else in a different location; at the same time, based on your approximate region, to optimize service adaptability, provide you with loan service suggestions tailored to the local scenario, and improve your user experience, and will not be used for any purpose unrelated to the service.
Data storage instructions: Rough location-related data will be encrypted via HTTPS and uploaded to our dedicated server https://www.graceloan.cc. The storage period is strictly controlled within the necessary range for service. Data exceeding the storage period will be automatically deleted or anonymized. We will never share such data with any third party.
1.1.3 Camera Permissions
The content we monitor and collect includes: With your authorization, we will obtain camera permissions on your device, allowing you to take photos through the application. We will only collect relevant image data taken by you through the camera, including but not limited to ID card photos, facial photos, and photos of relevant supporting documents. We will not actively turn on the camera to take photos secretly or covertly.
Purpose of collection: For identity verification, to confirm that the operation was performed by you personally and not by someone else, to ensure the authenticity of the account and loan application; at the same time, to collect the supporting documents required for the loan, to assist in completing the loan review process, to improve review efficiency, and to ensure the compliance and security of the service.
Data storage instructions: All images captured by the camera will be encrypted using the HTTPS protocol before being uploaded to our dedicated server https://www.graceloan.cc. This data will be used solely for identity verification and loan approval. The storage period will strictly adhere to the principle of service necessity. Irrelevant images will be promptly removed after the approval process is completed. We will never share this data with any third party.
1.1.4 Device Permissions
What we monitor and collect: With your authorization, we will collect and monitor specific information related to your device, including but not limited to your phone number, device name, model, region and language settings, device identifiers (such as IMEI, serial number, Android ID), device hardware and software information, IP address, device operating status, usage habits, and other unique device identifiers and operating-related information.
Purpose of data collection: To uniquely identify your device, establish a device security profile, prevent unauthorized devices from impersonating you to log in, apply for loans, and perform other operations, effectively prevent fraudulent activities, and protect your account and funds; at the same time, to optimize application performance based on device information, adapt to different device models, and improve your user experience.
Data storage instructions: Device-related data will be encrypted via HTTPS and uploaded to our dedicated server https://www.graceloan.cc. Encrypted storage ensures data security, and we promise that we will never share such data with any third party, and it will only be used for device identification and security control.
1.1.5 Application List Information
The content we monitor and collect includes: With your authorization, we will access the names and installation status of applications installed on your device. We will not read any content, data, usage records, or privacy information within the applications, but will only obtain information such as the application name and whether it is installed.
Purpose of data collection: For device security testing, to confirm that your mobile device does not have any non-Google trusted applications, malicious virus applications, fraudulent applications, etc. Such applications may steal your personal information and account information, and threaten your financial security; at the same time, by analyzing the device's operating environment through application list information, we can optimize application compatibility and avoid service anomalies caused by conflicts.
Data storage instructions: The application list information will be encrypted via HTTPS and uploaded to our dedicated server https://www.graceloan.cc. The storage period will be as long as necessary for the service. The information will be automatically deleted after the storage period expires. We promise not to share this information with any third party and strictly protect the privacy of your device applications.
1.1.6 Ad ID Declaration
The content we monitor and collect includes: With your authorization, we may obtain your device's advertising ID. This ID is used solely for advertising optimization and is not associated with your personal identification information, account information, or other sensitive data, nor is it used to identify your specific identity.
Purpose of collection: To push loan-related advertisements, event information and service recommendations that are more relevant to your needs, optimize the effect of ad push, avoid irrelevant ad interference, and improve your user experience; you can choose to turn off this permission at any time. After turning it off, we will no longer push personalized ads based on ad IDs, and it will not affect your use of our core loan services.
Data storage instructions: Ad ID related data will be encrypted via HTTPS and uploaded to our dedicated server https://www.graceloan.cc for ad push optimization only, and will not be shared with any third party; you can withdraw authorization at any time through device settings, and we will immediately stop collecting and using this type of data and delete the stored ad ID information.
1.2 Personal Data
The content we monitor and collect: "Personally Identifiable Information" refers to various types of information that can be used to uniquely identify you, including but not limited to your name, password, ID card number, date of birth, marital status, gender, email address, residential address, education level, phone number, income, emergency contact information, and other relevant personal information. Specific examples of information that may be collected are as follows (but not limited to the following):
Your name (including last name and first name; middle name is optional); your ERA personal identification number; your date of birth; your employment information and income details; your bank account information; any personal information you provide to us during customer service communications (including email, telephone, or other communication methods), dispute resolution, or complaint feedback; your state, region, and detailed residential address.
