Privacy Policy

Summary of Key Permissions
Boreleza is dedicated to maintaining your privacy and transparency in compliance with the Zambia Data Protection Act No.3 of 2021 and other relevant legislation. We require specific permissions to access specific data from your device in order to ensure a seamless loan acceptance process and determine your eligibility. We exclusively offer our services by securely transmitting, storing, and processing collected data. Your information will not be disclosed to any third parties without your prior, informed consent, except as required by law or for the performance of the loan agreement.


Emergency Contact Information
In order to confirm identity and prevent future fraud, we require you to provide two emergency contacts by manually entering their information in the app. We do not access or retrieve any data from your address book. Furthermore, this data is transmitted via HTTPS and is securely stored on our servers.

Device Specifications
The objective of gathering device information is to confirm your identity and avert deception. This is executed each time you select to register through the homepage. This data includes the device model name, settings, and unique identifiers, as well as the display and brightness settings, CPU and performance details, operating system version, brand, code, model, IMEI, serial number, development mode status, screen dimensions, time zone, default language, and other necessary device environment elements. Additionally, we collect information regarding the applications that are installed on your device; however, this is limited to financial applications. The data encompasses the program name, version number, installation date, most recent update date, and whether the application is pre-installed on the system. This data allows us to identify and evaluate any potential threats, thereby preventing the implementation of malicious software and ensuring the stability of financial accounts. It is imperative that we refrain from utilizing or gaining access to data from applications that are not classified as financial. This information will not be processed or transmitted if you opt not to select "Apply" on the homepage. To prevent unauthorized access, all information that is collected is securely stored on our servers.

Network Information
1. GAID/ADID: In order to enhance your advertising experience, we analyze ad data in accordance with your Google Advertising ID (GAID).
2. ACCESS_WIFI_STATE:We collect data about your Wi-Fi network to assess risk and identify any anomalies.
3. ACCESS_NETWORK_STATE: We gather your network information, such as your connection status, and network type, to assess risk and prevent data loss during network failures.
4. Supplementary information encompasses the network type, SIM provider, SIM country ISO, and mac address.

KYC
We may request specific personally identifiable information from you while you are using our services. This information has the potential to be utilized in novel ways to identify or contact you. - Telephone number

- Full name
- Gender

- Date of birth

- The identification number

- Information regarding education

- Information concerning vocations

- Marital status

- Address

Security and Storage of Data
Utilizing cutting-edge encryption and security protocols, all data that has been collected is securely transmitted to our servers. Your data will not be disclosed to any other parties unless you provide explicit consent. Nevertheless, the data will not be submitted if you opt not to register.
We gather personal information, including your name, phone number, operating system, and device model. Furthermore, we accumulate address information, device activity. Incorporating data from financial institutions may improve our credit assessment. Consent to the acquisition, processing, and secure storage of data is granted by your use of our services.
In rigorous compliance with the Zambia Data Protection Act No. 3 of 2021, all data collected is stored on secure servers, which may be situated within the Republic of Zambia or hosted on secure international cloud infrastructure. In order to guarantee the security of the data, sophisticated encryption protocols are implemented. You hereby provide explicit consent for the cross-border transfer and processing of your information, provided that such transfers are conducted under rigorous technical and contractual safeguards that are intended to ensure a level of data protection that is equivalent to that established by Zambian law for the purposes of loan facilitation and risk mitigation.

Utilization of Information
In order to acquire your personal information, the subsequent two methodologies are implemented:
1. We retain the right to collect and retain any information you provide when you use our financial services, such as when you submit online forms, register for products and/or services, provide feedback, resolve disputes, or contact us regarding our financial services. This pertains to information that has been explicitly disclosed. Furthermore, we may accumulate and preserve the data that is generated regarding your transactions and activities while you are utilizing our services. Utilization data is consistently collected throughout the service's operation.
2. Proactive data collection: We collect information from your smartphone, computer, and other access devices when you use our website, application, and associated services.

Our Approach to Utilizing Your Data
Utilizing the data we have gathered, we can:

- Confirm your identity.

- Develop credit assessment models.

- Manage credit reports and evaluate loan applications.

