1. Introduction
Welcome to zubaLoan, a micro-lending service offered by LUVA TECH INTERNATIONAL LIMITED (D-U-N-S Number: 850394761), a company registered at Tsavo Building, Tsavo Road, Starehe District Nairobi, Nairobi, Kenya ("Company", "we", "us").
We operate the zubaLoan mobile application ("App") and website ("Service") to provide fast, accessible mobile loan products to users in Uganda. Your privacy and the protection of your personal data is of utmost importance to us.
By downloading and using the zubaLoan App, or by accessing our website, you agree to the terms set forth in this Privacy Policy. If you do not agree with any part of this Policy, please discontinue use of our Services immediately.
We collect your information to evaluate your loan eligibility and provide our services. We use strong security measures to protect your data and do not sell it to third parties for marketing purposes without your consent.
2. Information We Collect
To provide you with our loan services and to comply with legal obligations, we collect several categories of personal information:
2.1 Information You Provide Directly
- Identity Information: Full name, date of birth, gender, nationality, and photograph as shown on your National Identity Card (NIN).
- Contact Information: Mobile phone number, email address, and residential address.
- Financial Information: Mobile money account details (MTN MoMo or Airtel Money number), employment status, monthly income estimates, and any other financial information relevant to loan assessment.
- Government ID Data: National Identity Number (NIN) or other government-issued identification details used for identity verification.
- Emergency Contact: Name and phone number of a contact person you designate during registration.
2.2 Information Collected Automatically
- Device Information: Device model, operating system version, unique device identifiers (IMEI, Android ID), mobile network carrier, and IP address.
- Usage Data: App interaction logs, feature usage patterns, session duration, loan application history, and in-app behavior.
- Location Data: General location data (city/region level) based on IP address and, with your permission, precise GPS location to assist with fraud prevention and credit assessment.
- Network & Connectivity: Wi-Fi network information, mobile data status, and call logs metadata (frequency and duration of calls, not content) used for credit scoring purposes, subject to your explicit consent.
2.3 Information from Third Parties
- Credit Bureaus: We may obtain credit history reports from licensed credit bureaus operating in Uganda to support our lending decisions.
- Mobile Money Providers: We receive transaction confirmation and verification data from MTN Uganda and Airtel Uganda when you authorize loan disbursements or repayments.
- Identity Verification Partners: We work with licensed identity verification services to confirm the authenticity of documents you submit.
3. How We Use Your Information
We process your personal information for the following specific purposes:
🏦 Loan Assessment & Origination
To evaluate your creditworthiness, determine eligible loan amounts and interest rates, and process your loan application.
✅ Identity Verification
To verify your identity, confirm the authenticity of documents provided, and prevent fraudulent applications.
💸 Loan Disbursement & Repayment
To disburse approved loans to your mobile money account and to process repayment transactions.
📊 Credit Scoring
To build and update your internal credit profile over time, which determines your credit limit and interest rate.
🔔 Service Communications
To send you loan approval notifications, payment reminders, account alerts, and important service updates via SMS, push notification, or email.
⚖️ Legal Compliance
To comply with applicable laws, regulations, court orders, and requests from governmental or regulatory authorities in Uganda and Kenya.
🛡️ Fraud Prevention
To detect, investigate, and prevent fraudulent transactions, identity theft, and other illegal activities.
📈 Service Improvement
To analyze usage patterns, troubleshoot technical issues, and enhance the functionality and user experience of our App.
We will only send you promotional or marketing messages if you have explicitly opted in to receive such communications. You may opt out at any time by updating your preferences in the App settings or contacting our support team.
5. Data Security
We implement industry-leading security measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction:
- Encryption in Transit: All data transmitted between your device and our servers is protected using TLS 1.2 or higher (HTTPS).
- Encryption at Rest: Sensitive data stored on our servers is encrypted using AES-256 encryption standards.
- Access Controls: Access to personal data is restricted to authorized personnel on a strict need-to-know basis. All access is logged and monitored.
- Regular Security Audits: We conduct periodic security assessments, vulnerability scans, and penetration testing of our systems.
- Two-Factor Authentication: Our administrative systems require multi-factor authentication to prevent unauthorized internal access.
- Incident Response: We maintain a formal data breach response plan and will notify you and relevant authorities within the timeframes required by applicable law if a breach affecting your data occurs.
While we take strong measures to protect your data, no transmission over the internet or storage system can be guaranteed as completely secure. You are responsible for keeping your login credentials and mobile PIN confidential. Do not share your password with anyone, including our support staff.
6. Data Retention
We retain your personal data for as long as necessary to fulfill the purposes for which it was collected, and in accordance with applicable laws and regulations:
- Active Account Data: Retained for the duration of your account and the active loan relationship.
- Loan Records: Financial and loan transaction records are retained for a minimum of 7 years after the loan is fully repaid, as required by Ugandan financial regulations.
- Identity Documents: Copies of ID documents and KYC data are retained for the period required by applicable anti-money laundering laws (typically 5–7 years after account closure).
- Communication Logs: Customer support interactions and in-app communication logs are retained for 3 years.
- Deleted Accounts: If you delete your account, we will anonymize or delete most personal data within 90 days, except data we are required by law to retain.
7. Your Rights
Subject to applicable law, you have the following rights with respect to your personal data:
👁️ Right to Access
You have the right to request a copy of the personal data we hold about you and information about how we process it.
✏️ Right to Rectification
You can request that we correct inaccurate or incomplete personal data about you. You can update basic profile information directly in the App.
🗑️ Right to Erasure
You may request deletion of your personal data, subject to our legal obligations to retain certain data (e.g., for regulatory compliance and fraud prevention).
🚫 Right to Restrict Processing
In certain circumstances, you may request that we limit the processing of your personal data while a dispute or complaint is being resolved.
📦 Right to Data Portability
You may request a copy of your personal data in a structured, commonly used, machine-readable format to transfer to another service provider.
🙅 Right to Object
You may object to our processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests.
To exercise any of these rights, please contact us at privacy@zubaloan.com. We will respond to your request within 30 days. We may need to verify your identity before processing your request.
8. Children's Privacy
The zubaLoan Service is intended for adults aged 18 years and above. We do not knowingly collect or process personal data from anyone under the age of 18. If you believe that we have inadvertently collected information from a minor, please contact us immediately at privacy@zubaloan.com and we will delete such information promptly.
10. Third-Party Services & Links
Our App and website may contain links to or integrations with third-party services (e.g., MTN MoMo payment pages, Airtel Money). These third parties have their own privacy policies, and we encourage you to review them. We are not responsible for the privacy practices of such third parties. Our collection and use of information from these interactions is governed by this Privacy Policy.
11. International Data Transfers
LUVA TECH INTERNATIONAL LIMITED is headquartered in Kenya, and some of our service providers may be located in other countries. If your data is transferred outside of Uganda or Kenya, we ensure that appropriate safeguards are in place (such as contractual data protection clauses) to maintain the same level of protection required by applicable data protection laws. By using our Services, you consent to such transfers.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons. When we make material changes, we will:
- Post the updated policy on this page with a new "Last Updated" date.
- Send a notification through the App or via email at least 14 days before significant changes take effect.
Your continued use of the Service after changes have been posted constitutes your acceptance of the updated Privacy Policy.
13. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:
We aim to respond to all privacy-related inquiries within 30 business days of receipt. If you are not satisfied with our response, you may have the right to lodge a complaint with the relevant data protection authority in Uganda.