SK Solutions Fin Android Privacy Policy

1. INFORMATION WE COLLECT

When you register, use the Platform, explore financial products or submit an application, we may collect the following categories of information.

1.1 Personal Identification Information

We may collect:

Full name;

• ID or passport number;
• Date of birth, where required;
• Mobile number;
• Email address;
• Residential address;
• City, province or state; and
• Postal code.

Purpose

This information may be used to:

• create and manage your account;
• identify and communicate with you;
• prepare your application;
• support identity verification;
• provide application-related notifications; and
• enable Standard Bank to assess an application where authorised.

1.2 Employment and Business Information

Because the Platform supports business financing only, we may collect:

• Employment status;
• Employer name;
• Job title;
• Length of employment;
• Business or company name;
• Business registration number;
• Tax number;
• Industry;
• Years in business;
• Business address; and
• Information showing whether you are a business owner or authorised company representative.

Purpose

This information is used to:

• understand your employment or business profile;
• prepare your application information;
• identify financial products relevant to your needs;
• verify business-related information where necessary; and
• support the independent assessment conducted by Standard Bank.

1.3 Financial and Funding Information

We may collect information such as:

• Requested amount;
• Preferred term;
• Purpose of financing;
• Funding description;
• Monthly income;
• Monthly business revenue;
• Monthly expenses;
• Existing financial commitments;
• Existing monthly repayment obligations; and
• Relevant Standard Bank financing product or facility, where selected.

Funding purposes may include, for example:

• Materials Purchase;
• Equipment Purchase;
• Working Capital; and
• Other eligible funding needs.

Purpose

This information may be used to:

• display financial products relevant to your needs;
• prepare and submit your application;
• provide Standard Bank with information necessary for independent assessment; and
• display application status and related information through the Platform.

The amount or term requested by a user does not represent an approved credit amount or final financing condition.

1.4 Supporting Documents

Depending on the selected business-financing product or Standard Bank's requirements, you may be asked to upload:

• Identity documents;
• Proof of address;
• Proof of income;
• Bank statements;
• Business registration documents;
• Tax documents;
• Purchase orders;
• Supplier quotations;
• Invoices; and
• Other supporting documents reasonably required for an application.

Purpose

Supporting documents may be used to:

• verify information provided in an application;
• support application processing;
• enable Standard Bank to conduct independent eligibility, affordability or credit assessments; and
• satisfy applicable legal, compliance or fraud-prevention requirements.

1.5 Application and Status Information

We may process:

• Application number;
• Application submission date;
• Selected financial product;
• Requested amount;
• Application status;
• Document submission status;
• Requests for additional documents; and
• Status updates received from Standard Bank.

Purpose

This information is used to enable the My Applications and application tracking functions of SK Solutions Fin.

1.6 Device and Usage Information

When you use the Platform, we may automatically collect technical information such as:

• Device type;
• Operating system;
• IP address;
• App version;
• Login and security logs;
• Crash or error information; and
• Platform usage information.

Purpose

This information may be used to:

• operate and maintain the Platform;
• detect abnormal or unauthorised activity;
• prevent fraud and security threats;
• diagnose technical issues;
• improve application stability and performance; and
• protect users and Platform systems.

1.7 Permission-Based Information on Android

The Android App asks for access only when a user starts a feature that requires it. The App may process identity-document images captured with the device camera and approximate location used for address completion, application support, fraud prevention and security checks. Notification access is used to deliver application and account updates. A user may deny an optional request, although the related feature may then be unavailable.

1.8 Device, Network and Security Information on Android

To operate the Android App, protect accounts, prevent fraud, diagnose failures and assess device risk, we process defined technical information including:

• App-generated, Android, advertising and Firebase installation identifiers;
• device model, manufacturer, operating-system and build information, App version, screen characteristics, language, locale and time zone;
• storage, memory, battery, network, Wi-Fi, proxy and Internet Protocol information;
• root, emulator, debugging and other device-security or integrity indicators; and
• push-notification token and notification-delivery information.