- Manage the collection and payment processes.
As discussed in the subsequent section, the information supplied can be utilized to evaluate and qualify your creditworthiness, validate your identification, assess the risk associated with your credit request, and conduct statistical analysis.

The Exchange and Transmission of Data
In order for Boreleza to transmit or communicate personal data, the following conditions must be met:
1. The objectives of Boreleza Group entities, affiliates, or subsidiaries are as follows: Enhance the quality of service, evaluate performance, develop new products, and conduct statistical analyses.
2. The goal of service providers, who are third-party entities that are independent, is to enhance the delivery of credit-related services.
3. The primary objective of governmental, judicial, or administrative authorities is to adhere to legal requirements or court mandates.
4. The primary objective of software suppliers, information security, and risk management is to ensure security and prevent fraud.
5. Commercial Affiliates: The goal is to increase visibility.

We are capable of offering loan services that are secure, transparent, and efficient, as well as that satisfy your financial requirements, provided that you grant us your consent. Your utilization of the Boreleza authorizes the data acquisition, utilization, and dissemination procedures detailed in this disclosure.

To protect your privacy, we have implemented the following policies regarding data acquisition and utilization.

1. COMMON EXPERIENCES OF USERS
1.1 Comprehensive Background Information

"We" ("us" or "our") are dedicated to delivering the highest quality of service. We have consistently prioritized the safeguarding of your privacy and personal information.

1.2 Criteria Employed to Evaluate this Privacy Statement
Supplementary information regarding the establishment and operation of your Boreleza account (your "Account"), the management of any personal information you submit through the Boreleza applications (the "Apps"), and the utilization of our lending services (collectively, the "Services," which include the Apps and your Account) is contained in our privacy statement and Terms of Use. In order to gain a comprehensive understanding of the management of their personal information, users are required to review this Privacy Policy in conjunction with our Terms of Use.

It is highly recommended that you review the literature that is attached to ensure that you are fully informed of our policies and guidelines regarding the use of your personal information.

For additional information regarding the services' general utilization guidelines, please consult our Terms of Use.

Please do not hesitate to reach out to us if you have any questions or concerns regarding our privacy policies or a policy. You may reach us via the Apps or at help@Boreleza-zm.com.

1.3 Policy Updates and Amendments
We consistently assess this policy and our privacy policies to ensure that your personal information is handled with the utmost care. It is your responsibility to conduct regular evaluations of the Terms of Use and this Privacy Policy to ensure that you are informed of the most recent version and any subsequent modifications. You acknowledge this requirement.

2. DATA WE COLLECT AND PROCESS
A specific quantity of your personal information must be collected, preserved, exchanged, examined, and managed in order to offer you the services. The information we will collect about you and the circumstances in which it will be used are comprehensively described in this section of the policy.
2.1 Account Activation Requirements for Identity Verification
Access to services will be restricted during the initial phases of account creation. Nevertheless, prior to granting you access to all services and completely activating your account, we must first verify your identification in accordance with the law. We require your Zambian ID and any supplementary documentation that may be necessary for this purpose. We would like to remind you that it is your responsibility to promptly inform us of any changes to your personal information. It may be necessary to re-verify your identity.
2.2 Transactional data
We collect information about your creditworthiness and the lending transaction when you use our services to borrow money or engage in any other service-related transaction. Information concerning your personal information, employment and income, credit history, debt-to-income ratio, collateral, loan purpose, amount, and terms, bank account details, residential details, references, and any information regarding co-signers or guarantors may be relevant.
2.3 Credit and Background Checks
For instance, in order to ascertain which account to debit and whether to grant credit, we will verify your income, employment, and bank account information. We will verify your identity, phone number, emergency contact details (including name, relationship to you, and phone number), bank account details, and previous credit repayment history before granting you additional credit through the Apps. We may also disclose your information to third parties, such as debt collection agencies, if you fail to pay the credit or comply with the service's terms and conditions.
2.4 Customer Preferences
Depending on your preferences, we may utilize your consent to send you emails or other marketing materials. By monitoring your responses to our marketing messages and interactions with them, we can gain a more comprehensive understanding of your preferences. Consent may be revoked at any time.
2.5 Inquiries or requests for information regarding expenses
In the event that you contact us with inquiries, submit a complaint about our services, or wish to notify us of an issue (such as an issue with the applications), this personal information will be promptly added to your account.
Automated decision-making processes are facilitated by the data of service partners. As previously indicated, verification procedures are facilitated by a third-party provider. Please be aware that we may receive personally identifiable information that is generated during the verification process. Our organization and its collaborators implement automated decision-making systems during verification assessments.
2.6 Automated Identity Verification and Screening
For the purpose of identity verification, we utilize automated systems to analyze your personal data. Please be informed that account authorization may be denied if our automated systems are unable to verify your identity in accordance with the necessary regulatory standards.
2.7 Technical Information, Cookies, and Applications
In order to acquire a more comprehensive understanding of the way in which our consumers perceive the services and applications, including their attractiveness and unattractiveness, we gather information about your usage patterns, including the services and/or applications you use and the frequency with which you use them. This information may encompass your IP address, operating system, platform, browser plug-in types and versions, and, if applicable, your registration information.
2.8 Technical and Device Information
We collect technical data and unique identifiers, such as IMEI numbers, MAC addresses, and mobile phone numbers, to guarantee the functionality and security of the services. Additionally, we manage data concerning the device's operating system, mobile browser version, network provider, and time zone setting.

2.9 Emergency Contact Data

To assess credit eligibility and facilitate account management, we collect and verify emergency contact information (specifically name, relationship, and phone number). This data is processed exclusively when you manually provide.

3. THE MANAGEMENT OF YOUR PERSONAL DATA PROCESS
It is imperative to underscore that we exclusively manage your personal information in compliance with the law. In this section, we offer a thorough elucidation of the legal defenses we employ and the justification for our use of your personal data, including local data protection laws.
3.1 To guarantee that the website and services are accessible to clients
3.1.1 The following protocols have been implemented to protect your personal information:
(1) By connecting your account to a third-party website, the value of your account will be enhanced.
(2) Guarantee that the applications are accessible.
3.1.2 The legal basis for the processing of your information is as follows:
(1) Processing is required to fulfill our legitimate interests, which encompass the operational, maintenance, and improvement of our Services and Applications, the timely updating of records, the provision of lending-related services, the marketing of these services to you and other users in accordance with all relevant laws and regulatory requirements.
(2) The processing is necessary to fulfill a contract to which you are a party or to take action at your request prior to the execution of such an agreement.
(3) Processing is necessary to fulfill a legal obligation to which we are subject, such as identity verification procedures and other relevant legal requirements.
3.2 To safeguard your accounts, funds, and offerings
3.2.1 The subsequent protocols are implemented to oversee your personal information:
(1) To prevent malfeasance, identify hazards, and manage them effectively. The purpose of utilizing personal data is to protect your identity, finances, and personal information. It also assists us in fulfilling our legal obligations in the context of financial offenses, such as fraud.
(2) Operational verifications are conducted both internally and externally to guarantee the security and safety of our services. We reserve the right to investigate any suspected violations or questionable activity to ensure that you are not in violation of the law or our terms of service.
3.2.2 Your information is processed using the following legal justifications:
(1) We have a legitimate interest in safeguarding our services, our affiliated companies, your account funds, any necessary third parties, and ourselves from security-related assaults that could be detrimental.
(2) In the event that we are required to comply with your instructions prior to the execution of the contract in order to conduct a transaction with you in a satisfactory manner;

(3) Fulfilling our legal obligations, which include the necessity of atoning for financial malfeasance. For instance, in order to protect your interests or those of the other individual, it may be necessary to investigate hazardous behavior.
3.3 To guarantee regulatory compliance and facilitate communication.
3.3.1 We are dedicated to the protection of your personal data's privacy:
(1) We may contact you to inform you of potential fraudulent activities associated with your account or to address inquiries and requests you have submitted.
3.3.2 The following legal bases are utilized to process your information:
(1) To safeguard our business network and relevant third parties from unauthorized or malevolent activities, as well as to protect the security of your account, funds, and our services.
(2) When it is necessary to fulfill our obligations under an existing agreement with you or to take steps at your request prior to entering into a contract; and

