Privacy and Policy

DANA FinTech Limited

Bangladesh

Privacy Policy

Effective Date: 14/12/2021

Summary

Dana FinTech Limited takes your privacy very seriously. This Privacy Policy outlines what personal information we obtain, with whom we share it, and how we can be stopped from sharing such information with certain parties. This Privacy Policy should be read in its entirety. For citizens of various jurisdictions, such parts can apply differently. You agree to the following by installing Dana:

"By downloading Dana, I hereby agree to the collection and processing of my personal information, including but not limited to the determination of my credit score and the provision of a loan, for valid business purposes. I hereby certify that to the best of my understanding, all the information given by me is accurate and correct and that any misrepresentations or falsification therein would be treated as an attempt to defraud Dana and her partners. I authorize Dana, from the references given and other appropriate sources, to verify and investigate the above statements/information as may be needed. I hereby waive my rights to the confidentiality of customer information for this reason and expressly agree to the collection of any personal information and documents relating to me that may be collected from third parties, including government agencies, my employer, credit offices, business associates and other institutions that may be deemed necessary and sufficient in the conduct of my company. Furthermore, I accept that this request and all supporting documentation and all other information collected in connection with this request shall be used and transmitted to Dana and shall remain the property of Dana, whether or not my credit score has been assessed or the loan has been granted. I specifically and unconditionally allow Dana to reveal any information concerning me to any bank or affiliate and to any other financial institution. In particular, I hereby accept and authorize: 1) the routine submission and disclosure, as well as any modification or correction thereof, of my basic credit data; and 2) the sharing of my basic credit data with other lenders and with properly accredited credit reporting agencies."

1: Introduction

This policy applies to your use of:

- Once you have downloaded or streamed a copy of the App to your cell phone or handheld device, the Dana mobile application program is available on our platform or hosted on the Google Play Store.

- Some of the services are provided via the App that is accessible through the App Portal or some of our other pages.

The definitions of the words used in this policy are as follows:

'Authorities' shall include any legal, administrative, public or regulatory authority, any government, any tax authority, exchange of securities or futures, any judge, central bank or law enforcement authority, or any of its agents having jurisdiction over Dana.

'Compliance obligations' means Dana's obligations to comply with a) laws or international rules and internal policies or procedures; (b) any authority order or reporting, disclosure or other contractual obligations; and (c) laws requiring us to verify our customers' identity.

'Customer' or 'Consumer' means any person in the territory to whom Dana supplies its goods or services.

'Customer Information' means your personal data, sensitive and/or tax information, including your relevant information, your purchases, your use of our products and services and your relationships with Dana.

'Financial crime' means money laundering, terrorist funding, corruption, corruption, tax evasion, fraud, evasion of economic or commercial penalties and/or any act or attempt to circumvent or infringe any of the applicable laws.

'Law' include any local or international law, legislation, judgment or court order, voluntary code, system of penalties, agreement between any member of Dana and the Authority, or agreement or treaty between the Authority and the Authority that applies to Dana.

'Personal Data' or 'Personal Information' refers to any information, whether captured in a material form or not, from which an individual's identity is obvious or can be fairly and directly ascertained by an agency keeping the information, or which, when combined with other information, would identify an individual directly and definitely.

'Sensitive Personal Information' refers to Personal Information (1) relating to the ethnicity, ethnic origin, marital status, age, color, and social, philosophical or political affiliations of an individual; (2) relating to the health, education, genetic or sexual life of an individual, or to any proceeding for any offense committed or alleged to have been committed by that individual; (3) issued by government agencies unique to a person, including but not limited to, social security numbers, prior or current health records, licenses or denials thereof, suspension or revocation, and tax returns; and (4) expressly provided for by an executive order or by an act to be retained by Government.

'Services' means that once you have downloaded or streamed a copy of the App on your Device, you keep the App available on our site OR hosted on the App Site.

'Tax authorities' means the tax, revenue or monetary authorities of Bangladesh or abroad.

'Tax information' means your tax status paperwork or information.

"We", "Our" and Us" actually refer to Dana. The plural involves reference to the singular (and vice versa).

