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PRIVACY NOTICE

Last updated January 11, 2021

Thank you for choosing to be part of our community at Leaf Global Fintech Corporation (“Company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice, or our practices with regards to your personal information, please contact us at info@leafglobalfintech.com. For the purposes of European and UK data protection laws, we are the controller of your personal information.

When you use our mobile application, as the case may be (the "App") and more generally, use any of our services (the "Services", which include the App), we appreciate that you are trusting us with your personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately.

This privacy notice applies to all information collected through our Services (which, as described above, includes our App), as well as any related services, sales, marketing or events.

Please read this privacy notice carefully as it will help you understand what we do with the information that we collect.

1. WHAT INFORMATION DO WE COLLECT?​

Personal information you disclose to us

In Short: We collect information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the App, express an interest in obtaining information about us or our products and Services, when you participate in activities on the App (such as by posting messages in our online forums or entering competitions, contests or giveaways), by visiting our Website or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and the App, the choices you make and the products and features you use. The personal information we collect may include the following: names; phone numbers; email addresses; mailing addresses; usernames; passwords; contact preferences; transaction data; and other similar information.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our App and Website.

We automatically collect certain information when you visit, use or navigate the App. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about who and when you use our App and other technical information. This information is primarily needed to maintain the security and operation of our App, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Notice: https://www.leafglobalfintech.com/leaf-cookie-policy/.

The information we collect includes:

  • Log and Usage Data. Log and usage data is service-related, diagnostic usage and performance information our servers automatically collect when you access or use our App and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the App (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps') and hardware settings).
  • Device Data. We collect device data such as information about your computer, phone, tablet or other device you use to access the App. Depending on the device used, this device data may include information such as your IP address (or proxy server), device application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system configuration information.
  • Location Data. We may collect information data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type of settings of the device you use to access the App. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Locations settings on your device. Note however, if you choose to opt out, you may not be able to use certain aspects of the Services.

Information collected through our App

In Short: We collect information regarding your geo-location, mobile device, push notifications, when you use our App.

If you use our App, we also collect the following information:

  • Geo-Location Information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our App, to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device's settings.
  • Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's camera, contacts, reminders, SMS messages, social media accounts, storage, and other features. If you wish to change our access or permissions, you may do so in your device's settings.
  • Mobile Device Data. We automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our App, we may also collect information about the phone network associated with your mobile device, your mobile device's operating system or platform, the type of mobile device you use, your mobile device's unique device ID and information about the features of our App you accessed but only as strictly necessary for the functioning of the App.
  • Push Notifications. We may request to send you push notifications regarding your account or certain features of the App. If you wish to opt-out from receiving these types of communications, you may turn them off in your device's settings.

The information is primarily needed to maintain the security and operation of our App, for troubleshooting and for our internal analytics and reporting purposes.

Third party data collected through the App

We collect data of your phone to provide a segmented risk profile and generate an aggregated statistical information. We use the data as part of our decision process to assess your creditworthiness for a loan with us. We may also use your data to assess your interest in receiving financial services through algorithms and mathematical modelling.

To protect your identity, we remove all personal identifiers (if any) and pseudonymize such information. Any metadata processed in this way cannot be used to reproduce the original data collected. Here are the examples how our official third party vendor, Credolab, collects the metadata:

  • Credolab’s mobile technology may count the number of calendar events scheduled and their time stamp. Only this information is sent to Credolab’s servers, NOT the underlying raw data.
  • While Credolab’s mobile technology may scan and process your phone book contacts on your mobile device and may have the ability to send names and contact details to Credolab’s servers, the names and contact details are NOT sent to Credolab’s servers.
  • While Credolab’s mobile technology may scan and process information about the list of applications installed on your mobile device, Credolab will only collect data relating to the frequency of use of such applications but NOT the activities you engage on any such application.
  • Credolab’s mobile technology may count the number of registered accounts, including your social accounts. However, Credolab will only NOT access the social media profiles and Credolab will NOT analyze the information in the apps connected with them.
  • Credolab’s mobile technology may count the total time you spent to apply for a loan, the time you spent in the same position, how fast you scrolled application etc. While our Credolab’s technology may scan and process such information, Credolab do NOT read the content of what you type in the application form.
  • CredoLab calculates the alternative credit score by analyzing only METADATA, not personal data. CredoLab does not share raw data with us

2. HOW DO WE USE YOUR INFORMATION?​

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our App for a variety of business purposes described below. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

Purpose

Lawful Basis

To facilitate account creation and login process.

For the performance of the contract entered into with you (Article 6(1)(b), GDPR).
To deliver and facilitate delivery of services to the user. We may use your information to provide you with the requested service.
Fulfill and manage your transactions. We may use your information to fulfill and manage your transactions, payments, and other actions made through the App.

For the performance of the contract entered into with you (Article 6(1)(b), GDPR) and we have a legitimate interest to manage our business (Article 6(1)(f), GDPR).

