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Nestly Privacy Policy

Introduction

We, at Value Addition Microfinance Limited (“Nestly” or “We”) understand Privacy and its value. Therefore, it is all the more important for us to make YOU (“You” or “Customer” or “User”), the User of the website www.syntrixtech.org (the “Website”) and its associated mobile applications, Nestly (“Application”) (collectively, the “Platform”) understand the reason behind collection of your information and its usage and the manner in which we collect, use, store and share information about you (“Privacy Policy”). This Privacy Policy has been prepared in compliance with:

  • Data Protection and Privacy Act of Uganda 2019;
  • Data Protection and Privacy Regulations,2021
  • Other applicable acts, regulations and rules which require the publishing of a privacy policy for handling of or dealing in personal information including sensitive personal data or information and all applicable laws, regulations, guidelines provided by applicable regulatory authorities including but not limited to the Uganda Microfinance Regulatory Authority.

This Privacy Policy is incorporated into and at all times is subject to and is to be read in conjunction with the Terms of Use of the Platform.

Collection of Information

The collection of information under this Privacy Policy are conducted for the following categories of services:

a. A. Information we collect about you

In order to facilitate the housing and business services , Nestly will be required to access, collect Personal Information .In such cases, Nestly will share the information securely and ensure that all personal information recipients comply with confidentiality, fidelity and secrecy obligations and sign covenants in this regard. Nestly may make information available to third parties that are financial and non-financial companies, government agencies, courts, legal investigators, and other non-affiliated third parties as requested by you or your authorized representative, or otherwise when required or permitted by law.

  • User Personal Information: The data points we collect from You for different services include, inter alia, your full name, email id, NIN, GST Network user id & password, address, mobile number, postal code.
  • Social Account Information: Nestly may provide you with the option to register using social accounts (Google or Apple ID) to access the app and shall collect only such registered email id and user public profile information like name, email, ASID depending on the platform used by you to log-into the Application during registration/ sign in process in the Platform.

How we use this information: We may collect and store email id, name and address associated with that account for the purpose of verification and to pre-populate relevant fields in the course of Platform interface. However, we shall not collect / store account passwords.

  • SMS Information: Nestly collects stores and monitors SMS information from your device. However, we do not store or monitor your Personal SMS information.

How we use this information: We use this data to provide you with updates or confirmation of any actions taken in our Platform during the term of Services.

  • Device Information and Installed Apps data: We additionally collect certain device information provided herein for our different services. Information which the Application collects, and its usage, depends on how you manage your privacy controls on your device.
  • Property Listings and Booking Information

a. When a broker, property manager, landlord, or other authorized user ("Listing Provider") creates or submits a property listing on Nestly, we may collect and process information relating to that property and the listing. This may include, but is not limited to:

  • Property name, title, description and type;
  • Property location, address, landmarks and other location-related information;
  • Rental price, deposit requirements, availability and applicable terms;
  • Number and type of rooms, amenities and property features;
  • Photographs, videos, floor plans and other media uploaded to the Platform;
  • Information relating to the landlord, property owner, broker or Listing Provider;
  • Property documents or information submitted for verification;
  • Listing performance, views, enquiries, saves, shares and other interactions;
  • Reviews, ratings, complaints and feedback relating to the property or Listing Provider; and
  • Any other information voluntarily provided in connection with a property listing.By submitting a listing, the Listing Provider represents that they have the necessary authority or permission to provide the property information and content to Nestly and to make the property available through the Platform.

b.Nestly may use listing information to:

  • Create, display, maintain and manage property listings;
  • Enable users to search for, compare, save, enquire about and book properties;
  • Verify the authenticity and accuracy of property and Listing Provider information;
  • Detect and prevent duplicate, fraudulent, misleading or unauthorized listings;
  • Improve search results, recommendations and the overall Nestly experience;
  • Generate analytics and insights concerning property and marketplace performance;
  • Promote properties and Nestly services through the Platform and, where permitted, through third-party marketing channels, including social media and digital advertising;
  • Communicate with Listing Providers and users regarding listings, enquiries and bookings;
  • Investigate complaints, disputes, fraud, abuse or violations of Nestly's policies; and
  • Comply with applicable legal, regulatory and security requirements. Nestly may format, resize, crop, optimize, organize or otherwise modify listing content for technical, presentation, accessibility or promotional purposes without changing the substantive meaning of the information.

c.Listing Visibility

Certain information submitted as part of a listing may be made visible to other users or the public, depending on the nature of the information and the user's access to the Platform. This may include property photographs, general location, property description, amenities, rental price, availability, reviews, ratings and Listing Provider information.