Purpose of Collection: We may request the aforementioned personally identifiable information from you to fulfill our legal obligations, verify your identity, assess your creditworthiness, prevent various fraudulent activities, and facilitate your transactions. We may also use the personal information you provide to send you exclusive loan offers, process your loan applications, provide our various services, or conduct related investigations. It should be noted that GraceLoan may collect personally identifiable information required for some products and services on a voluntary basis. However, in some scenarios, collecting personally identifiable information is a necessary condition for you to access our services and apply for loan business. If you refuse to provide it, you may not be able to use the relevant services or apply for a loan normally.
Why We Collect Information
To effectively fulfill our service responsibilities, ensure service compliance and security, and better provide you with loan services tailored to your needs, we collect your relevant information primarily for the following purposes. All uses strictly comply with this Privacy Policy and relevant Ethiopian laws and regulations:
1. We handle all transaction matters that arise during your use of our services, ensuring smooth and compliant transaction processes and protecting your funds.
2. Complete your identity verification process to confirm your true identity, prevent identity theft, and protect your account security;
3. Assess your credit risk profile and, based on relevant information, determine your repayment ability to provide a reliable basis for credit approval;
4. We will check our database to see if your data contains duplicate records and also screen blacklist information to prevent credit risks;
5. To handle loan disbursement matters for your use of this service and assist in collecting loan repayments, ensuring the orderly operation of credit business;
6. Construct a scientific and reasonable credit assessment model to score your credit status and provide data support for matching loan products;
7. We will provide you with personalized loan product recommendations based on your credit history, income level, and needs, enhancing your service experience;
8. Analyze customer service usage habits to understand your service needs and provide a reference for service optimization and product upgrades;
9. Fulfill our obligations to our partners, ensure compliance of cooperation processes, and protect the legitimate rights and interests of all parties;
10. Troubleshoot any issues that arise during the service process, resolve service anomalies promptly, and ensure the stability and continuity of the service;
11. Strictly comply with applicable Ethiopian laws, regulations and rules, especially those related to Know Your Customer (KYC) and anti-money laundering requirements, and fulfill compliance obligations;
12. To detect and prevent various fraudulent activities and other illegal uses of the service, maintain service order, and protect your and our legitimate rights and interests;
13. We will send you marketing notifications, service updates, and various promotional offers to keep you informed about our service activities.
14. Authorized to contact you regarding service-related matters through automatic dialing, pre-recorded voice calls, or SMS (if applicable) for the purposes described in this Privacy Policy.
How we use and share information
By using our services, you consent to our and GraceLoan's use of your customer information in accordance with the terms of this Privacy Policy, and all use will strictly comply with the relevant laws and regulations of Ethiopia.
3.1 Uses of Information
All information we collect will be used for the purposes explicitly stated in this Privacy Policy, and we will never use your information beyond the scope of authorization.
We will not disclose personally identifiable information to any third party unless necessary to provide the services we provide. We may share limited personal information with select partners for research and development purposes; we may also provide anonymous personal information of our users to other parties for the purpose of compiling statistics related to user groups and loan portfolios, and may disclose such anonymous information to any third party for such purposes, provided that such information remains anonymous and does not contain any personally identifiable information.
3.2 Information Sharing
By using this service, you agree that we may transfer and disclose any of your customer information to the following recipients as needed for the service and to achieve the purposes described in this policy, and all sharing shall comply with the principle of minimum necessity and compliance requirements:
1. To provide relevant information to GraceLoan's members, subcontractors, service providers or agents as needed for internal administrative work and credit decision-making;
2. Verify with the emergency contacts you provided to confirm whether they agree to be added as your emergency contacts so that we can contact them promptly if you fail to fulfill your loan obligations or do not answer our calls;
3. Provide information to credit consulting agencies, credit agents, and any financial institutions to obtain various information related to credit consulting and assist in completing credit reviews;
4. Provide relevant information to the person acting on your behalf, the recipient of funds, the beneficiary, the account holder, and the intermediary to ensure the smooth progress of the service;
5. We share information with third-party service providers who have contracts with GraceLoan. These service providers support our business operations, particularly in areas such as marketing, identity verification, fraud prevention, anti-money laundering, transaction processing, and areas focused on analytics tools, information search services, hosting services, website development, risk assessment, debt collection, and customer service. We share data only to the extent necessary to fulfill our legal obligations and provide the services we provide, and we require these third parties to strictly comply with this Privacy Policy.
