Privacy Policy

Effective Date: March 23, 2026

1. Purpose, Scope, and Legal Framework

1.1 DinheiroFácil provides digital consumer credit services in the Republic of Angola and has obtained the necessary authorization and/or licensing from the relevant Angolan financial regulatory authorities, including the National Bank of Angola (BNA), where applicable.

1.2 For the purposes of this Policy, when users download and use the DinheiroFácil mobile application provided via the App Store, or access our services through other official channels, we generally act as the controller of personal data processing.

1.3 In specific circumstances, we may also act as a data processor, processing personal data on behalf of a third party. In such cases, the third party acts as the data controller and has entered into a contract with the user, and we will process the data strictly in accordance with its instructions and within the limits permitted by law.

1.4 If you have any questions regarding this Policy, you may contact us at: business@sengaiservicos.org

1.5 Our processing of personal data complies with the Angolan Personal Data Protection Law (Law No. 22/11 of June 17, 2011), applicable regulations of the Data Protection Authority (APD), and other relevant laws. By using our services, the user confirms that they have read, understood, and agreed to this Policy.

1.6 Our services are not intended for individuals under the age of 18, and we do not knowingly collect personal data from children.

2. Terms and Definitions

2.1 “This Policy”: refers to this document, which explains how we collect, use, share, store, and protect personal data.

2.2 “Channel”: refers to any official means of accessing the services (including APP and website).

2.3 “Child”: refers to any individual under the age of 18.

2.4 “Consent”: refers to the user’s freely given, specific, informed, and explicit authorization.

2.5 “User/Customer”: refers to a natural person located in Angola who uses our services.

2.6 “Personal Data”: refers to any information that can identify or be associated with an individual.

2.7 “Sensitive Personal Data”: includes sensitive information as defined by law, such as race, health, ethnicity, beliefs, biometric data, financial status, etc.

2.8 “Services”: refers to the financial products and functionalities provided by DinheiroFácil.

2.9 “We”: refers to DinheiroFácil.

2.10 “You”: refers to the user or their legally authorized representative.

3. User Consent and Device Permissions

3.1 By installing the application and clicking “Accept”, the user:
a) agrees to this Policy
b) authorizes access to the following device permissions (where applicable)
c) agrees that we process their personal data in accordance with this Policy (including sensitive data where necessary)
d) guarantees that the information provided is true, accurate, and up to date
e) agrees to its use for identity verification, credit assessment, fraud prevention, and compliance with legal and regulatory requirements
f) understands that we may disclose relevant data to regulatory authorities when required by law

3.2 Permissions we may request (based on user authorization):

Location (Approximate Location)

Used to ensure account security, prevent fraudulent activities, and meet applicable regulatory requirements. We do not collect precise location data without authorization.

Camera

Used for identity verification and liveness detection (such as capturing ID documents or selfies). The camera will not be used in the background.

Contacts (Optional)

Only used when the user actively selects contacts to fill in emergency contact information. We do not access or upload the full contact list.

If the user refuses to grant relevant permissions, some functions may not operate properly.

4. Data We Collect

4.1 Types of Data Collected

(1) Identity Information
Includes name, gender, date of birth, nationality, and ID number
Source: Obtained via OCR recognition of documents uploaded by the user
Purpose: Identity verification, KYC, fraud prevention, and compliance requirements

(2) User Profile Information
Includes education, occupation, income, marital status, housing information, etc.
Purpose: Credit assessment, risk control, and service optimization

(3) Banking and Payment Information
Includes bank account information, transaction records, etc.
Purpose: Loan disbursement, repayment processing, and AML compliance

(4) Camera Data
Used for identity verification (such as facial recognition or liveness detection)
Not collected in the background or used for other purposes

(5) Emergency Contacts
Collected only when the user actively provides them
Used for contact support in emergency situations

(6) Device Technical Information
Includes device model, operating system version, IP address, and other necessary technical information
Purpose: Ensuring system security, preventing fraud, and improving service stability
Not used for advertising or cross-app tracking

(7) Location Data
Approximate location information collected with user authorization
Used for account security protection and risk prevention

(8) Usage Logs
Includes login records, verification code (OTP) records, and in-app activity
Purpose: Account security, troubleshooting, and product optimization

(9) Third-Party Data
Obtained from legally authorized credit bureaus, payment service providers, and other partners
Purpose: Information verification, credit assessment, and compliance requirements

4.2 We only collect additional data where lawful and necessary, and will clearly explain the purpose at the time of collection.

4.3 Data sources include:
User-provided data
Device information
Lawful third-party sources

4.4 We do not share personal data unless required by law or with user consent.

4.5 Failure to provide necessary information may result in inability to use part or all of the services.

4.6 Data is protected through encrypted transmission (such as HTTPS).

4.7 We do not sell your personal data, nor do we use it for third-party advertising purposes.

5. Purpose and Legal Basis for Data Processing

We process data only when there is a lawful basis, including:

6. Automated Processing

6.1 We may use automated systems to assist in risk assessment, credit approval, and security monitoring.

6.2 Where applicable, users may request manual review or inquire about relevant decisions through customer service channels.

7. Data Sharing

Where lawful and necessary, we may share data with:

All sharing is based on lawful purposes and subject to appropriate data protection measures.

8. Cross-Border Data Transfer

Your data may be stored or processed outside Angola. We will take reasonable measures to ensure a level of protection equivalent to local legal requirements.

9. Security Measures

We implement industry-standard technical and organizational measures to protect data, including preventing unauthorized access, disclosure, or misuse.

Users are also responsible for safeguarding their account information (such as passwords and verification codes).

In the event of a data security incident, we will take appropriate measures in accordance with the law.

10. Data Retention

We retain data only for the period necessary to fulfill the purposes of this Policy and comply with legal requirements.

Generally, data will be retained for 5 to 10 years, or longer if required by law.

After the retention period, data will be deleted or anonymized.

11. User Rights

Under applicable laws, users have the right to:

Users may submit requests via email, and we will process them after verifying identity.

12. Policy Updates

This Policy may be updated from time to time. Updates will be communicated through the application, website, or other appropriate means.

13. Contact Information

Customer Service Email:
business@sengaiservicos.org

Phone:
+244934507836

Service Hours:
Monday to Friday, 09:00–18:00 (Angola Time)