Nestly will not intentionally make private account credentials, identification documents, payment credentials or other information designated as confidential publicly available, except where disclosure is required or permitted by law or is necessary to provide a requested service.

d.Booking and Enquiry Information

When a user submits an enquiry, booking request, reservation request or other expression of interest in a property, Nestly may collect and process information necessary to facilitate and manage that interaction.

This may include:

  • The user's name and contact information;
  • Property and Listing Provider information;
  • Requested dates, duration and number of occupants;
  • Booking or enquiry status;
  • Messages and communications relating to the property or booking;
  • Transaction or payment-related information where applicable;
  • Cancellation, modification or dispute information;
  • Reviews, ratings and feedback following an interaction; and
  • Technical, device and usage information associated with the booking or enquiry. Nestly may use this information to facilitate enquiries and bookings, communicate with users and Listing Providers, provide confirmations and notifications, prevent fraud and abuse, resolve disputes, improve the Platform and comply with applicable legal obligations.

e.Information Shared During a Booking

To facilitate an enquiry or booking, Nestly may make certain information available to the relevant parties. The information shared may depend on the stage of the enquiry or booking and the role of the user.

For example, a Listing Provider may receive information reasonably necessary to respond to an enquiry or manage a booking, while a user may receive information about the Listing Provider and property necessary to evaluate and proceed with the booking.

Nestly will seek to limit the information disclosed to what is reasonably necessary for the relevant interaction, subject to applicable law and the operation of the Platform.

f.Booking Records and History

Nestly may retain records relating to enquiries, bookings, cancellations, communications, reviews, disputes and other interactions for as long as reasonably necessary to operate the Platform, maintain accurate records, prevent fraud and abuse, resolve disputes, enforce agreements, comply with legal or regulatory obligations, and protect the rights and safety of Nestly and its users.

g.Property Verification

Nestly may collect and process information and documents relating to a property for purposes of verifying the property, its location, ownership or authorization to list, where such verification is required.

Where verification is conducted through third-party sources or service providers, Nestly may share or receive information necessary to complete the verification process, subject to applicable law and the terms governing those services.

h.Duplicate and Related Listings

Where Nestly identifies listings that appear to represent the same or substantially similar property, Nestly may compare listing information, property identifiers, location information, photographs, descriptions and other relevant data to identify potential duplicate or related listings.

Nestly may consolidate, link, restrict, suspend or otherwise manage duplicate or conflicting listings where reasonably necessary to maintain the accuracy, integrity and reliability of the Platform.

i.Listing Removal

Nestly may remove, restrict, suspend or modify a listing where it reasonably believes that the listing:

  • Contains inaccurate, misleading or fraudulent information;
  • Has been submitted without appropriate authorization;
  • Violates Nestly's Terms or Listing Policies;
  • Creates a safety, legal or regulatory risk;
  • Is a duplicate or materially conflicts with another listing;
  • Contains prohibited or unlawful content; or
  • Otherwise threatens the integrity, security or proper operation of the Platform.Where appropriate, Nestly may retain information relating to a removed or suspended listing for fraud prevention, dispute resolution, legal compliance, auditing and other legitimate purposes.
  • Device Information: When you install the Application, we store the information we collect with unique identifiers tied to the device you are using. We collect information from the device when you download and install the Application and explicitly seek permissions from you to get the required information from the device. Additionally, we also collect your Log information (via the domain server through which the User accesses the App Search queries, IP address, crashes, date etc for the purpose of improvising the Application functionality. In addition to the above, we also track and collect the data related to the performance of the Application and other diagnostic data for identifying and resolving any technical glitches that may be identified from such data and also for improving the overall functionality of the Application.

