Data Privacy & Protection Policy

Effective 1st October 2023

We take your privacy seriously. What follows outlines the kinds of personal information we might collect when you access this site, how that personal information might be used and shared, among other data practices. This privacy policy covers the personal information of users of our site and any other personal information that we might receive about individuals, whether offline or online.

By using or accessing our site, you agree to the data practices described in this privacy policy, and you are consenting to our processing of your personal information as set forth in this privacy policy now and as amended by us.

See the Controlling Your Privacy section below for information on your choices regarding your personal information and information on correcting or deleting your personal information and to exercise other rights as an individual.

CHANGES TO THIS POLICY

We may change this privacy policy from time to time. If we make any material changes to our privacy policy, we will either notify you by means of a notice on our site or via email. Where required by law we will request your approval. We recommend that you review our privacy policy frequently for updates. Your continued use of our site after any change in this privacy policy will be treated as your acceptance.

INFORMATION WE COLLECT AND SOURCES OF INFORMATION

Categories of personal information

In the last 12 months, we have collected the following categories of personal information:

• Identifiers such as name, email address, mailing address, phone number, IP address (internet protocol address) and cookie identifiers
• Professional or employment related data when employers register their employees on our system
• Internet or other similar network activity such as browsing history, information on your interaction with our site, browser type and referring site
• Location data

Categories of sources

We collect personal information from the following categories of sources:

1. Information you provide

Personal information that you provide:

• when you interact with our site and provide your personal information (e.g., when you provide your information on our Request Demo data form),
• when we communicate via email or otherwise, or
• when your employer enters your data into their account on our system.
2. Information automatically collected

Personal information that we automatically collect through cookies and similar technologies. Through these technologies we collect information such as IP address (internet protocol address), browser type, referring site and the date and time of each visitor to our site. We also allow certain third parties to use cookies on our site as well. See Cookies and Similar Technologies.

USE OF PERSONAL INFORMATION

We may use personal information:

• To provide you with products and services
• To respond to your inquiries
• To send administrative information to you such as information about our site and changes to our terms and policies
• To send you marketing communications, which you have the right to opt out of
• To recognize you when you return to the site
• To show you relevant information that may interest you
• To use in other ways as disclosed to you when you provide your information
• To use in other ways as approved by you
• For our business purposes, such as data analysis, audits, developing new products, enhancing our website, improving our services, identifying usage trends and determining the effectiveness of our promotional campaigns
• For other purposes such as: (a) legal requirements; (b) legal process such as subpoenas; (c) responding to requests from public and government authorities; (d) enforcing our terms; (e) protecting our business; (f) protecting the rights of others; and (g) pursuing available remedies or limiting our liability.

We may combine your personal information with other information. We will treat combined information as personal information.

SHARING PERSONAL INFORMATION

We may share your personal information with:

• Our corporate affiliates
• Our service providers who help us run our business (e.g. data centers)
• A company that buys or invests in our business or assets
• For other purposes such as: (a) legal requirements; (b) legal process such as subpoenas; (c) responding to requests from public and government authorities; (d) enforcing our terms; (e) protecting our business; (f) protecting the rights of others; and (g) pursuing available remedies or limiting our liability
• any other party as long as we inform you at the time you provide the information
• any other party with your consent

In the preceding 12 months, we have not sold our users’ personal information.

THIRD PARTY CONTENT AND SITES

This privacy policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties. For example, our site may link to other sites operated by third parties or a third party may have a widget on our site which directs to their site. The inclusion of a link or a widget on our site does not imply endorsement of the linked site by us. We may also utilize framing techniques that may make it appear that you are still on the site when you are actually on a third- party website. This framed content is marked “ad” or “advertisement” or “sponsored” or similar designation.

Advertising partners and other third parties may use cookies, scripts and/or web beacons to track visitors to our site in order to display advertisements and other useful information when they visit other sites. Such tracking is done directly by the third parties through their own servers and is subject to their own privacy policies.

We are not responsible for these third parties’ data practices. We recommend that you visit such third parties’ privacy policies.

