1. Privacy Policies

 What data and how is collected and used

“Iman Pay” app collects following user’s data:

- Phone number

- Passport or ID card

related to calendar events.

- Accounts: This might include social accounts, however profiles and information

related to user inside the app is not collected. Only metadata related to accounts are

being collected.

- Installed Applications: only metadata related to installed applications are being

collected.

The process of data collection includes registration steps where users add personal

data after accepting the “Public offer” which includes “Privacy policy” rules by using

OTP in the app.

The SMS read access is needed to identify the financial eligibility of the user to

access the core financial service of Iman Pay. If the user denies granting SMS access,

they are not able to continue the journey until the end in order to access the core

financial service offered by Iman Pay.

We collect users’ SMS for conducting behavioral scoring for checking their

creditworthiness. Received information assists us to prevent fraud and check our

potential customers in more details before providing them financing aid that can

improve our installment portfolio.

Such data collection should be also approved by customers. They can accept our

Without users’ acceptance we do not use their personal data for scoring.

- Image

Face data which is collected by the app we send to local authority’s database for

users’ identification. It allows to recognize face of our users by comparing it with

data from governmental organization. It assists us to prevent the growth of fraud

cases. Thus, third party already has face data of users, and they store it not more than

during the one year.

We use access to locations of our users for showing closest shops of our partners to

them. Here, we ask permission from users to access to their location. If they deny we

do not access to their location.

“Iman Pay” app uses the service for marketing purposes.

2. CredoLab Pte Ltd.

“Iman Pay” app uses Credolab services as part of decision process to assess your

creditworthiness, provide a segmented risk profile and generate an aggregated

statistical information. To protect your identity, we remove all personal identifiers (if

Credolab’s privacy policy is available at the following link:

https://www.credolab.com/privacy-policies/gdpr-privacy-policy.

 Explanation of data retention/deletion policies

According to our retention policy, collected data is retained until we get response

from organizations which provides information about the users’ creditworthiness.

With respect to our deletion policy, we provide two options for users of app “Iman

Pay”: log out from the app and delete their account. First option allows users to leave

 Request of permissions

Before starting the registration process, user is asked to provide permission for

collecting their personal information for scoring. Users should be familiarized with

“Public offer” document and accept it. This document includes information of

“Privacy Policy” rules which are also accepted by users. After receiving the

permission from user for collecting their personal information, registration process is

started.

“Public offer” we start automatically to collect data for providing limit which can be

used by users for purchases in installments. If users do not agree with collection of

their information they reject “Public offer” and do not register in the app.

3. Data Minimization

“Iman Pay” app asks an access only to “Camera” and “Contacts” apps which are

essential for core functionality of the app. Access to “Camera” is needed for taking a

selfie in the app. “Contacts” is used for adding friends’ contracts in the app. It’s

important for users who can take a participation in the referral system.

5. Account Sign-In

“Iman Pay” app includes account-based features. Therefore, the process of users’

sign-in is crucial for the core functionality of the app. Here, we provide our users

option to delete their account if they do not want to hold it. Account deleting

functionality is placed in app’s “Settings” near the “Log out” button.

6. Apps for discovering the passwords

It’s restricted in our company to use developers’ apps for discovering the passwords of

users.

7. SafariViewController

“Public offer” by users. Acceptance of this document means that users allow to collect

their personal information for scoring. Our company restricts to collect users’ personal

information without their explicit consent.

9. Legal entity submits user information

“Iman Pay” app provides financial service that’s specialized as highly regulated field.

Therefore, user information is submitted by a legal entity providing services, not by our

developers.

10. Request of basic contact information

“Iman Pay” app requests basic contact information from users as their phone number.