Jemi Cash Privacy Policy

(October 2025)

This Privacy Policy (hereinafter referred to as "this Policy") applies to all users who access or use Jemi Cash related services (hereinafter referred to as "this Service"). Jemi Cash is a company that is legally registered and continues to exist under the laws of Ghana.

Please read and understand this policy carefully before continuing to use this service. This policy explains how Jemi Cash collects, stores, uses, and protects information you directly provide during your use of this service, or information indirectly provided by legally authorized third parties. Jemi Cash retains your personal information only to the extent permitted by law and for the period necessary to achieve the purposes for which the information was collected.

Jemi Cash will process the information you disclose to us strictly in accordance with the purposes and methods stated in this policy. We will only access and collect your personal information if you voluntarily provide the information or expressly consent to our access to such information. Furthermore, we will only collect relevant personal information when it is necessary for transactions between you and Jemi Cash.

We may revise this policy from time to time and publish an updated version on our official website. The revisions will take effect from the date of publication. If required by law, we will notify you appropriately before the revisions take effect. Your continued access to or use of this service constitutes your agreement to be bound by the then-effective Privacy Policy.

1. Scope of Personal Information Collection

To process your transaction requests and fulfill relevant legal obligations, we will collect personal information necessary for the functionality of Jemi Cash services when you use them, in accordance with the principles of "legality, legitimacy, and necessity." Unless you give your separate consent or otherwise stipulated by law, this information will not be used for any other purpose. The categories of information we collect include, but are not limited to:

● Identity and contact information : such as your name, ID number, facial recognition image, background information, permanent address, contact information (such as mobile phone number, email address), and information of relevant referrs or guarantors.

● Device and log information : including your IP address, operating system type, browser type, and telecommunications usage data.

● Financial and credit information : including financial data, credit reports and related credit information.

● Installed Apps List : To complete the risk assessment, Jemi Cash collects a list of apps installed on your device when the app launches. This information will be securely transmitted to the server https://srv.Jemicash.com . You can choose to "agree" or "decline" this collection upon first launch; whichever you choose, it will not affect your normal access to or use of Jemi Cash's core services.

● SMS log information includes sender's number, sender's name, SMS content, and the time of sending or receiving.

● Third-party source information : Other information and data that you generate on third-party platforms and authorize us to obtain (collectively, "Personal Data").

1.1 Sources of Personal Information Collection

Jemi Cash will collect and obtain your personal data from you and one or more of the following sources through legal means, including but not limited to:

● Your personal data that you voluntarily submitted to us;

● Data generated based on your Jemi Cash account/fund usage and management behavior;

● Legally obtainable information from various public channels or legally registered agencies;

● Information provided in accordance with the law by government agencies, regulatory bodies, and/or law enforcement agencies;

● Information provided by mobile network operators/telecom companies in accordance with the law;

● Information from other third parties or legitimate sources;

● Information that is automatically provided or collected during your use of or access to our products or services (including through your mobile device), as well as information collected through cookies and related technologies in some of our products.

We will only conduct the aforementioned data collection activities if you agree to disclose your personal data and there are no other legal or contractual restrictions.

Jemi Cash reserves the right to request additional supporting documentation from you to verify the authenticity and accuracy of the information you provide. By submitting any information to us, our authorized agents, or designated platforms, you expressly guarantee that such information is accurate and not misleading.

1.2 Authorization and Use of Personal Information Collection

To provide you with comprehensive financial services, Jemi Cash needs to access necessary system permissions and collect relevant information with your explicit consent. We promise that all data collection and processing activities will strictly comply with the principles of "legality, legitimacy, and necessity" and relevant laws and regulations.

1.2.1 SMS Permission

-Purpose of Use: To automatically fill in SMS verification codes to complete the identity verification process and send you notifications closely related to account security and service performance (including but not limited to repayment reminders, transaction confirmations, and security alerts).

-Information Processing: We only read SMS content directly related to the above purposes (mainly verification codes and system notifications) and will not collect, store, or use it for any other unrelated private communications. All data transmission is encrypted and transmitted to our designated server (https://srv.Jemicash.com) via secure HTTPS.

