Legal

Consumer Protection Policy / Privacy Policy

Effective date: 18th October 2021

At Goodloans Limited, we’re committed to protecting and respecting your privacy. This Privacy Policy explains when and why we collect personal data (including sensitive personal data) about people who visit our website and use our software applications, how we use it, the conditions under which we may disclose it to others and how we keep it secure.

We will update this Policy from time to time, so please check this page regularly to ensure that you’re happy with any changes. All updates and amendments are effective immediately upon notice, which we may give by any means, including, but not limited to, by posting a revised version of this Privacy Policy Statement or other notice on the website or within our smart phone application. We encourage you to review this Privacy Policy Statement often to stay informed of changes that may affect you.

Any questions regarding this Policy and our privacy practices should be sent by email to: hello@goodloans.co. Please also feel free to provide feedback, suggestions or improvements you feel we can make to this Privacy Policy, as we are always looking for ways to improve the way we protect our customers’ privacy, and better meet our customers’ needs.

We are only able to provide you with the services (including use of our website and software applications) under the conditions of this privacy policy.

Who we are

Goodloans Limited Company (referred to as “Goodloans Limited”, “Goodloans”, “we”) is a London-based technology company which operates in Africa. Our core mission is to provide financial products and services to the underserved and unbanked in Africa. To this end, we have built software applications that allow you to apply for financial products and services. Goodloans Limited Company is a Private Limited Company registered in the UK, with company number 12482742. Our registered address is: Goodloans Limited, The Harley Building, 77 New Cavendish Street, London, England, W1W 6XB

Who controls the personal data we collect from you

Under the GDPR (General Data Protection Regulation), Goodloans are known as a data “Controller” of the personal data you provide us. We are registered with the ICO (Information Commissioner’s Officer) in the UK registration reference: ZB024107 and also with Ghana DCP (Data Protection Commission) registration reference: 0003473.

We collect data on behalf of Partner Lenders, who review (incl. KYC checks) and process user loan applications (incl. disbursing and collecting loans and sharing relevant data with the regulator).

If you are not satisfied with how we process your data you can contact hello@goodloans.co, you can also raise a concern with the ICO (https://ico.org.uk/) with our company’s registration reference ZB024107. Please go to https://ico.org.uk/concerns/ for more information about raising a concern with the ICO.

How we collect personal data from you

We obtain personal data about you when you use our smart phone application, and we also collect web analytics and marketing data for our website using cookies, web beacons and similar technologies, some of which are provided by third parties as described below.

Cookies

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide data to the owners of websites. We use the following cookies:

Google Analytics
Facebook Pixel

These cookies are used to collect data about how visitors use our website. We use the data to compile reports and to help us improve the website, and for marketing, advertising and promotional purposes strictly related to Goodloans. The cookies collect data in an anonymous form, including the number of visitors to the website, where visitors have come to the website from and the pages they visited.

Web beacons

Small graphic images (also known as “pixel tags” or “clear GIFs”) that may be included on our sites, services, applications, messaging, and tools, that typically work in conjunction with cookies to identify our users and user behavior. We use the following web beacons: -* Facebook Pixel (cookie names: act, c_user, datar, dpr, fr, pl, presence, sb, wd and xs)

How to change your cookie settings

Most web browsers allow some control of cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

What personal data we collect

To provide Goodloans as a service, prevent fraud and meet our regulators requirements, we collect personal data (including sensitive personal data) from our users. We will only collect personal data required to provide you with the services you have requested. To help provide you with a clear view of the personal data we collect, we have divided the data into personal data and sensitive personal data:

Personal data: first name, last name, gender, locale, timezone, address, email address, details provided throughout the loan application form, in applications events, smartphone information, smartphone installed applications. In addition,
Sensitive personal data:

Photo of Identity Cards and front facing photo to confirm identification
Geo-location
Phone contacts
SMS data that contains financial transactions
Financial data
Bank account data

We also collect data from third party organisations including credit reference bureaus and identification registries. We always take steps to ensure that third-party data providers are legally and contractually bound to disclose your personal information to us.