(3) To comply with our statutory and regulatory obligations under the Zambia Data Protection Act No. 3 of 2021 and Anti-Money Laundering Act, which include identity verification (KYC), anti-money laundering (AML) screenings, and other mandatory compliance checks.
3.4 Advertising Distribution
3.4.1 Purpose of Processing
We process specific personal data to send personalized promotional communications regarding supplementary services offered by us or our partner businesses. The purpose of this processing is to protect your privacy and data protection rights.
3.4.2 Legal Foundations for Processing
Your information is processed for advertising purposes under one or both of the following legal justifications:
(1) Your authorization is requested.
Only if you have explicitly authorized us to use your data for marketing purposes (e.g., by agreeing to receive marketing communications), will we process it.
(2) Legitimate interests
Please be advised that we process your data in a manner that is necessary and proportionate, and that does not violate your fundamental rights and freedoms, in order to promote our services to existing and potential users.
You have the right to object to processing that is based on legitimate interests at any time. If you withdraw your consent or object to processing, we will cease the use of your personal data for direct marketing purposes.
3.5 Enhance, modify, and improve our services and applications
3.5.1 We are dedicated to the protection of your personal data's privacy:
(1) Our objective is to acquire a more thorough comprehension of your preferences for our services and applications by examining your utilization patterns. To prevent you from disregarding any promotions or discounts, we may also monitor your use of the applications and services. For example, we may reach out to you if you have not been active on the Apps for an extended period of time or if you have not communicated with one of our online enterprises using the data we have collected.
(2) To respond to any inquiries you may have, and

(3) To improve and customize our services and applications.
3.5.2 The following are the legal justifications for the use of your information to accomplish the aforementioned objectives:
We are committed to the following: the provision of lending-related services and applications; the management, enhancement, and operation of these services and applications; the marketing of our services to you and other users; and the maintenance of accurate records in compliance with all relevant laws, duties, and regulatory requirements.

4. NOTICE REGARDING THE PROTECTION OF PRIVATE DATA
The following conditions must be met in order for your personal information to be disclosed:
4.1 The disclosure of your personal information is contingent upon your consent.
4.2. We may disclose your personal information to authorized debt collection agencies, financial institutions, and licensed credit reference bureaus in order to facilitate credit reporting, identity verification, and the recovery of outstanding debts.
Furthermore, your data may be disclosed to our strategic partners and service providers, who assist in the prevention of fraud and the modeling of risk.
4.3. The sole objective of this sharing is to enhance the precision of your credit assessment and the security of our financial ecosystem. It is subject to stringent confidentiality agreements.
4.4 Our organization may disclose your personal information to specific service providers, partners, or group companies in order to facilitate the execution of services such as money transfers, in-app services, transaction management, and verification checks. Depending on their performance, we may occasionally require a partner to have access to your entire account and financial data.
4.5 We retain the right to share your personal information with specific service providers or group companies in order to assess the services and make the requisite adjustments to guarantee the highest quality for you and others.
4.6 We may be compelled to disclose your personal information in order to address valid claims or legal actions of law enforcement, regulatory agencies, officials, or other entities, or to comply with a legal requirement.
4.7 In the event of a merger, acquisition, or other restructuring, we may disclose your personal information to a third party that is responsible for its processing.
Zambian consumer protection laws and financial industry regulations will govern the storage of your transaction and other account information. In the event that any of the aforementioned circumstances warrant the transfer of your personal data to a country other than the one from which it was originally acquired, we will ensure that the relevant data privacy regulations are strictly enforced. We will also conduct a thorough examination of the legal framework for the transmission of personal data, in addition to discussing the potential for cross-border data sharing and the participation of the countries. We assure you that your personal information will be safeguarded to the same extent, irrespective of your current location.