-Anti-Fraud: To prevent risks such as telecommunications fraud and identity theft, we will obtain and verify transaction verification and identity verification information in SMS messages. This is fully encrypted and used solely for anti-fraud risk control; it will never be disclosed or misused. Your trust is our primary concern. To ensure user account and transaction security and prevent malicious fraud, this application requires permission to read SMS messages. This permission is solely for the following anti-fraud risk control operations: Verifying user identity-related verification code information to prevent risks such as unauthorized account logins and fraudulent transactions; Identifying notification SMS messages related to abnormal transactions to provide timely warnings of fraud risks; Investigating SMS content matching fraudulent characteristics to reduce the probability of users encountering telecommunications fraud.

This application promises that SMS data is stored and transmitted with end-to-end encryption, and is used only for anti-fraud risk control scenarios. It will not collect irrelevant content or disclose any user SMS information to any third party.

1.2.2 Location permissions (rough location)

● Purpose : Based on your location, we will provide you with information on nearby partner merchants' offers and personalized financial service recommendations tailored to your region.

● Information Processing : Your location information is anonymized and aggregated immediately after collection. We will not continuously or in the background track your personal whereabouts. This permission request strictly adheres to the "minimum principle" necessary for the service.

1.2.3 Camera Permissions

● Purpose of use : To scan and identify your ID documents, bank cards and other documents when you conduct identity verification, account opening or bank card binding.

● Information Processing : Your real-time consent will be obtained again before each use of the camera. We use Optical Character Recognition (OCR) technology to automatically extract the required structured information and promise to destroy the original image immediately after recognition and not save it.

1.2.4 Equipment Information

● Purpose of use : To implement necessary risk controls, prevent fraudulent activities, and ensure system compatibility between the application and your device to optimize the service experience.

● Information scope : The collected device information is limited to basic attributes such as device model, unique device identifier, and operating system version.

● Information processing : This type of information will be de-identified immediately after collection and placed under strict internal access control mechanisms to prevent unauthorized access.

1.2.5 Application List Information

● Purpose of use : By analyzing the types and activity levels of applications installed on your device, we aim to conduct risk assessments and user profiling to provide you with more accurate recommendations for financial products and services.

● Information Processing : We only perform macro-level statistical analysis on the application list and never read, store, or process any personal data or private content within any specific application. All relevant information is encrypted before transmission.

1.2.6 Advertising Identifiers

● Purpose of use : To utilize the advertising identifiers (such as IDFA and AAID) provided by the device to measure advertising effectiveness, control the frequency of ad display, and improve the relevance of financial product recommendations.

● Your Control : We fully respect your right to choose. You can reset your advertising identifier or completely turn off interest-based personalized advertising recommendations at any time in your device's system settings, and your settings will take effect immediately.

2. Use of personal information

We collect and process your personal information with the core purpose of creating a secure, efficient, and personalized service environment for you, ensuring that you can fully enjoy the various products and services offered by Jemi Cash. During your use of our services, we will use and process your personal data for the following explicitly listed purposes (hereinafter referred to as "Permitted Uses"), to the extent authorized by you or otherwise required by law, and will disclose it to Jemi Cash's affiliates, subsidiaries, and trusted partners as necessary:

● Identity verification : Used to verify your identity and fulfill the legal "Know Your Customer" (KYC) obligation.

● Service Acceptance : Evaluate, verify and process your application for any Jemi Cash product or service.

● Customer Communication : We handle your complaints and inquiries, and communicate with you through methods including but not limited to sending service updates and business reminders to resolve disputes in a timely manner.

● Account Management : Used for the daily management and maintenance of your Jemi Cash account and related financial facilities.

● Credit assessment : Conducting credit investigations and assessments to review your credit and financial status; assisting other financial institutions in conducting credit checks with your authorization.

● Needs Analysis : Analyze and assess your specific financial needs.

● Marketing and Promotion : Subject to compliance with relevant laws and regulations, this is used for marketing and product promotion to you.

● Credit history : Provides a reference for establishing and continuously updating your credit history.

● Security and Compliance : Used for detecting, investigating and preventing crime, fraud or other illegal activities; utilizing and disclosing relevant information to cooperate with investigations, bring lawsuits and comply with international sanctions.

● Legal and regulatory obligations : To respond to the requirements of civil or criminal legal proceedings, and to comply with all applicable laws, regulations and regulatory requirements.

● Debt recovery : Used to collect overdue payments and enforce your obligations to Jemi Cash.

● Data analytics : Compiling, researching, analyzing information, and generating statistical reports to gain a deeper understanding of our customer base, thereby continuously improving our products, services, and development strategies.

● Personalized recommendations : Based on analysis, we provide you with information on products and services that we or third parties believe may be of interest to you.

