This
Privacy Policy, together with our Terms of Use, describes the types of
personal information we collect and how we use that information. It also
describes the choices available to you regarding our use of your personal
information and how you can access, update, and restrict our use of your
information. By accessing our website at www.DadaSoko.org or our mobile
application (collectively, the “Website”), you signify that you have read this
Privacy Policy, and you expressly consent to our collection, use, disclosure,
storage and protection of your personal information as described in this
Privacy Policy. Capitalized terms used but not defined in this Privacy
Policy have the meanings defined in our Terms of Use.
Who We Are
GlobalSoko Microfunds (together with its
subsidiaries — collectively, “DadaSoko,” “we,” or “us”) provides an online
platform to connect people through lending. We are a Nevada nonprofit public
benefit corporation with headquarters in Las Vegas, Nevada and Nairobi, Kenya.
Personal Data We Collect (and How We Collect
It)
Basic Personal Information. When you create an account on the Website, we
collect your name, email address, and a means to authenticate your account (for
example, a password). You may also choose to provide additional information,
such as your phone number, your location, a picture, your address, and your
payment account identifying information. We may receive some information
about you from other DadaSoko Users (for example, if they invite you to use the
Program, or in order to deliver a DadaSoko Card purchased for you) and from
third-party payment processing providers like PayPal (for example name, payment
account email address, and in some cases physical address).
Transaction Activity. We record information about deposits to
your account and the Loans you make through the Program, individually (for
example, amount and recipient of a Loan) and in the aggregate (for example,
number of Loans made and distribution by gender, country, and sector). We
also collect information on any donations you make to DadaSoko (whether through
the Website or offline). If you purchase a DadaSoko Card, we collect
information about your purchase (for example, your name, the purchase date, and
the amount) and information you provide about your recipient (for example, name
and email or physical address for delivery). If you redeem a DadaSoko
Card, we record (and may disclose to the purchaser) your Lender profile and the
date you redeem the DadaSoko Card.
Loan Application and Borrowing Activity. If you apply to borrow funds through the
Program, we collect information you provide (for example, photograph, email and
physical address, phone number, description of business and finances, personal
references, desired loan terms, payment account, and certain demographic
information), as well as information from third parties (such as your personal
references, your DadaSoko Trustee, credit reporting agencies, and public
Internet searches). If you are approved to borrow, we record information
on individuals you invite to become Lenders, whether or not your Loan is
successfully funded, repayments you make, updates you provide to Lenders, and
your correspondence with DadaSoko.
Other Use of DadaSoko’s Website and Features. We may collect other information you choose to
provide in order to facilitate your participation in the Program or use of
Website features.
·
- If you make changes
to your DadaSoko account preferences (for example, receiving
marketing information from us, instructions on whether to automatically
lend funds in your account, and whether to donate inactive account
funds), we record that information.
- If you join a lending team, we
collect information on the Loans you attribute to the team and any
comments you post to the team message board.
- We also collect comments you
post to any other Web page hosted by DadaSoko (such as a Loan page, blog,
or volunteer forum), or through DadaSoko’s Lender messaging feature.
- If you invite a friend to use
the Website, we will ask you for your friend’s name and email address.
DadaSoko stores this information for the sole purposes of sending your
friend a one-time email inviting him or her to visit the Website, giving
you the ability to send your friend reminders, and tracking the success
of our referral program. If you choose to import contacts from your email
account address book to invite friends to our Website, we or our service
providers will collect your email, username, and password and we will
only use them for that purpose.
Other Interactions with DadaSoko.
·
- If you contact DadaSoko
customer service, we will collect the information you provide (for
example, your name, email address, physical address, phone number and
comment) in order to respond to you.
- If you submit an application
to DadaSoko (for example, to be an employee, volunteer, or Trustee), we
collect the information you submit (for example, name, phone number,
resume, cover letter, and position of interest) to review your
application and follow up with you.
- If you participate in a survey
or other promotion, we may request certain personal information from you
(for example, name, address, and demographic information).
Authentication Information from Third-Party
Applications. If you
choose to access the Website through a third-party integration, you grant
DadaSoko permission to access and use certain information about you from that
third-party application in accordance with the third-party application’s terms
of use, DadaSoko’s Terms of Use, and this Privacy Policy:
·
- If you sign into the Website
through your Facebook account, you grant DadaSoko permission to access
your public Facebook information (including account email address and
photograph), as well as a list of your Facebook friends who also use
DadaSoko, and whether you opt to show your DadaSoko lending activity to
your friends through Facebook.
- If you sign into the Website
through your Google account, you grant DadaSoko permission to access your
email address and public Google profile information.
- If you sign into the Website
through your Apple ID, you may choose to grant DadaSoko access to your
name and email address in accordance with Apple’s terms of use and
settings.
