Privacy Policy

1. Overview & Scope

At VamoPay ("we", "our", or "us"), we are deeply committed to protecting personal privacy and maintaining strict data confidentiality. This Privacy Policy details how VamoPay collects, processes, protects, and handles personal, financial, and device telematics data when you use the VamoPay device financing platform, retail POS systems (VamoRetail), supply-chain ERP systems (VamoERP), and associated hardware-level risk management services.

This policy applies to individual consumers who purchase smartphones, motorcycles, or commercial equipment through VamoPay-enabled installment financing programs, as well as retail merchants, financial institutions, telecom operators, and original equipment manufacturers (OEMs) participating in our network.

2. Information We Collect

To evaluate credit eligibility, prevent fraudulent purchases, and enforce collateral agreements, we collect the following categories of information:

A. Identification & KYC Data

• Personal Identifiers: Full legal name, residential address, mobile telephone number, and email address.
• Government-Issued ID: Digital copies and identity numbers from national ID cards (such as Bilhete de Identidade in Angola), passports, voter cards, or tax identification numbers.
• Biometric & Verification Data: In-store facial photographic proof of identity and live portrait verification to prevent identity theft.
• Guarantor Information: Contact and identity verification details of loan co-signers or family guarantors where required by underwriting criteria.

B. Hardware & Telematics Telemetry

• Device Identification: International Mobile Equipment Identity (IMEI 1 & IMEI 2), serial numbers, MAC addresses, chipset models, and factory build identifiers.
• Operating System & Security State: OS version, firmware security patch levels, kernel status, tamper detection flags, and SIM card identifiers (IMSI / ICCID).
• Vehicle & Motorcycle Telematics: Real-time GPS location coordinates, ignition status, battery voltage, and geofence boundary crossings for financed two-wheelers and commercial vehicles.

C. Financial & Installment Contract Data

• Down payment transaction records, installment payment schedules, repayment history, overdue notices, and loan settlement status.

3. How We Use Information

We process collected data exclusively for the following lawful business purposes:

• Underwriting & Credit Scoring: Assessing consumer affordability using our mature credit scoring models to approve installment financing.
• Contract Administration: Generating payment reminders, receipts, and maintaining up-to-date account ledgers across retail partner stores.
• Fraud Prevention & Anti-Theft: Detecting SIM-card swaps, unauthorized firmware flashing, factory reset attempts, or suspicious geolocation anomalies.
• Regulatory Compliance: Complying with Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and local consumer finance reporting mandates.

4. Device Lock & Collateral Security Protocols

In accordance with transparent lending standards modeled after global leaders such as PayJoy:

• Grace Period & Pre-Due Reminders: Friendly lock-screen notifications and SMS reminders are delivered prior to payment due dates.
• Delinquency Lock Functionality: If an installment remains unpaid past the stipulated grace period, the device transitions into a restricted state. In this state, regular applications are temporarily locked, and the screen displays payment instructions and customer support links.
• Emergency Calling Preserved: Even in a locked state, access to emergency telephone numbers (e.g., Police, Ambulance, Fire) is strictly preserved at all times.
• Automated Instant Unlock: Upon successful payment confirmation, the VamoPay server transmits an encrypted unlock command, instantly restoring full device functionality without manual retail intervention.

5. Sharing & Disclosure of Information

VamoPay never sells, rents, or commercializes personal data to third-party advertisers. Data is shared strictly on a need-to-know basis with:

• Lending Partners & MFIs: Licensed microfinance institutions and banks funding the underlying installment portfolios.
• Authorized Retail Partners: Certified retail stores where the customer originated the installment purchase or services payments.
• Telecommunications Carriers: Network partners enforcing SIM subsidy compliance where applicable.
• Legal & Regulatory Authorities: Competent judicial or law enforcement bodies when mandated by court orders or binding statutes.

6. Data Security & Retention

We employ military-grade security architectures to safeguard sensitive personal and telematics data:

• Encryption: AES-256 encryption at rest for all database records and TLS 1.3 encryption in transit for all network API communications.
• Access Controls: Multi-factor authentication (MFA), strict role-based access control (RBAC), and immutable audit logging.
• Retention Policy: Customer information is retained for the active duration of the credit contract plus statutory retention periods required by financial tax laws, after which records are securely purged or anonymized.

7. Your Rights & Choices

Subject to applicable local laws, customers maintain the right to:

• Request a copy of personal information recorded in their financing profile.
• Request correction of inaccurate or outdated contact information.
• Request deletion of data following full settlement of all outstanding loan obligations and expiration of regulatory retention mandates.

8. Contact Us & Data Protection Officer

For privacy inquiries, data subject requests, or questions regarding our security protocols, please reach out directly: