Privacy Policy

Dynamic Microfinance Institution S. C. (hereinafter referred to as “DMFI”) is a financial service provider licensed by the National Bank of Ethiopia to undertake microfinance businesses throughout Ethiopia.

Financial consumers’ privacy is important to DMFI. Thus, it developed this Privacy Statement with the objective of ensuring the confidentiality and security of personal data of financial consumers in line with the requirements of Art. 5.4.1. Of the Financial Consumer Protection Directive No. FCP/01/2020.

What Personnel Data MFI Dose Collect

DMFI may collect or process (which may include collecting, organizing, structuring, using or disclosing) personal data of financial consumers as and when they use its financial products and services. Personal data collected about customers will be limited to the minimum required by laws, regulations and directives governing the Know Your Customer (KYC) and the Customer Due Diligence (CDD) requirements including basic bio data (full names, gender, date of birth, education, occupation, income and nationality), residential and business addresses, contact information (P. O. Box, email address, phone number, fax number, etc.), picture, specimen signature and subscriber IDs;

HOW DOES DMFI USE PERSONAL DATA?

A DMFI use discloses financial consumer’s personal data in a lawful, transparent and fair manner for legitimate purposes agreed to by the financial consumer or otherwise permitted by law.

DMFI uses Financial Consumers personal data to conduct the following activities:

As necessary for the performance of contracts: When DMFI enters into a contract directly with financial consumers, it process their personal data in order to prepare and enter into the contract, as well as to perform and manage the contract (i.e., to provide financial products and services, manage its relationship and contract, compliance with other contractual obligations and related administration). If DMFI does not process financial consumers’ personal data for these purposes, it may not be able to provide them with any of the financial products and services;

As necessary to comply with its legal obligations: DMFI processes financial consumers personal data to comply with the legal obligations to which it is subject for the purposes of compliance with relevant laws, regulations and directives and for responses to requests from, and other communications with, competent public, governmental, judicial or regulatory authorities. This includes, detecting, investigating, preventing and stopping fraudulent, harmful, unauthorized or illegal, Anti-Money Laundering (AML) and Counter Financing of Terrorist (CFT) activities that impact vital interests and public safety;

As necessary for its legitimate interests. DMFI processes financial consumers personal data based on legitimate interest to: (i) enter and perform contracts with financial consumers who use its financial products and services; (ii) develop, test and improve financial products and services; (iii) ensure authentication, integrity, security, and safety of accounts, activity and products including detect, and prevent malicious conduct and violations of DMFI’s terms and policies, prevent, investigate or address security threats; (iv) send marketing communications, advertising and promotions in relation to its financial products and services; and (v) meet its corporate and social responsibility commitments, protect its property rights and that of its financial customers’ rights, resolve disputes and enforce agreements.

Provide its financial products and services: DMFI provide its financial products and services to existing and potential financial consumers. In the process, DMFI collects and uses financial consumers’ personal data, including contact information, to address and deliver invitations, account statements, legal notices and court summons. DMFI also uses financial consumers’ personal data to manage relationships with financial consumers, compliance with contractual obligations and related administration.

Product research and development. DMFI uses financial consumers’ data in the process of developing, testing and improving its financial products and services.

Communicate with financial consumers. DMFI uses financial consumers’ personal data (including contact information) to communicate with them about its financial products and services, including product updates and changes to its policies and terms. DMFI also uses financial consumers’ personal data to respond to their complaints or requests;

Legal reasons. To comply with applicable laws or respond to valid legal processes, including from law enforcement or regulatory government agencies, to investigate or participate in litigation, or other adversarial legal proceedings and to enforce or investigate suspicious cases of Anti-Money Laundry (AML) and/or Counter Financing of Terrorist (CFT) activities;

DMFI will attempt to keep financial consumers’ files complete, up-to-date, and accurate. DMFI will tell financial consumers how and where to access their personal data and account information (except when it is prohibited by law) and how to notify DMFI about errors which it will promptly correct.

DMFI will continuously assess itself to ensure that financial consumers’ privacy is respected in.

HOW DOES DMFI SHARE PERSONAL DATA?

Rule of thumb. DMFI will not reveal financial consumers’ personal data to any one unless it has previously informed and secured the financial consumers’ written consent or are required by law.

Credit reference. DMFI will share personal data of financial consumers with reputable reference sources such as the Credit Reference Bureau (CRB) unit under the National Bank of Ethiopia and other financial service providers for the purposes of credit reporting, verification and risk management;

Registration of security rights. DMFI will share personal data of financial consumers with authorized public or private agencies including the Ministry of Transport, the Ministry of Trade and Industry, the Movable Collateral Registry Unit of the NBE, land registration offices, Banks, Insurers, MFIs, etc. for the purposes of registering its security rights over tangible (movable & immovable properties) and intangible assets it accepted as collaterals;

Marketing, promotions and third-party advertising. DMFI and/or its third party marketing partners may use financial consumers’ personal data to market, advertise and promote its financial products and services. DMFI may also use cookies or similar technologies, including from third party advertising partners, to show to financial consumers ads about DMFI’s financial products and services, or worthy causes from third parties;

Whenever DMFI engage third-parties to provide support services, it will require them to conform to its privacy statement and to allow DMFI to audit them for compliance.

PRIVACY RIGHTS AND CHOICES

At financial consumers’ request, and as required by applicable law, DMFI will:

Right of access. Furnish financial consumers of what personal data it has about them that is under its control including account statements free of charge at least once a month and any time when the account is closed;

Right of erasure. In certain circumstances, financial consumers have the right to the erasure of personal data that DMFI holds about them (for example, if it is no longer necessary for the purposes for which it was originally collected);

Right to object to processing. In certain circumstances, financial consumers have the right to request that DMFI stops processing their personal data and/or stops sending them marketing communications;

Right to rectification. Financial consumers have the right to require DMFI to correct any inaccurate or incomplete personal data;

Right to restrict processing. Financial consumers have the right to request that DMFI restricts processing of their personal data in certain circumstances (for example, if they believe that the personal data DMFI holds about them is not accurate or lawfully held).

To exercise their rights or if they have any other questions about DMFI’s use of personal data, financial consumers can send a request at the contact details specified in the How to Contact Us section of this Privacy Statement. Please note that DMFI may request financial consumers to provide additional information in order to confirm their identity and ensure that they are entitled to access the relevant personal data.

When legally permitted, DMFI may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort or jeopardize the privacy of others;

Financial consumers also have the right to lodge complaints to regulatory authorities such as the National Bank of Ethiopia or to judiciary.

CHILDREN

HOW TO CONTACT US

If financial consumers have any privacy related questions or comments related to this Privacy Statement please send an email to privacy@dynamicmfi.com.

Financial consumers can also contact DMFI by writing to the following address:

Dynamic MFI

P. O. Box 20943/1000

Addis Ababa, Ethiopia

Or, by Fax: +251 115 15 70 90

RETENTION

DMFI retains personal data for as long as required to engage in the uses described in this Privacy Statement, unless a longer retention period is required by applicable law.

The criteria used to determine our retention period include the following:

The length of time we have an ongoing relationship with you and provide DMFI products and services to you (for example for as long as you keep using our products);

Whether account owners modify or delete information through their accounts;

Whether we have a legal obligation to keep the data (for example , certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or

Whether retention is advisable in light of our legal position (such as in regard to the enforcement of our agreements, the resolution of disputes, and applicable statutes of limitations, litigation, or regulatory investigation).

PERSONAL DATA STORAGE

DMFI collects and stores financial consumers (customers’) personal data within the geographic boundary of Ethiopia. Besides, it uses Virtual Private Network (VPN), which encrypts data, line to securely transfer data from branch offices to the server and the vice versa.

DMFI also protect financial consumers’ personal data at rest with state of the art physical and virtual security technologies. Hourly back up of DMFI’s server data is taken to ensure data recovery and business continuity in the event of an incident. Wherever the financial consumers’ personal data might be processed, DMFI will take appropriate steps to protect it in accordance with this Privacy Statement under applicable laws.

PERSONAL DATA PROTECTION

DMFI keeps financial consumers’ personal data confidential and secure. Only authorized employees, who are trained in the proper handling and processing of financial consumers’ personal data, will have access to financial consumers’ personal data. Employees who violate DMFI’s Privacy Statement will be subject to disciplinary processes.