Privacy Policy

1. Introduction

a) About Us

Lendy is a mobile lending application operated by MONILUV TECH LTD, providing digital loan services to eligible users in Ghana.

This Privacy Policy explains how we collect, use, store, share, and protect your personal data when you use:

• The Lendy mobile application (the "App")
• Our official website: www.moniluvtech.com
• Related services (collectively, the "Services")

We strictly comply with:

• Ghana Data Protection Act, 2012 (Act 843)
• Applicable regulations issued by the Bank of Ghana
• Google Play Financial Services & User Data Policies

Our privacy practices are based on lawfulness, transparency, data minimization, and user control.

b) Purpose of This Policy

This Privacy Policy clearly explains:

• What personal data we collect
• Why and how the data is used
• How your data is protected
• Your rights and choices as a user

We follow Google Play's requirements for clear disclosure, explicit consent, and limited data use.

c) Scope

This Policy applies to personal data collected through:

• The Lendy App
• The website (www.moniluvtech.com)
• Related online services

It does not apply to data collected offline.

d) User Consent

By using our Services, you agree to this Privacy Policy.

• If you do not agree, you may still access non-core features
• Core services requiring identity verification require your explicit consent.
• Consent is obtained through clear in-app notices and opt-in mechanisms, in line with Google Play policies.

2. Data Collection & Permissions

To provide loan services, verify identity, manage risk, and comply with Ghanaian KYC and AML requirements, we collect the following data:

a) SMS Permission

Purpose

• SMS access is used to support loan-related verification, including:Income-related activity verification
• Creditworthiness assessment
• Fraud prevention

What We Access

• The App may access SMS inbox messages on the user’s device to evaluate whether they match predefined financial-related patterns (such as transaction or salary notifications).
• This evaluation is performed locally on-device during active loan application or verification processes.

What We Collect and Upload

• Only SMS messages that match predefined financial rules (e.g. bank transaction alerts, salary notifications, mobile money receipts) are selected for upload.
• For matched messages, only relevant financial information is transmitted.
• All transmitted data is encrypted and sent via HTTPS (TLS 1.3) to https://ldy.lendy2.com.

What Is Not Uploaded

• SMS messages that do not match financial patterns:
  • Are ignored
  • Remain on the device
  • Are not transmitted to our servers
• We do not upload:
  • Full SMS inbox contents
  • Personal or private SMS
  • One-time passwords (OTPs)
  • Non-financial conversations

How It Works

• SMS access occurs only when the user actively initiates a loan-related action (such as application or verification).
• SMS scanning does not run continuously in the background.

User Choice and Control

• Before requesting SMS permission, we present a clear and prominent disclosure explaining:
  • What data may be accessed
  • What data may be uploaded
  • The purpose of such access
• You may decline SMS permission and continue using basic App features.
• You may revoke SMS permission at any time via Android system settings.
• Without SMS permission, income verification and credit assessment may be limited and could affect loan approval.

b) Installed App List

Purpose

Installed app information is used solely to support:

• Credit assessment related to loan eligibility
• Detection of abnormal or potentially fraudulent patterns
• Risk evaluation and fraud prevention

What We Collect

For selected applications only, we collect limited technical information, including:

• Application name
• Whether the app is pre-installed
• Version code
• First install time
• Last update time

We do not collect information about non-relevant applications.

How It Works

• The App checks only a predefined whitelist / blacklist of known financial or high-risk applications.
• Installed app information is checked no more than once per day.
• Non-financial and unrelated apps are ignored and never stored.
• The App does not access app content, usage behavior, or user interactions.

