PRIVACY POLICY

Effective Date: April 4, 2026

1. Scope of this Privacy Policy

1.1 “TakaCashLoan - Easy and safe” is a digital consumer credit provider operating in the People’s Republic of Bangladesh and authorized and/or licensed by the competent Bangladeshi financial regulatory authorities, including the Bangladesh Bank (BB), when applicable. Acting as the data controller, we are responsible for collecting and processing your personal information whenever you download and use the TakaCashLoan - Easy and safe mobile application available on the Google Play Store, or whenever you access our services through other official channels.

1.2 Under certain circumstances, TakaCashLoan - Easy and safe may also act as a data subprocessor on behalf of another data controller with whom the user has a contractual relationship. In such cases, TakaCashLoan - Easy and safe will process the user’s personal information strictly according to the instructions provided by that data controller.

1.3 If you have any questions or concerns related to this Privacy Policy, you may contact us at the email address customer_service@yuanyiyanjie.com.

1.4 Users should carefully read this Privacy Policy to understand how we process their personal information in compliance with the applicable data protection and privacy laws of Bangladesh, including the Digital Security Act, Bangladesh Bank regulations, and any applicable data protection, cybersecurity, and financial service regulations issued by competent authorities in Bangladesh. By accepting the terms of this Privacy Policy through your use of TakaCashLoan - Easy and safe, you acknowledge and agree that your personal data will be processed in accordance with this Policy.

1.5 The services of TakaCashLoan - Easy and safe are not intended for persons under eighteen (18) years of age. We do not knowingly collect or process personal data relating to individuals below this age limit.

2. Definitions

2.1 “Privacy Policy” refers to this Privacy Policy of TakaCashLoan - Easy and safe, accessible through the TakaCashLoan - Easy and safe application and our official website. This Policy sets out the principles and procedures by which we store and process any personal information collected from or provided by the user.

2.2 “Channel” refers to any system or means established by us—including the TakaCashLoan - Easy and safe mobile application and website, whether web-based or mobile—that allows the user to access and use one or more of our services.

2.3 “Child” or “Children” refers to any individual under eighteen (18) years of age.

2.4 “Consent” means the expression of the user's will, given through a clear affirmative statement or action, expressed explicitly, unequivocally, voluntarily, specifically, and informed.

2.5 “Client” or “User” refers to any natural person located in the People’s Republic of Bangladesh to whom TakaCashLoan - Easy and safe provides services within its operations.

2.6 “Personal Data” means personally identifiable information, including but not limited to name, address, telephone number, identification number, location data, date of birth, gender, transaction records, online identifiers, or other elements relating to the physical, psychological, genetic, mental, economic, cultural, or social identity of an individual. It also includes any information associated with an identified or identifiable natural person, including sensitive personal data.

2.7 “Sensitive Personal Data” means personal information related to race, health status, ethnic or social origin, religious or other beliefs, genetic data, biometric data, financial status, marital status, family information (including names of children, parents, or spouse), or an individual’s gender or sexual orientation, as well as any other categories treated as sensitive under applicable laws of Bangladesh.

2.8 “Services” means financial products and features made available to clients by TakaCashLoan - Easy and safe through its mobile application, partner channels, or any other duly authorized channels.

2.9 “We”, “Our” or “Us” refers to TakaCashLoan - Easy and safe.

2.10 “You”, “Your” refers to the Client (User), including their personal representatives.

3. Consent and Authorization

3.1 By downloading the TakaCashLoan - Easy and safe application and selecting “Accept” on the permissions overview screen, the user declares that:

3.2 Requested Device Permissions
With the user’s explicit consent, we may request the following permissions. Users may refuse or withdraw such permissions at any time through device settings; however, some features may become unavailable and credit assessment may be affected:

4. Personal Information We Collect About the User

4.1 With the user’s consent, TakaCashLoan - Easy and safe collects personal information when the user accesses our Services. This information includes, but is not limited to, the following categories:

4.1.1 Identity Data

When using our application, we may collect the user’s full name, gender, date of birth, age, nationality, and national identification number (e.g., Identity Card).
Source: recognition by OCR of the identification document submitted by the user through the application.
Purpose: identity verification, KYC procedures, fraud prevention, eligibility assessment, and compliance with legal and regulatory obligations.