DadaSoko may from time to time offer similar
third-party integrations with other services.
Technical Data. Regardless of whether you have a DadaSoko
account, we use tools like cookies, web beacons, and other automated systems to
collect data on your behavior when you use the Website. Please see
our Cookie Policy for more detailed information. If you have
enabled cookies in your browser or if you use DadaSoko’s mobile
application, DadaSoko, independently and through third-party tools and programs
(such as Google Analytics), collects certain technical information (for
example, your path to the Website, pages visited, originating IP address,
device type, browser type, browser language, network connection
type, and the date and time of your visit). We use these tools to
analyze data to improve User experiences and prevent fraud. Please note that many
internet browsers offer a Do Not Track (DNT) setting; because there is no
industry or legal standard for DNT signals, DadaSoko does not respond to
them.
If you provide information to us about
individuals other than yourself, you must ensure that they have given their
permission for you to disclose the information to us and for you to allow us to
use it in the ways described in this Privacy Policy.
Accessing and Updating Your Personal
Information
This policy describes the types of data we
collect, as well as the sources from which we obtain it, the purposes for which
we use it, and the categories of third parties with which we share data.
You have the right to access the specific personal data DadaSoko has on
you. You can view this information through your DadaSoko account.
You also have the right to request that we provide some of your personal data
to you (or to another third party), in a machine-readable format. To make
such a request, or if you have additional questions about information DadaSoko
has collected on you, please reach out to us at info@DadaSoko.com
If your personal information changes, you may
update, amend, or remove certain information by signing into your DadaSoko
account and making the change in your account settings, or by contacting
DadaSoko. We will respond to your requests within 30 days.
How DadaSoko Uses Your Personal Information
We will only collect and use your personal data
(i) to carry out the terms of a contract we have entered into with you
(including providing our services pursuant to our Terms of Use), (ii)
where you have given consent, or (iii) where we have a legitimate interest in
conducting our operations, such as:
·
- to facilitate access to your
DadaSoko account.
- to personalize your experience
using the Website, both through user settings and through automated
profiling to better engage with you;
- to communicate with you about
your transactions or other Website activity, and to respond to your comments
or inquiries to DadaSoko customer service.
- to contact you (including via
email and phone) with general information about our initiatives,
marketing campaigns, surveys or other promotional activities.
- to generate leads and conduct
targeted advertising to you and other individuals with similar
characteristics and interests, where legally permissible.
- to analyze and improve our
services, communications, and advertising.
- to monitor compliance with our
policies and standards, and to improve security.
- to deliver an invitation to
use the Website or a DadaSoko Card purchased for you by another User.
- to process applications for
employment or volunteer positions.
- to comply with applicable law
or court orders and to exercise or defend our legal rights or the rights
of others.
Where we need your personal information in order
to provide our services or otherwise process your instructions and you fail to
provide that information, we may not be able to carry out your instructions or
deliver our services pursuant to our Terms of Use. In some cases, you may
not be able to open a DadaSoko account, or we may be required to close your
account.
Disclosure of Your Personal Information
DadaSoko does not sell or rent your personal
information to third parties. We may disclose any of your personal
information in the following circumstances:
·
- Publicly, to the extent
described in the section below (Information Displayed Publicly).
- In order to comply with
applicable law, regulation, legal process, or governmental request, or to
otherwise protect the rights, property, and safety of DadaSoko, Users,
and others.
- With our affiliates and
service providers, agents and representatives in connection with their
provision of services to DadaSoko for business purposes (for example,
account authentication, facilitating Website functionality, processing
transactions, distributing DadaSoko emails, conducting surveys, managing
employment applications, and monitoring Website traffic and security).
All such access shall be under appropriate confidentiality agreements and
limited to use to provide services to DadaSoko to help us further our
mission.
- With third parties providing
integrated Website features that you choose to use (for example,
Facebook and Twitter) to allow you to share information about your Loans
or other Website activity. Please note that we may withhold or
withdraw information related to Loans you have made to the extent necessary
to protect the privacy of borrowers.
- Where legally permissible, we
may share limited personal information, such as your email address or
phone number, with third party platforms like Facebook or Google to
advertise to you and others with similar interests and characteristics
through these platforms. You may opt out of the use of your data for
direct marketing purposes through your account settings at any time.
- As part of DadaSoko’s API,
which is a service DadaSoko provides to allow third parties to develop
applications and features using information from the Website and Program
(“Third Party Applications”). The DadaSoko API may share any
information that you display publicly on the Website, and if you
authorize a Third Party Application to use your non-public information
from the Website (for example, the amount of your available DadaSoko
Credit and outstanding Loans) the API may share the non-public
information with such Third Party Application. Third Party
Application developers have agreed to the DadaSoko API Terms of Service
or a separately negotiated agreement, which contain restrictions on the
use of your information. Despite these agreements, DadaSoko does
not screen or audit Third Party Applications, and we cannot guarantee
that third parties will abide by their agreements. You can revoke
permissions that you have granted to a Third-Party Application through
your DadaSoko account settings.