2: Information Dana collects

Customer information can be stored, used and exchanged. Customer Information may be requested by us or on our behalf, or by Dana, and may be obtained from you directly, from a person acting on your behalf, from other sources (including from information available to the public), and may be produced or combined with other information available to us or to any Dana member. The following information about you will be collected by us, which may include non-public personal information:

- Data sent to us by you: Given by filling in the App or on the App Web forms; Supplied by contacting us for example, by e-mail or chat); Generated by registering to use the App Site, installing or registering an App, subscribing to some of our Services (such as borrowing), searching for an App or Service, exchanging information via the social media features of an App, joining a contest, advertisement or survey, and reporting an issue with an App, our Services, or any of our Sites; Your name, address, e-mail phone number and address, telephone number of the device, SIM card, age, username, password and other registration details, financial and credit information, personal description and photograph.

 - Details about you and your device that we obtain. Any time you visit one of our blogs or websites, The information we can collect includes but is not limited to the following: using one of our Apps: Technical details, including the type of mobile device you are using, basic device identifiers, (for example, the IMEI or serial number of your device), information about the SIM card used by the device, information about the mobile network, the operating system of your device, the type of browser you are using or the location and time zone settings of your device (device information); Data saved on your device, including transactional notification SMS provided by financial institute ;

- Data from other sources that we obtain. We reserve the right to work with, and may obtain information about you from, a small range of third parties (including credit reference agencies, mobile network providers, and collection agencies).

- Application Numbers Unique. When you install or uninstall a Service that contains a specific application number, or when that Service is checking for automatic updates, we may obtain that number and your installation details, such as the type of operating system. Occasionally, through our mobile apps, we can send you push notifications to send you marketing messages and other notifications relevant to the service or transaction that may be important to you. You can opt out of receiving these types of communications at any time by turning them off through your settings or mobile application settings at the device level. We and our third-party service providers, including our marketing partners and analytics providers, may use mobile tracking technologies and/or website cookies to distinguish you from other users of the App, App Site or Service Site. This helps us to provide you with a good experience when you use the App or browse any of the sites and also allows us to improve the App and Our Sites.

We automatically capture such information and store it in log files, as is true of most websites. Your Internet Protocol (IP) address, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and/or clickstream data may be included in this information. From time to time, for reasons such as research, protection, content generation or marketing, we might combine this automatically collected data with other data we collect about you.

In order to improve and evaluate the use of the service, we can use analytics tools and applications. In order to help us understand how the service is used, analytics companies can access anonymous person data. Within the analytics program, we can link the information we store to any personal information you send within the mobile applications.

You may revoke your permission to access your customer details in the future by uninstalling the app from your device. We may store and exchange Customer Information after uninstalling for as long as necessary for the purposes for which Customer Information has been obtained or for the purposes for which legal claims have been created, exercised or defended, or for legitimate business purposes, or as permitted by law.

3: Why Dana collects data

We collect information for the following reasons, including but not limited to ('purposes'):

- To verify your identity;

 - To disburse loans and collect payments for your use of the Service

- To build the credit models and perform credit scoring

- To evaluate the actions of the customer

- To allow our partners to fulfill their obligations to you

- To allow us to fulfill our obligations to our partners

- To troubleshoot issues with the Service

- To comply with applicable laws, regulations, and rules, such as those relating to "know-your-customer" and anti-money laundering requirements

- To detect and prevent fraud and other illegal uses of the Service

- To give you marketing alerts, service notifications, and promotional offers

- To reach you by phone using an auto-dialed or pre-recorded message call or text message (SMS) messages as allowed for the purposes defined in this Privacy Policy (if applicable)

4: Usage and sharing of your Information

These clauses explain how we will use and share your information. By using the Services, you agree that we and members of Dana shall use Customer Information in accordance with such clauses.

Uses made of the information:

- We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.

- Information collected by us shall be used for the Purposes defined in this Policy.

- We do not disclose information about identifiable individuals to other parties, unless it is necessary for providing the Services. We may share limited personal information with select partners for research and development. We may provide other parties with anonymous individual information about our users for the purposes of compiling statistics relating to our user base or loan portfolio and may disclose such information to any third party for such purposes, provided that such information will always be anonymous.