4.1.2 Profile Data

We may collect information related to education level, employment status, profession, income, marital status, type of residence, and any other information provided by the user in application forms or questionnaires.
Purpose: credit scoring, service personalization, risk model improvement, and customer support.

4.1.3 Financial Data

We may collect bank account numbers, bank institution names, mobile money account details (where applicable), transaction records, repayment history, and other payment identifiers.
Purpose: loan application processing, repayment capacity verification, payment management, and compliance with AML/CTF requirements.

4.1.4 Camera Data (Identity Verification)

With the user’s authorization, we may access the device’s camera exclusively for liveness detection and identity verification, including capturing a selfie or uploading identification documents.
Purpose: to confirm the authenticity of the user’s identity and prevent identity theft.
Safeguards: we do not use the camera in the background and do not use the captured images for unrelated purposes.

4.1.5 Emergency Contact Data (Selective)

We may collect the name, relationship, and phone number of emergency contact(s) designated by the user.
Source: only contacts manually selected by the user from their address book.
Purpose: identity verification and communication in emergency situations. We do not access or collect the entire contact list.

4.1.6 SMS Data (Financial SMS Only)

With the user’s authorization, we access exclusively financial SMS messages and may process information such as sender, date and time, and financially relevant content.
Purpose: credit scoring, estimation of financial capacity, analysis of income and expense patterns, and fraud prevention.
We do not access or process non-financial personal SMS messages.
We apply automatic filtering mechanisms to identify and process only SMS messages reasonably necessary for financial, credit, repayment, transaction, security, and fraud prevention purposes.
Messages that are clearly unrelated to financial activities—including personal communications, social interactions, entertainment, health, education, food, travel, lifestyle content, or other non-financial topics—are automatically excluded and not processed.
SMS data processing is performed automatically. We do not manually read personal SMS messages.

4.1.7 Installed Applications Data

With the user’s authorization, we collect information related to applications installed on the device, such as package name, category, and installation status.
Purpose: device risk profiling, fraud prevention, and credit risk assessment.
Additional clarification: this information is mainly used to evaluate the use of finance-related applications and device risk and is not used for advertising purposes.

4.1.8 Device and Technical Data

When using our Android application, we may collect the type of mobile device used, device specifications (such as screen resolution and memory), IP address, Android device identifiers (including Android ID, device ID, IMEI, and serial number), mobile network operator, and operating system version.
These data are used for fraud prevention, account security, risk management, and to ensure service compatibility and performance, including device security and integrity signals.
These identifiers are not used for advertising, marketing, or cross-application profiling purposes.

4.1.9 Approximate Location Data

With the user’s authorization, we may collect approximate location data (approximate latitude and longitude, accuracy radius, time, and regional-level address).
Purpose: fraud prevention, device consistency checks, and regulatory compliance.
We do not collect background location data without the user’s explicit authorization.

4.1.10 Usage Data

We may collect account identifiers, passwords or authentication tokens, OTP verification events, device session logs, and records of the user’s interactions with the application or other Channels.
Purpose: account maintenance, access authentication, transaction processing, customer support, and product improvement.

4.1.11 Third-Party Data

We may obtain information about the user from partners and public sources, including private credit information centers (CPIC), identity verification and sanctions screening providers, telecommunications and payment partners, as well as marketing partners.
Purpose: validating information provided, credit scoring, regulatory compliance, and fraud prevention.

4.2 We may collect additional information only when necessary and lawful.

4.3 Sources include user input, device data, and third-party providers.

4.4 We process data to comply with Bangladesh Bank (BB) and applicable laws.

4.5 If data is not provided, services may be unavailable.

4.6 Data is securely transmitted via encrypted channels. With the user's consent and authorization, personal information will be encrypted and transmitted to our secure server via takaloan.api.takacashloan.com. No data is transmitted when the application is inactive or running only in the background.

