This policy has being duly authorized by the directors of Modality Apps (Pty) Ltd.
This policy is applicable to all staff and clients of Modality Apps (Pty) Ltd.
19 September 2018.
We, at Modality Apps (Pty) Ltd, acknowledge your needs as a user and as our valued customer specifically with regards to need for the security of your business’ private data and / or information and in turn the need for restrictions over the use and sharing of the same.
The above foremost in our minds, the purpose of this document is to provide you with an understanding as well as reasonable assurance with regards to:
security of your data and / or information;
how we collect your data and / or information;
how we use your data and / or information including:
the data and / or information we keep; and
the data and / or information we share.
This policy is regularly reviewed to make sure that we continue to serve your best interests with regards to privacy.
We are committed to keeping your information confidential and will not share or disclose any of your information with any unauthorised third party or user outside of your organization.
Any reference to "we" or "us" in this document shall mean Modality Apps (Pty) Ltd. and any reference to “you” shall mean the user of Mobiloan and in turn expressly the client of Modality Apps (Pty) Ltd.
Any Clause headings are for convenience and are not to be used in its’ interpretation;
Unless the context indicates a contrary intention an expression which denotes:-
masculine shall include feminine and vice versa;
a natural person shall include a juristic person and vice versa; and
the singular shall denote the plural and vice versa.
This document should be read in conjunction with The Protection of Personal Information Act, No 4 of 2013 (POPI);
Where there is a conflict between the words describing a number and the number, the words will prevail.
We recognise how important it is to protect and manage the information you share with us. To achieve our security objectives we:
Use software driven programmatic safeguards such as firewalls and data encryption;
Restrict access to physical hardware managed by ourselves;
Limit access to those employees identified by you and who require the same to discharge their responsibilities only.
When you share data with us through Mobiloan, that information is protected by secure socket layer (SSL) encryption.
Our security systems meet or exceed industry standards and we are constantly monitoring technological developments to ensure our systems are in line with industry best practices.
We collect information about you and your business in a number of ways, including:
Information you provide to us through the Mobiloan App and Mobiloan Dashboard;
Information you provide through communications with us; and
From integration partners such as credit bureaus and payment service providers.
In addition to the personal and financial information you submit (or we collect), we may also collect information about your computer including, where available, your IP address, operating system and browser type, for the purposes of system and loan administration and product improvement.
Information we retain
We will retain the following details for your sole use and benefit:
Your users’ and clients’ names, ID numbers, addresses, phone numbers, email addresses, employment, affordability, references, banking, financial details, images, signatures and uploaded documents;
Passwords, which are stored in an encrypted format and are not viewable or directly accessible by the staff or any users of Mobiloan;
The information you generate through Mobiloan from credit reference bureaus;
Details of the loans and transactions you perform through Mobiloan. Such information may be held within a database and / or electronic documentation;
Any other information which we reasonably need in order to operate your account or fulfil our regulatory obligations and discharge our responsibilities in terms of the appropriate Service Level Agreement.
We commit to retaining your data on our systems for the duration of your Service Level Agreement with Modality Apps (Pty) Ltd plus six (6) months thereafter, whereafter it will be removed from our servers and returned to you at your request in the most practical digital format. All your information is always available to you though the Mobiloan App or Mobiloan Dashboard.
Information we share
We will keep your information confidential and only share it with others for the purposes explained in this policy. We have trusted relationships with carefully-selected third parties who perform services on our behalf. All service providers are bound by contract to maintain the security of your information and to use it only as prescribed in their respective privacy policies.
Currently information is shared with the following service providers:
Amazon.com, Inc. Mobiloan stores all electronic documentation and payment responses generated through Mobiloan using Amazon EC2 web services. https://aws.amazon.com/privacy;
Journey Mobile, Inc. The Mobiloan platform runs on the Journey mobile app container which synchronizes all information on the app’s local database with their central cloud database hosted in South Africa. http://journeyapps.com/privacy-policy.html;
Information Technology Consultants (Pty) Ltd (Intecon). Mobiloan facilitates the creation and management of payment services provided by Intecon by using Intecon’s web services https://intecon.co.za/privacy-policy.php.
In addition to the above we may share your information with:
Any person to whom we sell or transfer (or enter into negotiations to sell or transfer) our business or any of our rights or obligations under any agreement we may have with you. If the transfer or sale goes ahead, the transferee or purchaser may use your information in the same way as us;
Regulatory and governmental authorities or ombudsmen, or other authorities, including tax authorities, if we are requested by them to do so; and
In complying with an order of court, having appropriate jurisdiction.
How we use your information
Your data is for your sole use and benefit and we will not use or disseminate it without your written knowledge or consent.
Notwithstanding the above, your data will be used to:
Allow you to operate and manage your Mobiloan application and its related services;
For us to manage any application, agreement or correspondence you may have with us;
Carry out, monitor and analyse our business;
Contact you by email, SMS, letter or telephone about our products and services, unless you tell us in writing that you do not want to receive marketing from us;
To form a view of you as an end user and to identify, develop or improve products, that may be of interest to you;
Carry out market research, business and statistical analysis;
Carry out audits; and
Perform other administrative and operational tasks, including the testing of systems.
Your data may also be used for other purposes for which you give your permission, or where we are permitted to do so by law, or where it is otherwise permitted under the terms of the The Protection of Personal Information Act, No 4 of 2013 (POPI).
For the purpose of the Protection of Personal Information Act, No. 4 of 2013 (POPI), the data controller is Modality Apps (Pty) Ltd.