KANGWE TECHNOLOGIES LIMITED – PRIVACY POLICY

Effective Date: 6 February 2026

Kangwe Technologies Limited (“Kangwe”, “we”, “us”, or “our”) is committed to protecting the privacy, confidentiality, and security of personal data.

This Privacy Policy explains what data we collect, why we collect it, how it is used, how it is shared, and how it is protected when you access or use our website, mobile applications, and digital lending platforms (collectively, the “Services”).

This Policy is designed to comply with:

  • Google Play User Data Policy
  • Google Play Financial Services Requirements
  • Google Play Biometric & Sensitive Data Rules
  • Zambia Data Protection Act
  • Applicable financial and consumer protection laws

1. SCOPE OF THIS POLICY

This Policy applies to:

  • Users of Kangwe websites and mobile applications
  • Loan applicants and borrowers
  • Merchants, partners, and suppliers
  • Visitors interacting with Kangwe digital platforms

By using our Services, you acknowledge and consent to the collection and processing of personal data as described in this Policy.

2. INFORMATION WE COLLECT

2.1 Personal Identification Information

  • Full name
  • National Registration Card (NRC) or passport details
  • Date of birth
  • Gender
  • Photographs

2.2 Contact Information

  • Mobile phone number
  • Email address
  • Residential and business address

2.3 Financial and Transaction Information

  • Bank account or mobile money details
  • Loan application data
  • Repayment history
  • Transaction records

2.4 Device and Technical Information

  • IP address
  • Device identifiers
  • Operating system and browser type
  • App usage logs and timestamps

2.5 Location Information

  • Approximate location derived from IP address or device settings (where enabled)

2.6 User Account and Service Data

  • Login and authentication credentials
  • Service usage history
  • Preferences relevant to loan services
  • Information provided through customer support, feedback, or surveys

3. FACIAL AND BIOMETRIC DATA

3.1 Collection

Where required for identity verification, fraud prevention, or enhanced security, Kangwe may collect facial or biometric data during:

  • Account registration
  • Identity verification
  • Secure authentication
  • Transaction approval

Biometric data is collected only with explicit user consent and is never collected secretly or in the background.

3.2 Use of Biometric Data

Biometric and facial data is used strictly and exclusively for:

  • Identity verification (KYC)
  • Fraud prevention and impersonation detection
  • Secure user authentication

This data is:

  • ❌ Not used for advertising
  • ❌ Not used for behavioural profiling
  • ❌ Not used for marketing or analytics
  • ❌ Not sold or shared for commercial purposes

3.3 Sharing of Biometric Data

Kangwe does not sell or monetise biometric data. Limited disclosure may occur only to:

  • Licensed identity verification or KYC service providers under strict confidentiality obligations
  • Law enforcement or regulatory authorities where required by law

3.4 Retention and Protection

  • Biometric data is stored securely using encryption and access controls
  • Retained only for as long as necessary for its purpose or legal obligations
  • Deleted or anonymised where legally permitted upon user request

4. HOW WE COLLECT INFORMATION

We collect data:

  • Directly from users during registration, loan applications, and communications
  • Automatically through app usage, cookies, and similar technologies
  • From third-party service providers such as Credit reference bureaus, identity verification services, and payment service providers
  • From public or regulatory sources where permitted by law

5. PURPOSES OF PROCESSING

We process personal data to:

  • Verify identity and conduct KYC checks
  • Assess creditworthiness and manage lending risk
  • Process loans, repayments, and related transactions
  • Prevent fraud, money laundering, and financial crime
  • Comply with legal and regulatory obligations
  • Operate, improve, and secure our Services
  • Communicate important service-related information

6. LEGAL BASIS FOR PROCESSING

Processing is based on:

  • User consent
  • Performance of a contract
  • Compliance with legal and regulatory obligations
  • Legitimate business interests, where permitted by law

7. DATA SHARING AND THIRD PARTIES

Personal data is shared only on a need-to-know basis with:

7.1 Regulatory and Government Authorities

Bank of Zambia, Courts, law enforcement, and statutory bodies

7.2 Financial and Credit Institutions

Licensed credit reference bureaus, Banks, payment service providers, and mobile money operators

7.3 Verification and Technology Providers

National identity verification services, Biometric and KYC providers, Cloud hosting and cybersecurity providers

7.4 Professional Advisors

Auditors, legal and compliance consultants

🚫 Kangwe does not sell personal data or share it for advertising purposes.

8. CROSS-BORDER DATA TRANSFERS

Where data is processed outside Zambia, Kangwe ensures:

  • Adequate data protection safeguards
  • Compliance with the Zambia Data Protection Act

9. DATA RETENTION

Personal data is retained only for:

  • Legal and regulatory compliance
  • Contractual and operational needs

Data no longer required is securely deleted, anonymised, or archived.

10. DATA SECURITY

We implement reasonable safeguards including:

  • Encryption
  • Access controls
  • Secure servers
  • Continuous monitoring

While we take strong measures, no system can guarantee absolute security.

11. USER RIGHTS

Subject to applicable law, users may:

  • Access their personal data
  • Request corrections
  • Withdraw consent (subject to no outstanding obligations or loans)
  • Request deletion where legally permitted
  • Object to certain processing activities

Requests can be submitted using the contact details below.

12. COOKIES AND TRACKING TECHNOLOGIES

Cookies are used to:

  • Enable platform functionality
  • Enhance security
  • Improve service performance

Users may disable cookies, but some features may be limited.

13. CONTACT DETAILS

Customer Support

Phone: +260 973 369 111

Email: support@kangwe.io

Office Location

Lusaka, Zambia

Social Hub

Facebook: Kangwe

Instagram: KangweOfficial

LinkedIn: Kangwe

Website

www.kangwe.io

14. CHILDREN’S PRIVACY

Kangwe Services are strictly for individuals aged 18 and above.

We do not knowingly collect data from minors.

15. POLICY UPDATES

We may update this Policy to reflect legal, regulatory, or operational changes. Updates will be communicated via:

  • Website
  • App notifications
  • Email or SMS where appropriate

16. DATA PROTECTION CONTACT

For privacy-related requests or questions:

Kangwe Technologies Limited

Email: info@kangwe.io

Phone: +260 973 369 111