Privacy Policy

1.0 Introduction

Welcome to CenuKa, a mobile application that provides online loan services to eligible users in Uganda. This Privacy Policy explains how we collect, use, store, and protect your personal information when you use our mobile application and services (collectively referred to as the "Services").

By accessing or using our Services, you agree to the collection, use, and disclosure of your personal information as described in this Privacy Policy. This policy is consistent with applicable Ugandan laws and regulations, including the Data Protection and Privacy Act (DPPA) of Uganda.

2.0 Definitions

2.1 "CenuKa" refers to the mobile loan application operated by the company providing this service in Uganda.

2.2 "Personal Information" means any information that can be used to identify an individual, either alone or in combination with other information.

2.3 "Sensitive Personal Information" means personal information that requires special protection, such as financial information, biometric data, or health information.

2.4 "User" refers to any individual who accesses or uses the CenuKa application or Services.

2.5 "Device" means the smartphone or other electronic device used to access the CenuKa application.

3.0 Information We Collect

3.1 Information You Provide to Us

We collect personal information that you voluntarily provide to us by filling out forms when you register for an account, apply for a loan, or use our Services, primarily for the following purposes:

  • Identity verification information: Full name, date of birth, gender, photos of National Identity Card, real-time facial recognition information (for account creation, identity verification, and fraud prevention)
  • Contact and residence information: Email address, phone number, alternative phone number, residential information (for account management and communication)
  • Personal and background information: Education, marital status (for user profile creation and risk credit assessment)
  • Financial and employment information: Occupation, income, employment information (for risk credit assessment and loan limit determination)
  • Emergency contact information: Information for two emergency contacts (for loan approval and payment reminders)

3.2 Information We Collect Automatically

When you use our application, we may automatically collect certain information, primarily for the following purposes:

Device and usage information: When using this application, we may collect information related to your device and usage, including device type, device model, operating system version, device identifier (such as identifiers generated by Android devices), IP address, and necessary operational logs (such as feature usage and page access logs).

This information is used exclusively for system operation and maintenance, risk identification, fraud prevention, service optimization, and security, and will not be used for unauthorized advertising or commercial marketing.

Location information: We will only obtain approximate information about your location (approximate positioning) based on your IP address for account security verification, risk assessment, abnormal behavior identification, and fraud prevention. We will not obtain precise information about your location, nor will we conduct continuous location tracking.

4.0 Permissions and Device Access

4.1 When using the application, with your explicit consent, we may request access to the following device permissions:

  • SMS:

    We only access SMS messages that contain specific financial information relevant to your creditworthiness and repayment ability. We do not collect, store, or view the full content of your personal SMS messages. Our system filters out non-financial SMS messages before any data is transmitted to our servers, ensuring your personal communications remain private. This information is used exclusively to assess your financial situation and determine your loan eligibility, for risk management and anti-fraud evaluation. You can refuse SMS access, but this may affect our assessment of your credit status and the overall application experience. You can enable or disable this permission at any time through your device settings.

  • Contact Information and Emergency Contacts:

    We will not obtain, read, or upload your phone's contact list. When applying for a loan, you will only need to voluntarily provide two emergency contacts. You can choose to manually fill in contact information or select it from your local contact list. We guarantee that we will only collect information for these two emergency contacts that you voluntarily provide, and will not obtain complete data from your contact list. This information will be used only for risk assessment, identity verification, and emergency contact purposes, and will not be used for marketing, promotion, or any purpose unrelated to the service, nor will it be sold or illegally shared with third parties.

  • Location Information:

    With your permission, we may collect and process your approximate location information. When you use this App normally, we collect this information to verify if your location matches the location information provided in your loan application, detect suspicious behavior, and prevent fraudulent applications. When you close this App or stop using it, collection of location data will automatically stop. You can also temporarily turn off or disable approximate location permissions in your device settings at any time.

  • Installed Applications:

    We collect information about applications installed on your device, but only transmit and store data related to specific financial applications. This includes whether the application is an integrated system application, application name, version code, first installation date, and last update date.

4.2 All of the above personal data is encrypted via HTTPS and transmitted to our secure servers located at https://ck.cenuka.com for storage. By default, users must explicitly grant permissions to access corresponding data. Permissions can be revoked at any time. To revoke permissions, users can adjust their device settings or contact us through the support channels provided in this document. Permission management procedures may vary depending on the device and software.

4.3 We ensure transparency by disclosing the data we collect, the reasons for collection, and how it is used. All data collection strictly complies with applicable Ugandan laws and regulations. Explicit user consent must be obtained before collecting any information. We regularly review and update our privacy practices to remain compliant and protect your data.

5.0 Cookies and Tracking Technologies

5.1 We use cookies and similar tracking technologies to enhance your experience, analyze usage patterns, and improve our Services. Cookies are small data files stored on your device.