4.7 We do not sell or misuse personal data.

5. Purposes and Legal Basis of Personal Data Processing

5.1 We process the user’s personal information only when there is a legal basis to do so. In most situations, we rely on one or more of the following grounds:

5.2 If the user does not provide or maintain the required personal information, we may not be able to provide the Services.


6. Use of Personal Information (Automated Decisions)

6.1 We may use automated decision-making processes and profiling features to provide credit services and prevent fraud.

6.1.1 Automated Credit Decision

When a user requests credit, we may use automated processing of the information described in Section 4 to determine loan approval and/or establish the credit limit, term, and applicable conditions.
Whenever SMS data is used in automated credit evaluations or fraud prevention, such data is assessed through automatic models and rules. Any applicable human review does not involve reading the content of personal SMS messages.

6.1.2 Credit Assessment with Machine Learning Models

Our underwriting models process Identity Data, Profile Data, Financial Data, Financial SMS, Installed Applications Data, Android Device Data, Approximate Location Data, and Usage Data to evaluate the user’s creditworthiness. Automated processing may result in credit denial or adjustment of amount or term. Models are periodically tested to ensure fairness, accuracy, and bias mitigation.

6.1.3 Automated Fraud Control

We use automated systems to detect, combat, and prevent fraud and AML risks. If the systems determine that a user or transaction poses a fraud risk, access may be restricted or denied.

6.2 User Rights Related to Automated Decisions

If you are denied or limited as a result of automated credit, underwriting, or fraud decisions, you may request a manual review by contacting us at customer_service@yuanyiyanjie.com. You also have the right to object to automated processing, aware that exercising this right may prevent us from providing the Services.

7. Disclosure of Personal Data

7.1 By consenting to provide personal information, the user also agrees that we may share their data with third parties as described below and for the purposes set forth in this Policy.

7.2 External third parties include, but are not limited to:

7.2.1 Private credit information bureaus and other reputable sources, as well as entities to which we may provide credit information, including repayment history and default records, in accordance with applicable laws and financial regulations of Bangladesh.

7.2.2 Local or international police, regulatory, or governmental authorities (including the Bangladesh Bank (BB) and other competent authorities in Bangladesh) upon official request, for the purposes of prevention, detection, investigation, or prosecution of illicit or fraudulent activities, and in compliance with applicable laws and regulations of the People’s Republic of Bangladesh.

7.2.3 Service providers of TakaCashLoan - Easy and safe, including cloud hosting providers, analytics service providers, identity verification providers, customer support providers, and external collection agencies, acting as subprocessors strictly under our instructions and in accordance with applicable data protection, cybersecurity, and financial regulations in Bangladesh.

7.2.4 Professional consultants, including lawyers and auditors, as well as courts or arbitral bodies, where necessary for the establishment, exercise, or defense of legal claims, or in the context of legal proceedings, audits, or regulatory reviews in Bangladesh.

7.3 We may sell, assign, transfer, or merge part of our business or assets. In such cases, the new owner or successor entity may use the user’s personal information strictly in accordance with this Privacy Policy and applicable laws and regulations of the People’s Republic of Bangladesh.

8. International Data Transfers

8.1 The user’s personal information may be stored or processed outside the People’s Republic of Bangladesh, including through cloud storage and computing infrastructures maintained by TakaCashLoan - Easy and safe or its authorized service providers and agents.

8.2 Whenever personal information is transferred outside the People’s Republic of Bangladesh, we will ensure that it is protected by implementing appropriate technical and organizational safeguards, and, where required, by adopting mechanisms, contractual protections, or obtaining necessary authorizations in accordance with applicable laws, regulations, and guidelines issued by competent authorities in Bangladesh, including the Bangladesh Bank (BB) and any relevant data protection or cybersecurity authorities.

9. Data Governance and Security

9.1 We implement an information security management system designed to preserve the confidentiality, integrity, and availability of data, in accordance with industry best practices and applicable laws and regulations of the People’s Republic of Bangladesh.