- If you apply to be a DadaSoko
fellow, we may disclose your application information to our Field
Partners in order to help evaluate your application and placement.
- Aggregated or pseudonymized
data that does not directly identify you may be shared with third parties
for educational, informational or promotional purposes in furtherance of
DadaSoko’s mission.
Information Displayed Publicly
Lender Profile. When you create a DadaSoko account, the default
setting is to have a public profile on the Website. You have the option
of changing your profile setting to “anonymous,” which will hide your profile
from the public. A public profile displays your first name, area of
residence (city, state/province and country), picture, public Lender page URL,
and the date on which you created a DadaSoko account. Other information
you choose to provide (for example, your occupation, the reasons why you lend,
a description of your work, and your website), will be publicly displayed as
well. If you have performed work for DadaSoko (for example as a DadaSoko
Fellow), information related to this work may be automatically included on your
public profile.
Lending Activity. Once you begin to make Loans, your public
profile will automatically display information about the Loans to which you
have contributed, and your name and picture will be displayed on the pages for
those Loans. DadaSoko may also publicly display your Loan activity,
either in a personally identifiable or anonymous manner (depending on your
profile setting at the time of such display), for example, as part of a
visualization of the current or historical activity on the Website.
Invitees. If you invite other people to use DadaSoko, the profiles of those
who have accepted your invitations and created an account on the Website may be
displayed on your public profile as accepted invitees. In turn, if you have
accepted an invitation from another DadaSoko user, your public profile may be
displayed as an accepted invitee on the profile page of the person who invited
you.
Lending Teams. If you join a lending team and you have a
public profile, information about your lending team(s) will be displayed on
your profile. In turn, you will be displayed as a member (and a captain, if
applicable) of the lending team on the team’s page either in a personally
identifiable or anonymous manner (depending on your profile setting) along with
the date you joined the team. The Loans you have attributed to a lending team
(individually and in the aggregate) also will be displayed on the team’s page
as Loans made by that team.
Borrower Profile. If you are approved to raise a Loan as a
DadaSoko borrower, some of the information you provided in your application
will be displayed publicly on your Loan page on the Website (for example, your
first name, business name, picture, location, written narrative, and amount of
your Loan request). The status of your Loan request will also be publicly
displayed (for example, fundraising, fully funded, expired, or ended). If
your Loan is fully funded, your repayment schedule and repayment activity will
be viewable by your Lenders and Trustee (if applicable), including information
on whether you have missed repayments or are in default.
Lender Messaging Feature. If you send a message to another User through
DadaSoko’s Lender messaging feature, your name, location, and a link to your
public profile will be made available to the recipient along with the content
of your message.
Public Forums. DadaSoko hosts various publicly accessible blog
pages and community forums. Any information you provide in these areas may be
viewed by others who access them.
How Long We Keep Your Personal Information
We will only keep your personal data for as long
as reasonably necessary to fulfill the purposes we collected it for, according
to our internal policies. These policies take into account relevant legal and
regulatory retention requirements (e.g. tax, audit, or legal compliance
requirements) and operational considerations. We will delete or permanently
anonymize personal data relating to inactive DadaSoko accounts (as defined in
our Terms of Use) within a reasonable period of time after an account becomes
inactive. Certain information, like personal data of DadaSoko borrowers and
borrower applicants may be kept indefinitely for data integrity and fraud
prevention purposes. If it is not possible to delete or anonymize certain data (for
example, because your personal information has been stored in backup archives),
then we will securely store the data and isolate it from any further processing
until deletion is possible. We reserve the right to retain indefinitely data
that does not directly identify you, for example, aggregated or anonymized
data.
How to Limit Our Use of Your Personal
Information
In certain circumstances, you have the right to
restrict DadaSoko’s use and storage of your personal information. For
instance, you may ask us to erase your personal data when it is no longer
necessary for the purposes for which it was collected, and you may opt out of
data sharing for advertising purposes. If our collection and use of
certain personal information is based on your consent, you have the right to
withdraw your consent. In such case, we will no longer process your
information unless there is another legal ground to do so. You may ask us
to limit our use of your personal data or to erase your personal data by
contacting us at info@DadaSoko.com
·
- You can limit DadaSoko's use
of certain personal data through your account settings.
- As personal data is necessary
for your participation in the Program, we will be unable to erase all of
your personally identifying information without deleting your
DadaSoko account. If you would like DadaSoko to delete all of your
personally identifying information, you should first donate or withdraw
all funds in your account, and then delete your account through Account
Settings (any funds remaining in the account at the time of deletion, as
well as any funds repaid to the account, will be automatically donated to
DadaSoko.) This action will permanently close your account and
automatically delete the personally identifying information associated
with your account.