When applicable:

• Parsed app data is transmitted no more than once per day.
• Data is encrypted during transmission via HTTPS (TLS 1.3)
• Data is sent securely to https://ldy.lendy2.com
• Installed app data is retained for no longer than 30 days for risk assessment purposes
• After the retention period, the data is automatically deleted

Important Notes

• Installed app data is not used to infer personal beliefs, political views, religious affiliation, or other sensitive personal characteristics.
• Installed app data is not used for advertising, marketing, or user profiling.
• We do not perform full device app enumeration or continuous background scanning.

c) Emergency Contacts

Purpose

Emergency contact information is used to:

• Verify your identity
• Support loan risk assessment

How It Works

• You manually input two emergency contacts, including:
  • Name
  • Relationship
  • Phone number
• We do not access your contact list or address book

Data Usage

• Emergency contact data is not used for harassment, marketing, or repeated collection calls, Used only for verification and risk control
• Not shared with third parties without legal basis
• Stored securely and deleted according to retention rules

d) Identity Information

We collect the following identity information for verification and eligibility assessment:

• Full name
• National ID number
• Date of birth
• Mobile phone number

This data is used strictly for KYC, AML, and loan-related purposes.

e) Device Identifiers

We collect the following device identifiers for analytics, attribution, and service integrity purposes:

• Google Advertising ID (GAID), used by the AppsFlyer SDK for advertising attribution and performance analytics
• Device identifier generated by the Android system (e.g. Widevine deviceUniqueId), used for security and fraud prevention

This data is used strictly for analytics, attribution, security monitoring, and regulatory compliance purposes, and is not used for credit assessment, loan approval, pricing, or risk evaluation.

Collection of device identifiers is limited to what is necessary for the purposes described above and does not involve continuous or background tracking unrelated to app usage.

Your Options

• You may disable personalized ads at any time via:

Settings → Google → Ads → Opt out of Ads Personalization

• Disabling personalized ads will not affect your ability to apply for or manage loans within the App.

3. Data Usage

We use personal data for the following purposes:

• Identity Verification (KYC / AML compliance)
• Credit Assessment
• Risk Management and Fraud Prevention
• Loan Processing and Management
• Customer Support
• Legal and Regulatory Compliance (including requests from the Bank of Ghana or Data Protection Commission)

4. Data Sharing & Disclosure

a) Data Sharing

We may share limited personal data with:

• Licensed Credit Reference Bureaus in Ghana
• Regulatory or legal authorities, when required by law
• Licensed debt collection partners, in cases of loan default
• Service providers, under strict confidentiality obligations

We do not sell or rent personal data.

b) Secure Transmission

All shared data is encrypted and transmitted via HTTPS (TLS 1.3).

5. Data Security

We implement industry-standard safeguards:

• TLS 1.3 encryption for transmission
• Secure storage with access controls
• Firewalls, intrusion detection systems, and regular audits
• Confidentiality obligations for authorized staff

6. Data Retention & Deletion

a) Retention

• Identity and transaction data: retained during account activity and up to 7 years after closure, as required by law
• Emergency contacts: deleted within 90 days after loan settlement, unless legally required otherwise

b) Deletion

• Requests can be submitted via the App or customer@lendy2.com
• Identity verification required
• Outstanding obligations must be settled
• Requests processed within 15 business days
• Some data may be retained if legally required

7. User Rights

Under the Ghana Data Protection Act, you have the right to:

• Access your personal data
• Correct inaccurate or incomplete data
• Request deletion (subject to legal retention)
• Restrict certain processing
• Withdraw consent for non-essential data use

Requests can be made via customer@lendy2.com.

8. Children's Privacy

Lendy services are strictly for users aged 18 years and above.

If data relating to a minor is identified, it will be promptly deleted.

9. Data Protection Officer (DPO)

Email: dpo@moniluvtech.com

The DPO oversees compliance with data protection laws and handles privacy-related inquiries.

10. Contact Us

• Company: MONILUV TECH LTD
• Customer Support Email: customer@lendy2.com
• WhatsApp: +233256070467
• Website: www.moniluvtech.com
• Working Hours: Monday-Friday, 09:00-18:00 (GMT)

11. Policy Updates

We may update this Privacy Policy due to legal, regulatory, or service changes.

Updates will be published via the App or our website. Where required by law, we will seek your consent to material changes of the updated policy.

Last Updated: January 7, 2026