6. If you fail to perform or improperly perform the relevant obligations in the signed loan agreement, we may transfer information about your overdue debts to debt collection companies, credit reporting agencies, and companies providing legal services in order to protect your legitimate rights and interests;
7. Disclose information to government officials, law enforcement agencies, or other third parties, but only when a formal request, court order, or similar legal process is received, or when we believe that disclosure is necessary to comply with the law, prevent physical harm, avoid financial loss, report suspicious illegal activities, or investigate violations of our Terms of Service;
8. Other uses permitted by law.
We may associate any category of information with other categories of information, and as long as such information is combined, we will process it as consumer information in accordance with the provisions of this Privacy Policy.
You agree that GraceLoan shall not be liable for any loss or damage arising out of or consequential from our use of, collection of, processing of, or sharing of information relating to you, or from any actions we take in accordance with the contents of this section.
Where do we store information?
The data we collect from you may be transferred to destinations outside Ethiopia and stored locally, or processed by employees working for us or our suppliers outside Ethiopia, who may be involved in processing your service requests. By submitting your personal data, you consent to the transfer, storage, and processing of such data. We will take all reasonable and necessary measures to ensure the secure processing of your data and strictly comply with the provisions of this Privacy Policy. To provide you with account-related services, we may also disclose your data to relevant entities we deem necessary.
GraceLoan is the controlling entity of your personal data. We highly respect your privacy rights and ensure that your personal data is protected and processed in accordance with relevant Ethiopian laws and regulations. It should be noted that absolute security cannot be guaranteed when transmitting information over the internet. Although we will take all reasonable and feasible measures to protect your personal data, we cannot guarantee the absolute security of information you transmit to our website; you assume all risks arising during information transmission. Once we successfully receive your information, we will immediately employ strict security procedures and functions to prevent unauthorized access and ensure data security.
Please note that you have the right to request the correction, deletion, and restriction of your personal data processing in accordance with the law. You also have the right to apply for access to your personal data, and we will cooperate with you in exercising your relevant rights in accordance with the law.
Customer Obligations and Rights
Please note that if you fail to provide the necessary consumer information for using the GraceLoan app or services in a timely manner, or conceal, revoke, or withdraw the necessary authorizations for processing, transferring, or disclosing your consumer information, or if we have reasonable grounds to suspect that you are illegally using the GraceLoan app or our services, or are involved in fraud, financial crimes, or other illegal activities, we reserve the right to suspend or terminate our services to you and to terminate our partnership with you. Furthermore, we may take necessary measures in accordance with our internal policies and compliance obligations to protect the legitimate rights and interests of both parties.
You agree that if any changes occur to the customer information you provide to us from time to time, you will notify us promptly (in any event no more than 30 days) by email ([email protected]) or by contacting our customer service hotline in writing, and will respond to any related requests we make in a timely manner to ensure that your information remains accurate and valid.
Data retention
If we provide you with a password or PIN code (or you choose to provide one) for accessing specific sections of our website, it is your responsibility to ensure that the password or PIN code remains confidential. We urge you not to disclose your password or login information to any third party to avoid account security risks due to information leakage.
Even if you request data deletion, GraceLoan may continue to process the data if it has a legal basis for processing it, especially when GraceLoan needs to process such data to fulfill legal obligations, for statistical analysis purposes, or to establish, exercise, or defend its own legal claims.
We will store your personal data for a reasonable period, in accordance with legally mandated data retention periods, to fulfill the loan agreement and realize the legitimate interests described in this policy.
We process your data to send you business information about GraceLoan products and GraceLoan partners, and this processing will continue until you explicitly object to our data processing.
We will retain your identity information, the contents and performance of the signed loan agreement, and the data used to assess your credit value and credit risk until the statute of limitations for any claims arising from the loan agreement expires.
Issues and Changes
For data processing based on your consent, we will cease processing the data covered by that consent when you withdraw your consent or when your consent expires (if there is a time limit on the consent).
We welcome any questions, comments, and requests you may have regarding this Privacy Policy. For inquiries or feedback, please email [email protected], and we will respond and process your request promptly.
If we make any changes to this Privacy Policy in the future, we will post the updated version on this page; where appropriate, we will notify you of the changes the next time you launch the application or visit the service website. The updated terms may be displayed on the screen, and you may need to read and accept these new terms to continue using our application or services.