How we use the information: We collect information about your device to provide automatic updates and additional security so that your account is not used in other people’s devices. In addition, the information provides us valuable feedback on your identity as a device holder as well as your device behaviour, thereby allowing us to improve our products interaction, quality of services and provide an enhanced customized user experience to you. We further collect other identifiable information such as your transactions history on the Platform when you set up a free account with us.

  • Installed Application Data: We collect and transmit a list of specific installed applications’ metadata information which includes the application name, package name, installed time, updated time, version name and version code of each installed application on your device. This data may be collected even when the app is closed or not in use. How we use this information: We use this information for your onboarding and Know Your Customer (KYC) purpose with your explicit consent.

5. Location, Camera, Microphone Access: We will collect your device location and request camera and microphone access for facilitating services

How we use this information: We shall collect your device location information for verifying your address, for the KYC and onboarding process for the Services. We may request camera access to scan and capture the required KYC documents as per the instructions of our Partners in accordance with applicable laws. We shall transfer such information to our Partners and shall not store any such data. We require microphone permissions to enable a two-way communication between our authorized agents and you for the purpose of performing and completing your Video KYC for the different Services. Your audio shall be recorded for regulatory purpose.

a. B. Information you give us about you

  • In due course of using our Services, you are required to submit data to enable our Services. We use this data to create your profile and provide you with the best available services. Mentioned below is some of the data we collect from you:
  • i. Data provided by you by filling in forms in the Application or on the Website. ii. Data provided by corresponding with us (for example, by e-mail or chat). iii. Data and information, you provide when you register to use the Website, download or register on our App, subscribe to any of our Services (such as applying for a loan), search for a Service, and when you report a problem with our App, our Services, or any of our Sites.
  • Data including your name, address, gender, date of birth, e-mail address, phone number, username, password and other registration information.

vii. Contact details (i.e. the phone number) of the third party individuals (including your relatives and friends) that are voluntarily added by you at the time of loan application.

  • This data helps us create your profiles, complete mandatory KYC as per the requirements of our Partners who offer you the Services unlock and approve loans and provide you with customized support in case of issues. Please note that we do not store any data provided by you except for the basic information such as name, address, your contact details etc.
  • Wherever possible, we indicate the mandatory and the optional fields. You always have the option to not provide any information by choosing not to use a particular service or feature on the Platform. While you can browse some sections of our Platform without being a registered member as mentioned above, certain activities require registration and for you to provide the above details.
  • We under no circumstances and at no point take any biometric data from you for any of our services or operations. In case, if any of our representatives ask for the same from you, we request you to kindly refrain from doing the same and address this concern to our Grievance Officer (the details of the same have been provided below).

6. User-Generated Content, Reporting and Blocking

Nestly allows users to create,upload, share, and interact with user-generated content, including property listings, images, reviews, messages, comments, and other information. Users are responsible for ensuring that all content they submit is lawful, accurate, respectful, and does not contain abusive, threatening, harassing, fraudulent, defamatory, discriminatory, obscene, or otherwise inappropriate material. Nestly provides users with tools to report objectionable content and to block other users. When a user reports content, the reported content may be immediately hidden from that user's feed while Nestly reviews the report and takes appropriate action. Users may also block other users, including through the messaging feature, to prevent unwanted communication or interaction. Nestly reserves the right to review, restrict, remove, or disable access to content or accounts that violate these Terms or applicable laws and may take further action where necessary to protect users and the integrity of the platform. Users must not use Nestly to harass, threaten, abuse, impersonate, defraud, or otherwise harm another person.

D. Storage of Personal Information

  • We shall only store basic personal information such as your name, your address, your contact information which are required to be stored for carrying out our services.
  • We ensure that every data or information that we collect from you is stored in servers located in Uganda and the same is compliance with all the statutory/regulatory obligations.
  • For other personal information collected as part of our outsourcing services being provided to our Partners, we shall collect such information upon the instructions of the Partners and thereafter transfer the same to the Partners upon the completion of the preliminary onboarding.

E. Collection of Certain Non-Personal Information

  • We automatically track certain information about you based upon your behaviour on our Platform. We use this information to do internal research on our users’ demographics, interests, and behaviour to better understand, protect and serve our users and improve our services. This information is compiled and analyzed on an aggregated basis.
  • Cookies: Cookies are small data files that a Website stores on your computer. We will use cookies on our Website similar to other websites / apps and online marketplace websites / apps. Use of this information helps us identify you in order to make our Website more user friendly. Most browsers will permit you to decline cookies but if you choose to do this, it might affect service on some parts of Our Website.
  • If you choose to make a purchase through the Platform, we collect information about your buying behaviour. We retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law. If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the Website, we collect such information into a file specific to you.