To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.

We have a legitimate interest to manage our business (Article 6(1)(f), GDPR).

Administer prize draws and competitions. We may use your information to administer prize draws and competitions when you elect to participate in our competitions.

To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.

Request feedback. We may use your information to request feedback and to contact you about your use of our App.

To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.

To post testimonials. We post testimonials on our App that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the consent of the testimonial. If you wish to update, or delete your testimonial, please contact us at info@leafglobalfintech.com and be sure to include your name, testimonial location, and contact information.

You consent to the data processing in question (Article 6(1)(a)).

To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user's consent.

To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, where we have your express consent to do so. For example, when expressing an interest in obtaining information about us or our App, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time (see the "WHAT ARE YOUR PRIVACY RIGHTS" below).

Deliver targeted advertising to you. We may use your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness, where you have opted-in to receive such advertising. For more information, see our Cookie Notice: https://www.leafglobalfintech.com/leaf-cookie-policy/

To protect our Services. We may use your information as part of our efforts to keep our App safe and secure (for example, for fraud monitoring and prevention).

We have a legitimate interest to manage our business (Article 6(1)(f), GDPR) and we may need to comply with a legal obligation (Article 6(1)(c), GDPR.

To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.

We have a legitimate interest to manage our business (Article 6(1)(f), GDPR), to comply with a legal obligation (Article 6(1)(c), GDPR and it may be necessary for the performance of the contract entered into with you (Article 6(1)(b), GDPR).

To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

To comply with a legal obligation (Article 6(1)(c), GDPR.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?​

In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

We may need to process or share your personal information in the following situations:

  • Business Transfers. We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • Vendors, Consultants and Other Third-Party Service Providers. We may share your personal information with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work.

Examples include: cloud computing services - Amazon Web Services (AWS);

payment processing - Beyonic, MFS Africa, Infoset, PayPal;

communication services - WhatsApp and RouteMobile;

Website testing- Google Play Console, Apple Store; and

Compliance service providers - Sumsub, Rebric.

.

Where we have obtained your consent, we may allow selected third parties to use tracking technology on the App, which will enable them to collect data on our behalf about how you interact with our App over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, pages or features, and better understand online activity. Unless described in this notice, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes. We have contracts in place with our data processors, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

  • Third-Party Advertisers. Where we have obtained your consent, we may use third-party advertising companies to serve ads when you visit or use the App. These companies may use information about your visits to our Website(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you. See our Cookie Notice: https://www.leafglobalfintech.com/leaf-cookie-policy/ for further information.
  • Affiliates. We may share your personal information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
  • Business Partners. We may share your personal information with our business partners to offer you certain products, services or promotions.
  • Other Users. When you share personal information (for example, by posting comments, contributions or other content to the App) or otherwise interact with public areas of the App, such personal information may be viewed by all users and may be publicly made available outside the App in perpetuity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our App, and view your profile.
  • The data collected is shared with selected and authorized providers of data analytics services. The service providers are described below:
    • CredoLab Pte Ltd: we use Credolab’s service to assess user’s credit worthiness. Metadata accessed, collected, and shared are as follows: device characteristics and configuration, media, and information related to how many applications are installed. The specific permissions are: READ_EXTERNAL_STORAGE, READ_CONTACTS, READ_CALENDAR.
  • Credolab’s privacy policy is available at the following link: https://www.credolab.com/privacy-policies/gdpr-privacy-policy.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?​

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice: https://www.leafglobalfintech.com/leaf-cookie-policy/.

5. HOW LONG DO WE KEEP YOUR INFORMATION?​

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than three (3) months past the termination of the user's account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

6. HOW DO WE KEEP YOUR INFORMATION SAFE?​

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our App is at your own risk. You should only access the App within a secure environment.

7. WHAT ARE YOUR PRIVACY RIGHTS?​

In Short: In some regions, such as the European Economic Area and the UK, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the European Economic Area and the UK), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If you are resident in the European Economic Area or the UK, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

If you have questions or comments about your privacy rights, you may email us at info@leafglobalfintech.com.

Account Information​

If you would at any time like to review or change the information in your account or terminate your account, you can:

  • Log in to your account settings and update your user account.

  • Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our App. To opt-out of interest-based advertising by advertisers on our App visit http://www.aboutads.info/choices/. For further information, please see our Cookie Notice: https://www.leafglobalfintech.com/leaf-cookie-policy/

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you may:

  • Access your account settings and update your preferences.

  • Contact us using the contact information provided.

8. CONTROLS FOR DO-NOT-TRACK FEATURES​

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

9. DO WE MAKE UPDATES TO THIS NOTICE?​

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

10. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?​

If you have questions or comments about this notice, you may email us at info@leafglobalfintech.com or by post to:

Leaf Global Fintech Corporation

16192 Coastal Highway

Lewes, DE 19958

United States

HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?​

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please contact info@leafglobalfintech.com. We will respond to your request within 30 days.