PRIVACY POLICY

March 5, 2026

Dotcash takes your privacy very seriously. This Privacy Policy explains what personal information we collect, with whom we share it, and how you, as a user of the Service, can prevent us from sharing certain information with certain third parties. By downloading Dotcash, you consent to the collection and processing of your personal information for Dotcash's legitimate business purposes, including, but not limited to, determining your credit score and providing loans. By accepting the terms of this Privacy Policy, you consent to the practices described herein.

Permission Notice

Dear customer, for us to better assess the credit score of you and offer the best loan, we need the below permission.

MOBILE PHONE(DEVICE)

Purpose: To detect potential fraud and verify the authenticity of your device.

Data Collection: We collect information about your device, including device name, model, phone status, and sensitive identifiers restricted by iOS. We do not access sensitive identifiers restricted by iOS.

Security: All data is encrypted and transmitted securely. It is not shared with third parties.

Location Data

Purpose: To confirm that you are located in Kenya and support risk control.

Data Collected: If you allow location access, we may collect your approximate location using the iOS location services framework.

Security: Location data is encrypted and securely transmitted to our server. We do not share your location with any third parties.

Emergency Contacts

Purpose: To verify your identity and assess credit risk.

Data Collected: You may manually enter the names, phone numbers, and relationships of two emergency contacts. We do not access your entire contact list or collect additional contact data.

Security: data is encrypted and securely transmitted to our server. We do not share your location with any third parties.

CAMERA

Purpose:To verify that the action was performed by you and not by someone else.

Data Collected:Take a photo of your ID and a selfie.

Security: data is encrypted and securely transmitted to our server. We do not share your location with any third parties.

How do we use your data

We collect certain data to be able to provide the Service to you. We also collect data for use in verifying your identity and creating credit scoring models to determine what Loans can be offered to you. We also use this data for purposes of collections and credit reporting.

The data we collect

When you register for the Service, we will collect your M-Pesa number and phone number and may also collect your name, age, image, media, email address or other contact information. Using this information, we will verify your identity with third parties, including emergency contacts you provide. We will also collect data from your device for use in our credit scoring system. This includes information related to your device, such as device manufacturer and model, operating system, and we also collect your email, such as SMS logs. To supplement this information, we also collect data from third parties, such as credit bureaus and other financial institutions. By registering for the Service, you authorize the collection and processing of the above data.

We will ensure that your data is protected to a strict standard.

The following Privacy Policy describes how we, Dotcash and its Affiliates, collect, store, use, transfer, disclose and protect your Personal Information.

Please read the following carefully to understand our views and practices regarding your Personal Information and how we will treat it. By downloading the App, you confirm that you have read, understood and accept the terms of this Privacy Policy set out hereunder. You also consent to the collection, use, storage, processing and disclosure of your Personal Information in the manner set out in this Privacy Policy. This Privacy Policy together with our Terms of Use and any additional terms applies to your use of the System and the Service.

This Privacy Policy includes the following matters:

1. DEFINITION

Unless otherwise defined, all capitalised terms used in this Privacy Policy shall have the same meanings ascribed to them in our Terms of Use (as applicable).

2. PERSONAL INFORMATION WHICH WE COLLECT

We collect certain Personal Information about you. The Personal Information which we collect may be provided by you directly (for example, when you opening an Account to use the Service via App, or you otherwise provide Personal Information to us) or by third parties, or be collected automatically when you use the App. We may collect information in various forms and for various purposes (including purposes permitted under Applicable Law).

Information obtained from you or from your Mobile Device directly:

Information collected whenever you use the App or visit our Website:

Information collected from third parties:

Due to the nature of the Services which we provide, we are required to work with a number of third parties (including Credit Reference Bureaus, Banks, Mobile Network Providers, collection agencies ,our agents, vendors, suppliers, contractors, partners and any others who provide services to us, perform functions on our behalf, or whom we collaborate with) and we may receive information about you from them. In such cases, we will only collect your Personal Information for or in connection with the purposes for which such third parties are engaged or the purposes of our collaboration with such third parties (as the case may be), provided that we have taken reasonable steps to ensure that such third parties would undertake to us to obtain your consent for the disclosure of your Personal Information to us in line with this Privacy Policy and Applicable Law.

Information about third parties you provide to us:

You may provide us with Personal Information relating to other third party individuals (such as Personal Information relating to your spouse, family members, friends and emergency contact). You will of course need their consent to do so–see Section 12 "Acknowledgement and Consent", below, for further information.