Sharing:

By using the Services, you agree that we may, as necessary and appropriate for the Purposes, transfer and disclose any Customer Information to the following recipients globally (who may also process, transfer and disclose such Customer Information for the Purposes):

- Any member of Dana and any sub-contractors, agents, service providers, or associates of Dana (including their employees, directors and officers);

- Persons acting on your behalf, payment recipients, beneficiaries, account nominees, intermediary, correspondent and agent banks, clearing houses, clearing or settlement systems, market counterparties, upstream withholding agents, swap or trade repositories, stock exchanges, companies in which you have an interest in securities (where such securities are held by us for you);

- Any financial institutions, credit reference agencies or credit bureaus, for the purposes of obtaining or providing credit references;

- Any third party to whom we provide introductions or referrals;

- Any party in connection with any Dana business transfer, disposal, merger or acquisition, wherever located, including in jurisdictions which do not have data protection laws that provide the same level of protection as the jurisdiction in which the Services are supplied.

- Third-party service providers under contract with Dana that help us with our business operations, such as transaction processing, fraud prevention, and marketing. We share your Personal Information with these companies only as necessary to provide you with our Service; and

  • - Law enforcement, government officials or other third parties, but only
    • - in connection with a formal request, subpoena, court order, or similar legal procedure; or
    • - When we believe in good faith that disclosure is necessary to comply with the law, prevent physical harm or financial loss, report suspected illegal activity, or to investigate violations of our User Agreement; or
  • - Any other legally permissible purpose.

5: Storing data

- The data that we collect from you may be transferred to, and stored at, a destination outside Bangladesh. It may also be processed by staff operating outside Bangladesh who work for us or for one of our suppliers. These staff members may be engaged in the fulfillment of your requests. By submitting your Personal Data, you agree to this transfer, storing or processing of data. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. We may also disclose your data to anyone we consider necessary in order to provide you with services in connection with an account.

- Where we have given you (or where you have chosen) a password or PIN that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to Our Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

6: Customer Obligations and Rights

You agree to inform us promptly, and in any event, within 30 days, in writing, if there are any changes to Customer Information supplied to us or a member of Dana from time to time, and to respond promptly to any request from us. Where:

- You fail to provide promptly Customer Information that we reasonably requested, or

- You withhold or withdraw any consents that we may need to process, transfer or disclose Customer Information for the Purposes (except for purposes connected with marketing or promoting products and services to you), or

- We have, or a member of Dana has, suspicions regarding Financial Crime or associated risk.

We may:

- Be unable to provide new, or continue to provide all or part of the, Services to you and reserve the right to terminate our relationship with you;

- Take actions necessary for us or a member of Dana to meet the Compliance Obligations; and/or

- Block, transfer or close your account(s) where permitted under local Laws.

In addition, if you fail to supply promptly your Tax Information and accompanying statements, waivers, and consents, as may be requested, then we may make our own judgment with respect to your status, including whether you are reportable to a Tax Authority, and may require us or other persons to withhold amounts as may be legally required by any Tax Authority and paying such amounts to the appropriate Tax Authority. You agree that We shall not be liable for any loss or damage arising from or incidental to our use, collection, processing, and sharing of Customer Information, and any action we have taken in relation to this Section. State laws allow you to restrict the sharing of your Personal Information in certain instances. However, these laws also state that you cannot restrict other types of sharing. Should we wish to use your information for marketing purposes, we will inform you prior to such use. You shall be entitled to prevent such usage by informing us, within 10 days of being informed of the proposed use, that you do not wish to disclose such information. You can also exercise the right at any time by contacting us at hello@dana.money.

7: Support

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you when you next start the App or log onto one of the Services Sites. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App or the Services. Questions, comments, and requests regarding this privacy policy are welcomed and should be addressed to

- Email: hello@dana.money

- Contact No.: +8801886-326223

- Head Office: House # 10/12, Road # 1, Block # B, Niketon, Gulshan 1, Dhaka-1212, Bangladesh.