● Information verification : We ensure the accuracy of the information we record by comparing it internally and cross-validating it with third-party data.

● Experience optimization : Leverage relevant resources to customize and optimize your user experience, and improve our products, services, internal operations, and business processes.

● Business Decisions : Provide a basis for supporting the company's business operations, financial and risk monitoring, strategic planning and decision-making, and for use in internal and external audit and compliance reviews.

● Assignment of rights and obligations : In the event of our business restructuring or merger, we will assign or transfer the rights and obligations we enjoy and assume under the agreements we have entered into with you.

● Cross-border transfer : After fulfilling legal procedures such as data export security assessment, your personal data will be transferred to domestic or foreign jurisdictions for processing and storage in order to complete transactions, fulfill contracts, provide products/services, and conduct legal proceedings.

● Risk and Credit Limit Assessment : By analyzing information about the applications installed on your device, we assess your user profile and risk level, and determine your credit limit accordingly.

● Other legitimate uses : for any other purpose required or permitted by law, regulation, court order and/or government guideline.

Special Note Regarding Cookies and Other Tracking Technologies : 
Jemi Cash may use technologies such as cookies, pixel tags, and web beacons. These technologies help us analyze user behavior, understand how users access and use different parts of our products and services, and measure and optimize the effectiveness of advertising and search. You can choose to be notified when cookies are received, or disable these tracking tools altogether, by adjusting your browser or mobile device settings. Please refer to the help documentation for your browser or device for specific instructions. Please note that if you choose to disable cookies, certain functions of some of our products or services may not work properly.

3. Sharing and Disclosure of Personal Information

Jemi Cash understands the importance of personal information security and is committed to protecting your privacy. We will only share or disclose your personal information to the extent necessary, for the "permitted purposes" clearly stated in Section 2 of this policy, and in strict compliance with all applicable laws, regulations, and regulatory guidelines. You hereby expressly acknowledge and agree that, in order to provide you with continuous, effective, and complete financial products and services, we may provide, disclose, or transfer your personal information to the following recipients located in or outside Ghana:

● Within the group : Jemi Cash’s holding companies, subsidiaries, affiliates and associates.

● Service partners include, but are not limited to, our professional advisors, contractors, third-party service providers, debt collection agencies, and other agents or entities that have entered into agreements with Jemi Cash to assist us in fulfilling certain functions and services.

● Credit and insurance institutions : national and local credit bureaus, credit reporting agencies, credit reference agencies, rating agencies, insurance companies and/or insurance brokers.

● Financial service providers : Other financial service providers related to the Jemi Cash products and services you use.

● Successor : Any actual or potential participant, assignee or assignee of our rights and/or obligations under any transaction between Jemi Cash and you.

● Guarantor and guarantor : Any individual or entity that provides a guarantee or security for the Jemi Cash products and/or services you use.

● Government and regulatory agencies : any competent authority or regulatory body (including the regulatory entity performing its functions), and any party required to disclose information to it under any law, regulation, or government, administrative, or court requirement.

● Strategic partners : Strategic or business partners with whom we establish specific product and service partnerships.

● Rights Protection Parties : Any person or entity that must be involved in the enforcement or protection of any rights we have under the agreement between you and Jemi Cash.

● Other parties authorized by you : Any other third party that you have expressly authorized and/or agreed to in advance.

4. Updating and correcting personal information

4.1 You are responsible for ensuring that all personal information you provide to Jemi Cash remains accurate, complete, and up-to-date throughout your use of our services. You should notify us promptly of any changes to your personal information.

4.2 You have the right to access the personal information held by Jemi Cash about you and to request corrections and updates to any inaccurate, incomplete, misleading, or outdated information. To exercise this right, please submit a written request to us via official correspondence or the designated email address (see the Contact Us section).

4.3 To ensure information security and the rigor of the processing procedures, Jemi Cash reserves the right to request you to provide identity documents and other necessary information to verify your identity, the authenticity of your request, and other information related to the requested correction.

4.4 Upon receiving your correction request and completing the necessary verification, Jemi Cash will correct or update the information within a reasonable timeframe in accordance with laws, regulations, and internal policies.

5. Protection of Minors' Privacy

5.1 Our products and services are intended solely for use by adults who are 18 years of age or older, or who have full legal capacity under the laws of their respective jurisdictions. Minors may not use our products and services in any form.