We use this technical information for App operation, account and application security, fraud prevention, analytics, attribution, notification delivery and technical support. It is shared only with SK Solutions Fin service providers where necessary for those functions and subject to the safeguards described in this Policy.

1.9 Analytics, Attribution and Messaging Providers

The Android App uses the following service providers. We do not sell, rent or exchange personal information. These providers process the defined information only to support the purposes shown below, subject to applicable law and our contractual arrangements.

2. HOW WE USE YOUR INFORMATION

We process personal information only where there is an appropriate and lawful purpose.

Your information may be used to:

• Create and manage your SK Solutions Fin account;
• Provide and maintain Platform functions;
• Display financial product information;
• Receive and process application information;
• Facilitate document submission;
• Transmit authorised application information to Standard Bank;
• Display and update application progress;
• Provide customer and technical support;
• Authenticate users and protect account security;
• Prevent fraud, misuse and unauthorised activity;
• Maintain system and service security;
• Comply with applicable legal and regulatory obligations; and
• Improve Platform functionality and user experience.

Important Notice

All credit assessments, approval decisions, approved amounts, interest rates, repayment terms, fees, contracts, disbursements and repayment arrangements are independently determined and managed by Standard Bank.

SK Solutions Fin does not make credit decisions or directly provide financing.

3. INFORMATION STORAGE AND SECURITY

We implement reasonable technical and organisational safeguards designed to protect personal information against:

• loss;
• unauthorised access;
• unlawful processing;
• alteration;
• disclosure; and
• destruction.

Measures may include:

• Encryption or other appropriate safeguards for data transmission;
• Access controls and authentication mechanisms;
• Restricted employee and service-provider access;
• System monitoring and security logging;
• Security testing and vulnerability management;
• Backup and recovery measures; and
• Internal information-security procedures.

No electronic system can guarantee absolute security. However, we take reasonable measures appropriate to the nature of the information processed and the risks involved.

3.1 Data Retention

We retain personal information only for as long as reasonably necessary for:

• providing Platform services;
• processing or supporting applications;
• maintaining transaction and application records;
• resolving disputes;
• fraud prevention;
• complying with legal obligations; or
• establishing, exercising or defending legal rights.

Where information is no longer required and there is no lawful reason to retain it, we will delete, destroy or de-identify it in accordance with applicable requirements.

3.2 Cross-Border Processing

SK Solutions Fin may use systems, service providers or infrastructure located outside South Africa.

Where personal information is transferred outside South Africa, we will take reasonable steps to ensure that such transfer is conducted in accordance with applicable data protection requirements and appropriate safeguards.

POPIA regulates both the lawful processing of personal information and the transfer of personal information outside South Africa.

4. INFORMATION SHARING AND THIRD-PARTY DISCLOSURE

We do not sell personal information to unrelated third parties.

We may share personal information only where reasonably necessary and permitted by law.

4.1 The Standard Bank of South Africa Limited

When you submit an application and provide the appropriate authorisation, we may share relevant information and supporting documents with Standard Bank.

This may include:

• identification information;
• contact information;
• employment or business information;
• financial information;
• funding requirements; and
• supporting documents.

Standard Bank may independently use this information to conduct its own:

• identity verification;
• eligibility assessment;
• affordability assessment;
• risk assessment;
• credit assessment;
• fraud prevention; and
• regulatory compliance processes.

Once personal information is received and independently processed by Standard Bank, the Bank may also act under its own privacy notice and legal obligations.

4.2 Service Providers

We may use trusted third-party service providers for functions such as:

• cloud hosting;
• data storage;
• cybersecurity;
• analytics;
• technical infrastructure;
• customer support;
• communications; and
• Platform maintenance.

Such providers may process information only to the extent necessary to provide their contracted services and subject to appropriate confidentiality and security requirements.

4.3 Legal and Regulatory Disclosure

We may disclose information where reasonably required:

• By applicable law;
• By a court order;
• By a competent regulator or government authority;
• To investigate suspected fraud or illegal activity;
• To protect the security of the Platform; or
• To protect the lawful rights and interests of users, the Company or other persons.