9.2 If you choose, or are assigned, a password or One-Time Password (OTP) code to access certain areas of the application, you are responsible for keeping this information confidential. We will never request the disclosure of your password or OTP code.

9.3 We have procedures in place to respond to suspected personal data breaches and, when required by applicable laws and regulations, we will notify the user and the competent authorities in Bangladesh, including the Bangladesh Bank (BB) and any relevant data protection, cybersecurity, or regulatory authorities.

10. Data Retention

10.1 We retain the user’s personal data only for the period necessary to fulfill the purposes described in this Privacy Policy and to satisfy legal retention obligations under applicable laws and regulations of the People’s Republic of Bangladesh, including those relating to anti-money laundering and counter-terrorism financing (AML/CFT), taxation, and financial services supervision.

As a general rule, identity, customer due diligence, credit, and transaction records are retained for a period typically ranging from five (5) to ten (10) years after the end of the relationship with the user, or for a longer period where required by applicable laws, regulatory instructions, or for the establishment, exercise, or defense of legal claims or rights in judicial or administrative proceedings. After the applicable retention period expires, the data will be securely deleted or irreversibly anonymized, except where continued retention is required by law.

10.2 Whenever we anonymize information in such a way that it no longer constitutes personal data under applicable laws of Bangladesh, we may use such anonymized data for lawful statistical, analytical, risk management, and business improvement purposes without further notice to the user.

11. Data Subject Rights

11.1 As a data subject under applicable laws and regulations of the People’s Republic of Bangladesh, the user has the following rights:

11.1.1 The right to be informed about the purposes and legal basis of processing their personal data.

11.1.2 The right to access their personal data and obtain information regarding the purposes of processing, categories of data processed, recipients or categories of recipients, retention period, and data sources.

11.1.3 The right to object to the processing of their personal data, in whole or in part, except where such processing is required for compliance with legal or regulatory obligations or other overriding legitimate grounds under applicable laws of Bangladesh.

11.1.4 The right to request the rectification of inaccurate, incomplete, or outdated personal data.

11.1.5 The right to request the deletion of personal data that has been unlawfully processed, is excessive, or is no longer necessary for the purposes for which it was collected, subject to applicable legal and regulatory retention requirements in Bangladesh.

11.1.6 The right to obtain a copy of their personal data in a structured, commonly used, and machine-readable format, and, where technically feasible and applicable, to request the transfer of such data to another service provider in accordance with applicable laws and regulations.

11.2 The user may request the restriction or suspension of processing of their personal data in circumstances permitted by applicable laws and regulations, including where the accuracy of the data is contested or where the user has objected to processing.

11.3 Where the processing of personal data is based on the user’s consent, the user has the right to withdraw that consent at any time. The user acknowledges that withdrawing consent may affect our ability to provide certain Services.

11.4 The user may exercise these rights directly or through a legally authorized representative by contacting us at customer_service@yuanyiyanjie.com. All requests are subject to identity verification and applicable legal requirements.

11.5 The user may request the closure and deletion of their account within the application. We reserve the right to refuse such requests where identity cannot be verified, where there are outstanding obligations such as active or unpaid loans, where the account is subject to investigation, or where retention of data is required by applicable laws or regulatory authorities in Bangladesh.

12. Changes to the Privacy Policy

12.1 We regularly review this Privacy Policy to ensure compliance with applicable laws and operational practices. Any updates or changes will be published on this page and, where appropriate, communicated to the user through the application, website, email, or SMS notifications.

12.2 The user is responsible for ensuring that the personal information provided remains accurate and up to date, and must promptly inform us of any changes to such information.

13. General Provisions

13.1 For any questions, concerns, or requests related to this Privacy Policy or the user’s rights, you may contact us through the following channels:

Customer Service
Email: customer_service@yuanyiyanjie.com
Service Hours: Monday to Friday, from 09:00 to 18:00 (Bangladesh Time)

If you wish to request the deletion of your personal data, you may contact us at the email address above. All such requests will be processed in accordance with applicable laws and regulations of the People’s Republic of Bangladesh.