COOKIES AND SIMILAR TECHNOLOGIES

We use cookies and similar technologies on our site. Cookies are small text files which are downloaded to your browser or device when you visit a website. Most web pages contain elements from multiple web domains so when you visit our site, your browser or device may receive cookies from several sources. This includes third parties that provide services on our behalf, such as site analytics service providers (e.g., Google Analytics). In relation to the use of cookies by third parties, we do not have access or control over these cookies.

Third parties may use cookies or similar technologies on our site’s visitors for site analytics provided to us and also to serve interest-based advertisements to such visitors when they visit other websites and mobile applications (e.g., Google Analytics). The collection of information by third parties is governed by their privacy policies.

For additional information on disabling cookies, see Controlling Your Privacy.

We do not respond to browser Do Not Track (DNT) signals at this time.

CONTROLLING YOUR PRIVACY

Disabling cookies

Note that you can change your browser settings to disable cookies if you have privacy concerns. Disabling cookies for all sites is not recommended as it may interfere with your use of some sites. The best option is to disable or enable cookies on a per-site basis. Consult your browser documentation for instructions on how to block cookies and other tracking mechanisms. You have to manage cookies from each browser and each device. Note that when you delete cookies, you are also deleting any opt-out cookies you previously set. You need to re-set any previously selected opt outs.

Promotional emails

We may send promotional emails to our business users (e.g., people who work for our clients or suppliers). If you ever decide you no longer want to receive these types of emails, you may unsubscribe through the email. We may still send you emails relating to the administration of our business and our working relationship.

Access and deletion requests

You may contact us as indicated under the “Contact Information” section below and request that we provide you with a copy of your personal information or that we delete your personal information that we maintain on our systems. We will respond to your request within a reasonable timeframe.

Your rights

• Right of access: If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data along with certain other details. If you require additional copies of the data, we may need to charge a reasonable fee.
• Right to rectification: If your personal data is inaccurate or incomplete, you are entitled to ask that we correct or complete it.
• Right to erasure: You may ask us to delete or remove your personal data as long as there is no outstanding loan balance owed by you to us. However, deleting or removing your personal data will prevent you from accessing loans in the future.
• Right to restrict processing: You may ask us to restrict the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it.
• Right to data portability: You have the right to obtain your personal data from us. You may reuse it elsewhere.
• Right to object: You may ask us at any time to stop processing your personal data. However, if we are relying on a legitimate interest to process your personal data and we demonstrate compelling legitimate grounds for the processing we may continue.
• Rights in relation to automated decision-making and profiling: You have the right to be free from decisions based solely on automated processing of your personal data, including profiling, that produce a significant legal effect on you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us or you provide your explicit consent.
• Right to withdraw consent: If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect any processing of your data before we received notice that you wished to unsubscribe.
• Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your personal data, you can report it to the National Cyber Security Authority.

You may exercise your rights by contacting us as indicated under “Contact Information” section below.

INTERNATIONAL DATA TRANSFERS

Your personal information may be transferred to us in countries other than the country in which you are resident. These countries may have data protection laws that are different from the laws of your country and may not provide the same level of protection as your country.

When transferring data outside of your jurisdiction, we will protect your personal information by (a) processing it in a territory that provides an adequate level of protection based on its data protection laws; or (b) implementing appropriate safeguards to protect your personal information, such as relying on standard contractual clauses.

DATA RETENTION

We endeavour to retain personal information only as long as is necessary for the use cases described in this privacy policy.

SECURITY

We use reasonable efforts to apply procedures and practices that are reasonably designed to protect from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal information transmitted, stored or otherwise processed by us. Please contact us if you believe that your personal information has been subject to a data breach on our systems.

MINORS

We do not collect information from anyone who is below the legal age for employment (16 years of age) and we ask that you not access our site if you are a minor. Please contact us if you believe that we have collected information about your child.

SENSITIVE INFORMATION

We do not collect sensitive information and we ask that you not send us such information. Sensitive information is defined by applicable law and can include the following: social security number, driver’s license number, credit card number, racial and ethnic origin, political opinions, religious beliefs, criminal background, trade union membership, genetic data, biometric data, and health data.

CONTACT INFORMATION

You may contact our Data Protection Officer for any inquiries at the address or email below:

Huza HR Ltd / Huza Financial Services Ltd

1 KG 6 Ave

Rugando

Kigali, Rwanda

Email: privacy@huzahr.com