Purpose of Collection

We shall use the information collected from you for facilitating the DIFFERENT Services for the following purposes as detailed below. We understand the importance of your information and ensure that it is used for the following intended purposes only.

The intended purpose of collecting information provided by you is to:

  • establish identity and verify the same;
  • to facilitate your KYC as per instructions;
  • troubleshoot problems, monitor, improve and administer our Platform;
  • provide our housing service
  • design and offer customized products and services offered by our third-party partners;
  • analyze how the Platform is used, diagnose service or technical problems and maintain security;
  • send communications notifications, information regarding the products or services requested by You or process queries and applications that You have made on the Platform;
  • measure consumer interest and satisfaction in our products and services and manage Our relationship with You;
  • marketing and promotional purposes including sending you promotional SMS, Email and WhatsApp and inform you about online and offline offers, products, services, and updates;
  • conduct data analysis in order to improve the Services / Products provided to the User;
  • use the User information in order to comply with country laws and regulations;
  • use the User information in other ways permitted by law to enable you to take financial services from our partners.
  • resolve disputes and detect and protect us against suspicious or illegal activity, fraud and other criminal activity;
  • Customize your experience and enforce our terms and conditions.
  • the contact details (i.e. the phone number) of the third party individuals (including your relatives and friends) that are voluntarily added by you at the time of loan application may be used for the purpose of establishing contact in case we are unable to contact you, including at the time of collection of installments.

We will use and retain only such basic personal information such as your name, contact information, address details and such other information which are necessary for the provision of Services and for such periods as necessary to provide You the Services on the Platform, to comply with our legal obligations, to resolve disputes, and enforce our agreements.

Disclosure to Third Parties

We will share your information only with our third parties including our regulated financial partners, vendors etc for facilitation of Services on the Platform.

We will share the information only in such manner as described below:

  • We share Your information with our third-party partners in order to conduct data analysis in order to serve You better and provide Services our Platform;
  • We may disclose your information, in order to enforce or apply our terms of use or assign such information in the course of corporate divestitures, mergers, or to protect the rights, property, or safety of us, our users, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
  • We will disclose the data / information provided by a user with other technology partners to track how the user interacts with the Platform on our behalf.
  • We and our affiliates may share your information with another business entity should we (or our assets) merge with, or be acquired by that business entity, or re-organization, amalgamation, restructuring of business for continuity of business. Should such a transaction occur than any business entity (or the new combined entity) receiving any such information from us shall be bound by this Policy with respect to your information.
  • We will disclose the information to our third-party technology or third-party data source providers;
  • We will share your information under a confidentiality agreement with the third parties and restrict use of the said information by third parties only for the purposes detailed herein. We warrant that there will be no unauthorized disclosure of your information shared with third parties.
  • We shall disclose your KYC journey or any data with respect to the same to the relevant regulatory authorities as a part of our statutory audit process.

We may share your personal information with the governmental authorities; quasi-governmental authorities, judicial authorities and quasi-judicial authorities if we are acting under any duty, request or order as part of our legal obligations and in accordance to the applicable laws. By accepting this Privacy Policy, you hereby provide your consent to disclose your personal information for such regulatory disclosure.

Any disclosure to third parties is subject to the following:

  • If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request, we shall not seek your explicit consent however we shall reasonably endeavour to notify the same to you accordingly as the case may be as stated under subclause 3;
  • We shall take your express consent in the event we share your personal data with third parties;
  • We shall share your information with third party only on a need basis and only for the purpose stated hereunder, as per the applicable laws.
  • We shall additionally seek express consent through a separate consent for at appropriate stages of data collection, if so required under applicable laws.
  • Usage of your information by such third parties is subject to their privacy policies. We share limited information with them, strictly to the extent required. We recommend you to have a look at the privacy policies of such third parties.

