PRIVACY
POLICY

1. Overview

This Privacy Policy describes how Agentics Technology Solutions Ltd., operator of UBL Africa, collects, uses, stores, and protects your personal information when you use the UBL Africa platform, mobile application, or website.

2. Data We Collect

We collect the following categories of data:

• Identity data: Full name, phone number, email address, national ID (where provided), region of residence
• Financial data: Loan application details, repayment history, mobile money transaction patterns (with consent)
• Behavioural data: GPS location data (for activity pattern scoring), app usage frequency
• Network data: Community vouch relationships, vouch strength, and vouching history
• Voice biometric: MFCC voice print (see Section 3)

3. Biometric Data

UBL Africa uses MFCC voice biometric technology for member authentication. This constitutes biometric data under Ghana's Data Protection Act 2012.

• Your voice print is captured at registration with your explicit consent
• It is stored in encrypted form in our secure AWS infrastructure
• It is used solely for identity verification within the UBL platform
• It is never shared with third parties
• You may request deletion at any time

4. How We Use Your Data

• Computing and maintaining your UBL Trust Score
• Verifying your identity for account access and transactions
• Processing loan applications through bank partners
• Detecting fraud and suspicious activity via SHIELD AI
• Complying with Bank of Ghana regulatory requirements

5. Data Sharing

• Bank Partners (GCB Bank, Ecobank): When you apply for financial products, we share necessary KYC and trust score data
• Smile Identity: For KYC verification under strict data processing agreements
• Regulatory compliance: We may disclose data to Bank of Ghana or law enforcement when legally required
• We never sell your data to advertisers or data brokers

6. Data Retention

• Identity and financial data retained for 7 years per Ghana anti-money laundering regulations
• Voice biometric data deleted within 30 days of account closure upon request
• Behavioural data retained for 2 years for fraud investigation

7. Your Rights

• Access a copy of your personal data
• Correct inaccurate personal data
• Request deletion of your account and data
• Withdraw consent for voice biometric capture
• Request explanation of your trust score calculation
• Lodge a complaint with the Data Protection Commission of Ghana

Contact: info@agenticstechnology.tech with subject "Data Rights Request".

8. Security

• TLS 1.3 encryption for all data in transit
• AES-256 encryption for data at rest
• AWS af-south-1 regional data residency
• SHIELD AI real-time anomaly detection on all platform activity

9. Contact

Email: info@agenticstechnology.tech
Address: Accra, Ghana
Governed by the laws of the Republic of Ghana.