1. Introduction
At SUSU, we respect your privacy and are committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our platform or use our services.
2. Information We Collect
We collect information that you provide directly to us, as well as data generated automatically during your use of the Service:
- Personal & Contact Information: Name, email address, phone number, and physical address.
- Identity (KYC) Data: Government-issued ID numbers, passport copies, biometric data (if applicable), and selfie photos required for compliance.
- Financial Data: Wallet balances, transaction history, bank account details, and mobile money numbers.
- Technical Data: IP address, device type, browser information, and usage logs.
3. How We Use Your Information
We use the collected information for the following purposes:
- To create and manage your account and digital wallet.
- To facilitate ROSCA group matching, contributions, and payouts.
- To comply with legal and regulatory obligations, including Anti-Money Laundering (AML) and KYC requirements.
- To process payments and prevent fraudulent transactions.
- To send you administrative notifications, SMS OTPs, and email verifications.
- To improve platform security, performance, and user experience.
4. Information Sharing & Disclosure
We do not sell your personal data. We may share your information in the following circumstances:
- With Group Members: Limited information (such as your name and payout order) is shared with members of the specific saving group you join to foster trust.
- Service Providers: We share data with trusted third-party payment processors, SMS gateways, and cloud hosting providers who assist in operating our Service.
- Legal & Regulatory Authorities: We may disclose information if required by law, court order, or governmental regulation, especially concerning financial compliance.
- Credit Bureaus: In the event of persistent default on contributions, we may report your information to credit reference agencies.
5. Data Security
We implement robust technical and organizational security measures to protect your personal data against unauthorized access, loss, or alteration. These include encryption of sensitive data, secure socket layer (SSL) technology, and strict access controls. However, no electronic transmission or storage is 100% secure.
6. Data Retention
We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, and to comply with our legal, accounting, or reporting requirements. Financial transaction records and KYC data are typically retained for a minimum of five (5) years after account closure.
7. Your Privacy Rights
Depending on your jurisdiction, you may have the right to:
- Access the personal data we hold about you.
- Request the correction of inaccurate or incomplete data.
- Request the deletion of your data (subject to legal retention requirements).
- Opt-out of marketing communications.
To exercise these rights, please contact our support team.
8. Cookies and Tracking Technologies
We use cookies and similar tracking technologies to track activity on our platform and hold certain information. You can instruct your browser to refuse all cookies, but this may limit your ability to use some features of our Service.
9. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of any significant changes by posting the new Privacy Policy on this page and updating the "Last Updated" date.
10. Contact Us
If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at support@susu.com.