- If you do not have a DadaSoko
account, or if you have other questions or requests regarding your
personal data, please reach out to us at info@DadaSoko.com
Security of Your Personal Information
DadaSoko takes reasonable steps to maintain
appropriate physical, technical and administrative security to help prevent
loss, misuse and unauthorized access, disclosure or modification of personal
information. While we take these reasonable efforts to safeguard your
personal information, no system or transmission of data over the Internet or
any other public network can be guaranteed to be 100% secure.
Electronic Communications and Emails
You will receive certain notices and information
based on your account status or activity (collectively,
"Communications") from DadaSoko (for example, confirmations of Loans
or donations you have made, statements with respect to the amount of DadaSoko
Credit available in your account, confirmation of email address or password
changes, and inquiries regarding activity in your account). By creating a
DadaSoko account, you agree that all Communications from DadaSoko relating to
your use of the Website and participation in the Program may be made
electronically by email or at the Website (although we reserve the right to
provide you with certain Communications through physical mail). To access the
Communications, you will need to use a computer with Internet Explorer 10.0 or
above, Edge, Firefox 4 or above, Chrome 19 or above, Safari 6 or above, or
Opera 12.1 or above and with hardware capable of running these browsers,
and/or a mobile device capable of running DadaSoko’s mobile application. You
may withdraw your consent to receive Communications electronically by
contacting DadaSoko as described below. However, if you withdraw your consent
to receive electronic Communications (other than for the optional emails
described below), you will not be able to fund any additional Loans through the
Website. The withdrawal of your consent will not affect the legal validity of
electronic Communications provided before you withdraw your consent, or in
connection with any of your Loans that have not been fully repaid by the time
you withdraw consent. It is your responsibility to inform DadaSoko of any
changes to your email address so that you continue to receive all
Communications without interruption. You may request a paper copy of any
electronic notice from DadaSoko by sending an email to info@DadaSoko.com, including your name and
the address to which you would like the paper copy sent.
By default, you will receive the following types
of optional emails from DadaSoko: news and promotions, portfolio and balance
updates, and Loan and borrower updates. Note that if you have a public Lender
profile, other Users will be able to send you messages through the
Website. You have the right to object to receiving these optional emails
from DadaSoko, and you can stop receiving them by clicking an “unsubscribe”
link in an email, or by changing your email preferences in your account
settings.
Third Party Applications and Links to Other
Websites
If you follow any links on the Website that take
you to a third-party site (for example, PayPal, Facebook, or Twitter), this
Privacy Policy no longer applies. The privacy practices of other websites
and other parties are governed by their respective terms of use and privacy
policies.
DadaSoko makes an API available to third-party
developers, who may from time to time create Third Party Applications (as
defined above). Third Party Applications are not created or maintained by
DadaSoko, and their use of your information is governed by their own terms of
service and privacy policies (whether you provide your information to these
third parties directly or through the DadaSoko API). DadaSoko gives no
guarantees or warranties with respect to any Third Party Application and is not
responsible for your use or inability to use any Third Party Application,
including without limitation the content, accuracy, reliability or security of
Third Party Applications or the privacy practices or other policies of third
parties. Please let us know at info@DadaSoko.com if you suspect a
Third Party Application is misusing your information.
Location of Data
DadaSoko collects and stores all data in the
USA. Your personal information may be accessed by DadaSoko, our affiliates,
service providers, agents, and representatives in the USA or elsewhere in the
world. DadaSoko will abide by this Privacy Policy regardless of where
your personal information is processed or stored.
Children Under the Age of 13
The Website is intended to be used by adults. It
is not intended for children, and DadaSoko does not want to collect any
personal information about individuals under the age of 13. DadaSoko recommends
that parents do not post, or permit others to post, any personally identifiable
information with respect to children under the age of 13. If you believe that
we have any information from a child under age 13, please let us know at info@DadaSoko.com
Contact Details
We take privacy seriously and we value yours.
For additional information, or if you have any questions regarding this Privacy
Policy or the privacy practices at DadaSoko, please submit your questions or
comments directly to info@DadaSoko.com via
email. You can also send questions or comments to:
GlobalSoko Foundation
Attn: DadaSoko
3960 Howard Hughes Parkway,
Las Vegas, Nevada
89169-5972
If you believe that any of your rights with
respect to your personal data have been breached, you may also lodge a
complaint with the appropriate supervisory authority or seek a remedy through
the courts.
Changes to this Privacy Policy
DadaSoko may update or modify this Privacy
Policy from time to time. We will note the previous date of any such changes at
the top of this policy. If we make any material changes, we will notify you by
email or by means of a notice on this Website prior to the change becoming
effective. Please be sure to check this page periodically for changes.