Except as described in this Privacy Policy or required by law, we will not disclose personal information to unrelated third parties without an appropriate legal basis.

5. YOUR PRIVACY RIGHTS

Where South African data protection law applies, users have rights under the Protection of Personal Information Act 4 of 2013 (POPIA).

POPIA establishes minimum requirements for lawful processing of personal information and provides individuals with rights and remedies concerning their personal information.

Subject to applicable law and any lawful limitations, you may have the right to:

• Ask whether we hold personal information about you;
• Request access to personal information we hold;
• Request correction or updating of inaccurate information;
• Request deletion or destruction of information where legally permitted;
• Object to certain processing of personal information;
• Withdraw consent where processing is based on consent;
• Request information regarding how your personal information is processed;
• Raise a complaint regarding our processing of personal information; and
• Lodge a complaint with the South African Information Regulator where applicable.

5.1 Account Deletion

You may request account deletion through Account Management in the App or by contacting service@sksoltech.com. We will verify the request and delete or de-identify personal information that is no longer required. We may retain information where necessary to comply with law, resolve disputes, prevent fraud, protect legal rights or maintain records relating to a submitted application or a Standard Bank agreement.

Withdrawal of consent does not affect processing that was lawfully carried out before the withdrawal and may affect our ability to provide certain Platform functions where the relevant information is necessary to provide the service.

6. CONTACT US

If you have any questions, privacy requests or complaints relating to your personal information or this Privacy Policy, please contact us:

SK Solutions Fin Operated by INDUSTRIA COPACABANA S.A.

Email: service@sksoltech.com

Customer Service: +52 5624354038

These contact channels may be used for:

• requests to access personal information;
• correction requests;
• deletion requests where applicable;
• withdrawal of consent;
• privacy-related enquiries; and
• privacy or security complaints.

The contact information above is intended for user support, privacy and compliance matters and will not be used solely for unrelated marketing purposes.

Where applicable, users may also lodge a complaint with the Information Regulator of South Africa, which is the authority established under POPIA.

7. CHILDREN’S INFORMATION

SK Solutions Fin is not designed for use by children or persons who do not have the legal capacity required to enter into the relevant financial or application arrangements.

We do not knowingly request financial applications from children.

If we become aware that personal information of a child has been submitted without appropriate lawful authority or consent, we will take reasonable steps to restrict processing and delete the information where required by law.

8. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy where necessary because of:

• Changes in applicable law or regulation;
• Changes in Platform functionality;
• Changes in the categories of information we process;
• Changes in Platform services or technology providers;
• Security requirements; or
• Changes in our business operations.

When material changes are made:

• the revised Privacy Policy will be published in the App or on the official website;
• the effective date will be updated; and
• additional notice or consent will be provided where required by applicable law.

We encourage users to review this Privacy Policy periodically.

Continued use of the Platform after an updated policy becomes effective will be handled in accordance with applicable legal requirements.

9. APPLICABLE LAW AND DISPUTE RESOLUTION

For services provided to users in South Africa, this Privacy Policy is intended to operate in accordance with applicable South African privacy and electronic communications requirements, including:

Protection of Personal Information Act 4 of 2013 (POPIA)

POPIA governs the protection and lawful processing of personal information and regulates matters including information security, data subject rights, automated processing and cross-border transfers.

Electronic Communications and Transactions Act 25 of 2002 (ECTA)

ECTA establishes a legal framework for electronic communications and electronic transactions in South Africa.

The Platform will also comply with other applicable South African legislation and regulatory requirements to the extent relevant to its activities.

If you have a concern arising from this Privacy Policy, you should first contact us using the information provided above so that we may attempt to resolve the matter.

If the issue cannot be resolved, you may exercise any rights available under applicable law, including approaching the Information Regulator of South Africa or another competent court, regulator or authority.

Nothing in this Privacy Policy limits any statutory privacy right that cannot legally be excluded or waived.