5. THE SAFEGUARDING OF YOUR PERSONAL INFORMATION
Our primary goal is to protect your privacy. In order to accomplish this, we have implemented suitable security protocols. We are dedicated to protecting your data from unauthorized access, alteration, disclosure, and use, as well as from inadvertent loss or injury.
Furthermore, as previously stated, we implement access restrictions for employees, contractors, volunteers, agents, and other pertinent third parties. These entities are responsible for safeguarding your personal information and will only utilize it in a manner that is in accordance with our policies.
The security of data transmitted via the internet cannot be guaranteed, and we regret to inform you of this. We are unable to ensure the security of any personal information you submit through our services, despite our best efforts. The data you transmit is your responsibility. Upon receipt of your data, we will promptly implement rigorous security measures to safeguard it from illicit access, disclosure, use, and modification.

6. TERMS THAT DIRECT THE STORAGE OF YOUR PERSONAL INFORMATION
6.1 Your information will be retained on file for the specified period in order to fulfill the objectives for which it was collected, including reporting, accounting, tax, and legal obligations.
6.2 When determining the appropriate retention period for personal data, it is crucial to take into account the volume, nature, sensitivity, potential harm from unauthorized use or disclosure, the reasons for processing the data, whether those purposes can be achieved through alternative methods, and any applicable legal, regulatory, tax, accounting, or other requirements.
6.3 Our results suggest that:
6.3.1 In order to safeguard the legal interests of both the creditor and the lender, we will securely store your financial information for a period of six (6) years. In the event of a contractual dispute or judicial inquiry, this duration is in strict compliance with the evidentiary requirements outlined in the Zambian Statutes of Limitation, thereby ensuring the availability of a verifiable and robust record that can be used as conclusive legal evidence for both parties.
Furthermore, in the event that the Financial Intelligence Centre Act or the Anti-Money Laundering Act require extended retention, we will continue to fulfill our statutory obligation of data preservation for the duration required by these laws to ensure regulatory compliance.
6.3.2 All relevant personal and transactional data will be deleted or anonymized six (6) years after account closure. In the event of default, ongoing legal disputes, or unresolved claims, data will be retained only until the final resolution of the claim or the expiration of the statutory limitation period as prescribed by Zambian law.
6.4 We may retain your personal information for an extended period in connection with our relationship with you and/or your use of the Services if there are reasonable grounds to suspect that legal action or other regulatory enforcement action is imminent or in the event of a complaint.

7. YOU ARE CONSCIOUS OF YOUR LEGAL RIGHTS
Under the Zambia Data Protection Act No. 3 of 2021, you possess specific rights regarding your personal information:

7.1 Right of Access: You have the right to request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

7.2 Right to Rectification: You have the right to request the correction of inaccurate or incomplete personal data. We may need to verify the accuracy of the new data you provide.

7.3 Right to Erasure (Right to be Forgotten): If you are not in debt, you are entitled to request the deletion of your personal information. You have the right to request that your personal information be removed from our records if there is no legitimate reason for us to retain it. If you have legitimately exercised your right to object to processing (see below) or suspect that we have unlawfully used your information, you are entitled to request the erasure of your data in accordance with local legislation.
7.4 Right to Object: You have the right to object to the processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing. You also have the absolute right to object to processing for direct marketing purposes.

7.5 Right to Restriction: You have the right to request that we suspend the processing of your personal data in specific scenarios, such as verifying the data's accuracy or during a legal dispute.

7.6 Right to Data Portability: You may request the transfer of your personal data to you or a third party in a structured, commonly used, machine-readable format.

7.7 Right to Withdraw Consent: Where we rely on consent to process your data, you may withdraw it at any time. However, this will not affect the lawfulness of any processing carried out before the withdrawal.

7.8 Right to Lodge a Complaint: You have the right to make a complaint at any time to the Office of the Data Protection Commissioner in Zambia. We would, however, appreciate the chance to address your concerns before you approach the regulator, so please contact us in the first instance.

7.9 Automated Decision-Making & Manual Review: Where a loan application or credit limit is determined solely by automated processing that significantly affects you, you have the right to:

Request an explanation of the logic and criteria used in the assessment.

Request a manual review of the decision by a qualified credit officer.

8. Services and Links Provided by Third Parties
Please be informed that our website and services may include hyperlinks to third-party websites, plug-ins, and applications. Third parties may be able to collect or share data about you if you click on those links or enable those connections. We are not in control of these third-party websites and are not liable for their privacy policies. We recommend that you review the privacy policies of all websites you visit after you depart from our website.