3. THE USE OF PERSONAL INFORMATION WHICH WE HAVE COLLECTED

We may use Personal Information collected for any of the following purposes as well as for such other purposes as are permitted by Applicable Law:

a. We may use your Personal Information:

b. We may also use your Personal Information more generally for the following purposes (although we will in each such case always act reasonably and use no more Personal Information than what is required for the particular purpose):

4. SHARING OF PERSONAL INFORMATION WHICH WE COLLECT

a. We may disclose to or share with Affiliates and other parties your Personal Information for any of the following purposes as well as for such other purposes as are permitted by Applicable Law (although we will in each such case always act reasonably and disclose or share no more Personal Information than what is required for the particular purpose):

b. Where it is not necessary for the Personal Information disclosed or shared with other parties to be associated with you, we will use reasonable endeavours to remove the means by which the Personal Information can be associated with you as an individual before disclosing or sharing such information.

c. Other than as provided for in this Privacy Policy, we may disclose or share your Personal Information if we notify you of this in advance and we have obtained your consent for the disclosure or sharing.

5. CROSS-BORDER TRANSFERS OF PERSONAL INFORMATION

Your Personal Information may be transferred to, stored, used and processed in a jurisdiction other than your home nation or otherwise in the country, state and city in which you are present while using any Service provided by us ("Alternate Country"), to companies Dotcash under Our group which are located outside of your home nation or Alternate Country and/or where Our Dotcash group's servers and/or service providers and partners are located outside of your home nation or Alternate Country.

In such a case, We shall ensure that such Personal Information remains subject to a level of protection comparable to what is required under the Kenya Laws (and, in any event, in line with our commitments in this Privacy Policy).

You understand and hereby consent to the transfer of your Personal Information out of your home nation or Alternate Country

6. Retention and deletion of personal information

a. Your Personal Information will only be held for as long as it is necessary to fulfill the purpose for which it was collected, or for as long as such retention is required or authorised by Applicable Law. We shall cease to retain Personal Information, or remove the means by which the Personal Information can be associated with you as an individual, as soon as it is reasonable to assume that the purpose for which that Personal Information was collected is no longer being served by retention of Personal Information and retention is no longer necessary for legal or business purposes.

b. We provide you with the right to cancel your account. If you wish to cancel your account, please follow the corresponding steps to cancel your account through "My-Settings-Cancel Account" or notify us by sending an email. If you want to cancel your account via email, the subject of the email should be "Cancel Account", and the email should indicate your name, mobile phone number, KTP and other information, and send the email to the customer service email. We will arrange a dedicated person to assist with account cancellation.

Please understand that after you submit the cancellation process, we may need to manually review your account cancellation to confirm whether you meet the account cancellation criteria. We will help you complete the account cancellation within 90 working days after sending your request. After you choose to cancel your account, we will delete or anonymize all relevant personal information in your account, unless otherwise provided by laws and regulations. After you log out, we will no longer be able to provide you with products or services that require your account login.

7. ACCESS AND UPDATE/CORRECTION OF PERSONAL INFORMATION

a. You may request us for access to and or the correction of your Personal Information in our possession and control, by contacting us at the details provided below. Subject to Applicable Law, we reserve the right to charge an administrative fee for such requests.

b. We reserve the right to refuse your requests for access to, or to correct, some or all of your Personal Information in our possession or control, if permitted or required under any Applicable Law. This may include circumstances where the Personal Information may contain references to other individuals or where the request for access or request to correct is for reasons which we reasonably consider to be trivial, frivolous or vexatious.

8. WHERE WE STORE YOUR PERSONAL INFORMATION

a. The Personal Information that we collect from you may be stored at, transferred to, or processed by third party service providers. We will use all reasonable endeavours to ensure that all such third party service providers provide a level of protection that is comparable to our commitments under this Privacy Policy.

b. Your Personal Information may also be stored or processed outside of your country by personnel who work for us in other countries, or by our third party service providers, suppliers, contractors or Affiliates, to the extent permitted under Applicable law. In such a case, we will ensure that such Personal Information remains subject to a level of protection comparable to what is required under the laws of your country (and, in any event, in line with our commitments in this Privacy Policy).

9. SECURITY OF YOUR PERSONAL INFORMATION

Confidentiality of your Personal Information is of utmost importance to us. We will use all reasonable efforts to protect and secure your Personal Information against access, collection, use or disclosure by unauthorised persons and against unlawful processing, accidental loss, destruction and damage or similar risks. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your Personal Information, you acknowledge that we cannot guarantee the integrity and accuracy of any Personal Information which you transmit over the Internet, nor guarantee that such Personal Information would not be intercepted, accessed, disclosed, altered or destroyed by unauthorised third parties<, due to factors beyond our control. You are responsible for keeping your Account details confidential and you must not share your password with anyone and you must always maintain the security of the Mobile Device that you use.