Basis for processing, and why we need to do it

We process personal data in order to provide services requested by you. This includes:

Verify your identity
Verify loan applications
Identify/prevent fraudulent use of our software applications
Identify/prevent financial fraud
Track financial activity
Build credit models
Customising your experience of our software applications
Processing payments to Goodloans
To enable Partner Lenders to disburse and collect loans
Provide aggregated insights to our third-party lending partners
Provide support and help with using our software applications
Understand how users use our software applications
Gain insights on new financial products and service we could develop
Analyse users’ behaviours to help improve our service
Conduct research and development
To meet legal requirements or response to lawful requests by authorised parties
To prosecute and defend our rights in a legal proceeding or enforce compliance with any agreement with us.

Profiling

Goodloans undertake analysis and profiling of your financial information in order to identify and inform you of financial products that we consider are likely to interest you or be suited to your financial circumstances or to enhance our services. You’ve the right not to be subject to a decision based solely on automated processing, including profiling. We understand that not everyone is comfortable with decisions being left entirely up to machines. If you have any questions about automated decision making, please contact us viahello@goodloans.co

How long the personal data is kept

We will hold your personal data (including sensitive personal data) on our systems for as long as you are using our services. Once you stop using our services, we hold your personal data for five years in case you wish to restart our services. If you don’t resume using our services within that time period we will fully anonymise your personal data so that you are no longer identifiable. If you wish your personal data to be deleted or anonymised before this five year window please contact us.

Who has access to your personal data

We only provide internal data access to trained individuals within Goodloans, who have an understanding of GDPR and its implications. All personal data that you provide through the services may be stored on AWS S3 (https://aws.amazon.com/s3), AWS DynamoDB (https://aws.amazon.com/dynamodb/) Firebase (https://firebase.google.com/) and/or Google Cloud Platform (https://cloud.google.com/).

Your data protection rights

You have a number of rights under the personal data protection laws, namely:

To access your personal data (by way of a subject access request);
To have your personal data rectified if it is inaccurate or incomplete;
To have your personal data deleted or removed, if: it is no longer required for the purpose it was collected; (ii) we are processing it with your consent and you withdraw your consent to its processing; (iii) you object to the processing and we have no overriding legitimate interest for the processing; (iv) the personal data has been unlawfully processed; or (v) we are required to delete it in order to comply with the law;
To restrict the processing of your personal data, if: (i) it is inaccurate and we require time to verify its accuracy; (ii) the personal data has been unlawfully processed; (iii) the purpose for which it was collected is no longer relevant, but we are required to keep it for legal reasons; or (iv) you object to the processing and we have no overriding legitimate interest for the processing;
A right of data portability, namely to obtain and reuse your personal data for your own purposes across different services if (i) we are relying on your consent;
To object to processing where (i) processing is based on public interest; (ii) processing is necessary for our legitimate interests or that of a third party. You also have the right to object to direct marketing and any related profiling;
Not to be subject to automated decision making (including profiling) which produces a legal effect or a similarly significant effect on you unless the processing is (i) required for entering into or performance of a contract; (ii) authorised by law; or (iii) we have your explicit consent to do so.
To claim compensation for damages caused by a breach of the data protection legislation;
If we are processing your personal data with your consent, you have the right to withdraw your consent at any time.

What happens if you fail to provide us with personal data

If you do not provide the required personal data we will not be able to provide you with the services you have requested.

In addition, we will be unable to provide you with financial products or services if you do not agree to the use of this privacy policy.

Agreement to Use of Personal Information and Data

By using our mobile application and website, you are consenting to our use of your personal information and data as described in this Privacy Policy Statement.

How to contact us

Please contact us if you have any questions about our privacy policy or personal data we hold about you by emailing our Data Protection Officer athello@goodloans.co, or by post: Data Protection Office, Goodloans Limited, The Harley Building, 77 New Cavendish Street, London, England, W1W 6XB.