5.2 The types of cookies we use include:

  • Essential cookies: Required for the operation of our application
  • Performance cookies: Help us analyze how users interact with our Services
  • Functionality cookies: Enable enhanced features and personalization

5.3 You can manage your cookie preferences through your device or browser settings. However, disabling certain cookies may affect the functionality of our Services.

6.0 How We Use Your Information

6.1 We use your personal information for the following purposes:

  • Create and manage your account
  • Establish user account profiles and perform risk credit assessment to provide faster loan limits
  • Process your loan applications and disburse funds
  • Assess your creditworthiness and manage credit risk
  • Verify your identity and prevent fraud
  • Communicate with you about your account and our Services
  • Improve our products and services based on your feedback
  • Send important notifications, updates, and promotional materials
  • Comply with legal and regulatory requirements

7.0 Sharing and Disclosure of Information

7.1 We may share your personal information with the following parties for specific purposes:

  • Our affiliates and subsidiaries: For internal business operations, service improvement, and compliance purposes
  • Financial payment institutions: Only bank account details necessary for loan disbursement and payment processing
  • Service providers: Limited information necessary to perform their services (e.g., identity verification, fraud prevention, customer support)
  • Government authorities: Only as required by law or to comply with regulatory obligations, including anti-money laundering and counter-terrorism financing requirements
  • Third parties with your consent: Only information you explicitly authorize us to share, for the purposes you specify

7.2 We do not sell, rent, or trade your personal information to third parties for marketing purposes.

7.3 We may share aggregated or anonymized information that cannot be used to identify you with third parties for research, analysis, or statistical purposes.

8.0 International Data Transfers

8.1 Your personal information will primarily be stored and processed within Uganda. In certain limited cases where data must be transferred outside Uganda for specific operational purposes, we take appropriate measures to ensure that these transfers comply with the Data Protection and Privacy Act (DPPA) of Uganda and that your personal information receives an adequate level of protection.

8.2 When transferring data internationally, we will use appropriate safeguards, including:

  • Standard data protection clauses approved by Ugandan data protection authorities
  • Binding corporate rules for international data transfers
  • Encryption and other security measures to protect data during transmission

8.3 You have the right to request information about any international data transfers that affect your personal information.

9.0 Data Retention

9.1 We retain your personal information for as long as necessary to provide our Services, fulfill our contractual obligations, and comply with legal and regulatory requirements.

9.2 After your account is closed or you stop using our Services, we may retain certain information for a reasonable period to:

  • Resolve any pending disputes
  • Comply with legal and tax obligations
  • Prevent fraud and maintain security

9.3 When your personal information is no longer needed, we will securely delete or anonymize it in accordance with our data retention policies.

10.0 Data Security

10.1 We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, use, disclosure, or destruction.

10.2 Our security measures include:

  • Data encryption (both in transit and at rest)
  • Secure access controls and authentication mechanisms
  • Regular security audits and vulnerability assessments
  • Employee training on data protection and privacy
  • Incident response procedures to handle security breaches

10.3 Despite our best efforts, no security system is completely impenetrable. We cannot guarantee the absolute security of your personal information, but we are committed to continuously improving our security measures.

11.0 Your Rights and Choices

11.1 As a user, you have the following rights regarding your personal information:

  • Right to access: You may request access to the personal information we hold about you
  • Right to correction: You may request correction of inaccurate or incomplete information
  • Right to deletion: You may request deletion of your personal information under certain circumstances
  • Right to restrict processing: You may request that we restrict processing of your information
  • Right to data portability: You may request a copy of your information in a structured format
  • Right to object: You may object to processing of your information for certain purposes
  • Right to withdraw consent: You may withdraw your consent to processing at any time

11.2 To exercise these rights, contact our Data Protection Officer using the contact information provided below.

11.3 You may also manage your marketing communication preferences by following the unsubscribe instructions in our messages or updating your account settings.

12.0 Children's Privacy

12.1 Our Services are not intended for use by individuals under 18 years of age. We do not knowingly collect personal information from children under 18 years of age.

12.2 If we become aware that we have collected personal information from a child under 18 years of age, we will take measures to delete that information as soon as possible.

13.0 Changes to This Privacy Policy

13.1 We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements.

13.2 When we make significant changes, we will notify you by posting the updated policy in our application and, if necessary, through additional communication channels.

13.3 Continued use of our Services after the changes take effect constitutes your acceptance of the updated Privacy Policy.

14.0 Third-Party Links

14.1 Our application may contain links to third-party websites or services. We are not responsible for the privacy practices or content of these third-party websites.

14.2 We encourage you to review the privacy policies of any third-party websites you visit.

15.0 How to Contact Us

15.1 If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, contact our Data Protection Officer:

CenuKa
Email: support@cenuka.com

15.2 You may also file a complaint with the relevant data protection authority in Uganda if you believe your rights have been violated.

16.0 Acceptance of This Policy

By accessing or using the CenuKa application and Services, you acknowledge that you have read, understood, and agreed to the terms of this Privacy Policy.

Last updated: February 2, 2026