10. CHANGES TO THIS PRIVACY POLICY

We may review and amend this Privacy Policy at our sole discretion from time to time, to ensure that it is consistent with our future developments, and/or changes in legal or regulatory requirements. If we decide to amend this Privacy Policy, we will notify you of any such amendments by means of a general notice published on the App and/or Website, or otherwise to your e-mail address set out in your Account. You agree that it is your responsibility to review this Privacy Policy regularly for the latest information on our data processing and data protection practices, and that your continued use of the App or Website, communications with us, or access to and use of the Service following any amendments to this Privacy Policy will constitute your acceptance to the amendments.

11. LANGUAGE

If there is any inconsistency between the English version of this Privacy Policy and other language versions, the English version shall prevail.

12. ACKNOWLEDGEMENT AND CONSENT

a. By accepting the Privacy Policy, you acknowledge that you have read and understood this Privacy Policy and you accept all of its terms. In particular, you agree and consent to us collecting, using, disclosing, storing, transferring, or otherwise processing your Personal Information in accordance with this Privacy Policy.

b. In circumstances where you provide us with Personal Information relating to other individuals (such as Personal Information relating to your spouse, family members, friends or emergency contact), you represent and warrant that you have obtained such individual's consent for, and hereby consent on behalf of such individual to, the collection, use, disclosure and processing of his/her Personal Information by us.

c. You also consent and expressly authorise to contact you and your emergency contact who has expressly agreed upon it, to verify your information or when we are unable to contact you via other methods or when we have not received your payment in connection with Loan.

d. You may withdraw your consent to any or all collection, use or disclosure of your Personal Information at any time by giving us reasonable notice in writing using the contact details stated below. You may also withdraw your consent for us to send you certain communications and information via any "opt-out" or "unsubscribe" facility contained in our messages to you. Depending on the circumstances and the nature of the consent which you are withdrawing, you must understand and acknowledge that after such withdrawal of consent, you may no longer be able to use the App or certain of the Service. A withdrawal of consent by you may result in the termination of your Account or of your contractual relationship with us, with all accrued rights and obligations remaining fully reserved. Upon receipt of your notice to withdraw consent for any collection, use or disclosure of your Personal Information, we will inform you of the likely consequences of such withdrawal so that you can decide if indeed you wish to withdraw consent.

13. MARKETING AND PROMOTIONAL MATERIAL

a. We may send you marketing and promotional communications via post, telephone call, short message service (SMS), e-mail, online messaging, or push notifications via the App to notify you about special privileges, promotions, or events offered or organised by us, our partners, sponsors, or advertisers, or to provide updates on our App and/or the products and services offered therein.

b. You may opt out from receiving such marketing communications at any time by clicking on any "unsubscribe" facility embedded in the relevant message, or otherwise contacting us using the contact details stated below. Please note that if you opt out, we may still send you non-promotional messages, such as Loan disbursement or repayment receipts, or information about your Account or the App.

14. THIRD PARTY WEBSITES

a. The App and Website may contain links to websites that are operated by third parties. We do not control nor accept liability or responsibility for these websites and for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties. Please consult the terms and conditions and privacy policies of those third-party websites to find out how they collect and use your Personal Information.

b. Advertisements contained on our App or Website operate as links to the advertiser's website and as such any information they collect by virtue of your clicking on that link will be collected and used by the relevant advertiser in accordance with the privacy policy of that advertiser.

15. ANALYTICS SERVICE PROVIDERS

By integrating the Facebook SDK into your application, Meta Platforms, Inc. and its affiliates may receive and process certain types of user data on our behalf to provide the core functionality of the SDK. This data collection depends on whether you have enabled app event analytics or ad displays in our app. To understand how our analytics service provider uses your information, you can view their privacy statement: https://www.facebook.com/privacy/policy

16. CHILDREN PRIVACY

To use our Services, you must be at least 18 years old. We cannot guarantee that children will not visit our websites or use our applications without parental consent or notification, and we do not knowingly collect, maintain, or use information from children under 18, and our Services are not directed to children. If you become aware that a child has provided us with information that violates this Privacy Policy, you may notify us at [email protected]

17. LIMITATION OF LIABILITY

We shall not be liable for any indirect, incidental, consequential, special, exemplary or punitive damages arising out of:

a. Your use of or reliance on the App or your inability to access or use the App; or

b. Any transaction or relationship between you and any other third party, even if we have been advised of the possibility of such damages.

We shall not be liable for delay or failure in performance resulting from causes beyond our reasonable control.

18. HOW TO CONTACT US

If you have any questions regarding this Privacy Policy or you would like to obtain access and/or make corrections to your Personal Information, please contact our Data Protection Officer at:[email protected]