5.2 Jemi Cash does not knowingly collect personal information from minors. If you, as a parent or guardian, discover that your child or a minor under your guardianship has provided us with personal information without your consent, please contact us immediately using the contact information published in this policy.

5.3 Once it is verified that the personal information of a minor was collected without the consent of the guardian, we will take immediate measures to delete such information in accordance with relevant laws and your request.

6. Information Security Assurance

6.1 Jemi Cash is committed to strictly complying with applicable laws and regulations and establishing a comprehensive information security system based on industry standards and best practices. We adopt a defensive, protection-in-depth strategy, implementing strict physical, administrative, and technical security measures (including but not limited to prevention, detection, and corrective controls) to protect your personal information from unauthorized access, disclosure, use, modification, damage, or loss.

6.2 We will regularly review and adjust our security strategies and controls as needed based on technological developments, business operations, and ongoing risk assessments to continuously improve our protection capabilities.

6.3 Limitation of Liability : Although Jemi Cash has invested significant resources and implemented industry-standard security measures, the security of any data transmitted over the Internet or any electronic storage system cannot be guaranteed to be 100%. Therefore, to the maximum extent permitted by law, you understand and agree that Jemi Cash cannot and will not be held solely liable for information security incidents caused by circumstances beyond our reasonable control (such as force majeure, third-party cyberattacks, etc.).

7. Retention and Deletion of Personal Data

7.1 Retention Period : We will retain your personal data, registration information, and transaction records for the necessary period for the following purposes. Unless otherwise provided by law, the retention period will be the longest of the following : (1) 
ten years from the date of termination of your business relationship with us ; 
(2) the period necessary to achieve the collection purposes described in this policy; 
(3) the period necessary to comply with our legal or regulatory obligations (including anti-money laundering, tax, etc.); to establish, exercise, or defend our legitimate legal claims; or to achieve a legitimate business purpose (which must meet the standards generally followed in the financial industry).

7.2 Data Destruction : Once the above retention period expires, or when we are no longer permitted or required to retain your personal data for legitimate purposes, we will securely destroy or delete your personal data in an irreversible manner (such as anonymization, shredding, erasure, etc.) in accordance with established physical and technical security procedures, ensuring that it cannot be subsequently retrieved, used, or restored, thereby preventing any unauthorized access, disclosure, or damage to the interests of the data subject.

8. Your Rights and Complaints

8.1 To the extent permitted by the applicable laws of the Republic of Ghana, you have the right to object to how we process your personal information and to oppose our use of your personal data for specific purposes.

8.2 If you have any questions about this policy, need to exercise your legal rights, or have any concerns or complaints about how we process your personal information, you may contact Jemi Cash through the channels specified in this policy.

8.3 Upon receiving your formal complaint, we will promptly acknowledge receipt in accordance with our internal compliance procedures and inform you of the expected investigation and response time.

9. Policy revision

9.1 Jemi Cash reserves the right to update and revise this Privacy Policy from time to time. Any updates or revisions will be published through our official platforms or website, indicating the latest revision date. We recommend that you review this policy periodically for any changes.

9.2 The revised Privacy Policy will take effect from the date of its publication and will apply to all your information that we hold and process thereafter. Your continued use of our services after the revision of this policy constitutes your acceptance of all the updated terms.

9.3 If you do not agree to the updated policy terms, you have the right to contact us to terminate your use of our services. In this case, we will process your personal information in accordance with Article 7 of this policy.

10. Consent and Confirmation

10.1 When you voluntarily provide us with your personal data, it means that you have read, understood and expressly agree that Jemi Cash, its affiliates, subsidiaries and authorized partners may collect, use, process and disclose your personal data in accordance with the purposes, methods and scope described in this Privacy Policy.

10.2 If you do not agree to any part of this policy (including any revisions thereof), please do not provide any personal information when we request it, and you should immediately stop accessing or using all our products and services.

10.3 Your continued access to or use of any of our products and services will be deemed as your full understanding and acceptance of all policy terms in effect at that time, constituting your confirmation and agreement to the continued effectiveness of this policy.

11. Contact Us

If you have any questions about this Privacy Policy, need to exercise your legal rights, or wish to make any requests or complaints regarding the processing of your personal information, please contact us through the following official channels. To ensure the security and efficient processing of your information, we recommend that you provide necessary identity verification information in writing.

Customer service email : [email protected]

We will register all requests we receive and respond within a reasonable timeframe that complies with legal and regulatory requirements and our internal procedures.