Data Retention and Deletion

We at Nestly promise to protect your personal data from unauthorized access, misuse, and disclosure using the right security measures based on the type of data and how we are processing the same. We retain information about you to provide a seamless experience, to contact you in case of support required and about your account, to detect, mitigate, prevent, and investigate fraudulent or illegal activities during the course of the Services. We retain your data for as long as necessary to provide you with our services. We may also retain and use your basic personal information inter alia as name, contact number, transactional details and address details as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements which shall always be in accordance with applicable laws. Subject to this section, we may delete your data upon reasonable written request for the same at any stage. However, you may not be able to use our services after deletion.

Changes in this Privacy Policy

We reserve the right to change, modify, add, or remove portions of this Privacy Policy at any time for any reason. In case, any changes are made in the Privacy Policy, we shall update the same on the Platform. Once posted, those changes are effective immediately, unless stated otherwise. We encourage you to periodically review this page for the latest information on our privacy practices.

Continued access or use of the Services constitute your acceptance of the changes and the amended Privacy Policy.

Security Precautions

The Platform intends to protect your information and to maintain its accuracy as confirmed by you. We implement reasonable physical, administrative and technical safeguards to help us protect your information from unauthorized access, use and disclosure. For example, we encrypt all information when we transmit over the internet. We also require that our registered third-party service providers protect such information from unauthorized access, use and disclosure.

Our Platform has stringent security measures in place to protect the loss, misuse and alteration of information under control. We endeavour to safeguard and ensure the security of the information provided by you. We use Secure Sockets Layers (SSL) based encryption, for the transmission of the information, which is currently the required level of encryption in Uganda as per applicable law.

We blend security at multiple steps within our products with the state-of-the-art technology to ensure our systems maintain strong security measures and the overall data and privacy security design allow us to defend our systems ranging from low hanging issue up to sophisticated attacks. In addition, the Website and App have been certified for the following security certifications:

a. ISO 9001: being the international standard that details requirements for a quality management system (QMS). Organizations use the standard to demonstrate the ability to consistently provide products and services that meet customer and regulatory requirements with the requisite security protections.

We aim to protect from unauthorized access, alteration, disclosure or destruction of information we hold, including:

  • We use encryption to keep your data private while in transit;
  • We offer security feature like an OTP verification to help you protect your account;
  • We review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems;
  • We restrict access to personal information to our employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations;
  • Compliance & Cooperation with Regulations and applicable laws;
  • We regularly review this Privacy Policy and make sure that we process your information in ways that comply with it.
  • Data transfers;

Data protection laws vary among countries, with some providing more protection than others.

We also comply with certain legal frameworks relating to the transfer of data as mentioned and required under the Data Protection and Privacy Act, 2019, rules, regulations and the amendments made thereunder.

When we receive formal written complaints, we respond by contacting the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of your data that we cannot resolve with you directly.

Your Rights

Modifying or rectifying your information: In the event that any Personal Information provided by you is inaccurate, incomplete or outdated then you shall have the right to provide us with the accurate, complete and up to date data and have us rectify such data at our end immediately. We urge you to ensure that you always provide us with accurate and correct information/data to ensure your use of Our Services is uninterrupted. In case of modification of Personal Information, Users will be required to furnish supporting documents relating to change in Personal Information for the purpose of verification by the Company.

Your Privacy Controls: You have certain choices regarding the information we collect and how it is used:

  • Your device may have controls that determine what information we collect. For example, you can modify permissions on your Android/iOS device or Browser to remove any permissions that may have been given. However, Platform does not provide a guarantee of Services if any such controls are exercised.
  • Delete the App from your device
  • You can also request to remove content from our servers in accordance with Clause C.

Report an issue: You have a right to report a security incident to the GRO (detailed mentioned herein below). You are entitled to prevent unauthorized such usage of your information by our personnel/agents 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 : nestlyhousing21@gmail.com

Grievance Redressal

You may make a request for deleting any information from the Platform at any stage upon making a request to us in the following manner:

a. Grievance Officer

The name and contact details of the Grievance Officer are provided below for your reference:

Name: ……………………………………………….

Parliament Avenue, Plot 5, Bhatia Chambers, suite 24A,

Email: nestlyhousing21@gmail.com

Time: Mon - Sat (08:00 - 05:00)

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