Privacy Policy
This Privacy Policy has been established to safeguard and uphold the privacy of users of our Product. The Product is developed, owned and managed by FAV & JAY GLOBAL (referred to as "FAV & JAY", "Cashpal Pro", "we", "us", or "our"). Please note that this policy does not extend to any external websites or mobile applications not under our operation that may be accessible through our Product.
We strongly encourage all users to thoroughly review and comprehend this Privacy Policy prior to utilizing our Services. Your use of our Services, whether by:
i) expressly indicating acceptance through clicking or checking the appropriate box, and/or
ii) simply accessing and engaging with our Product's features,
constitutes your acknowledgment of having read, understood, and agreed to all provisions contained herein, along with our Product's terms of use.
This document specifically outlines how Cashpal Pro handles personal information, including but not limited to its collection, processing, analysis, storage, correction, updating, display, transfer, dissemination, disclosure, and eventual deletion or destruction. By accessing or using our Services, you are confirming your acceptance of these information handling practices as described in this Privacy Policy.
Cashpal Pro collects certain information from users during registration and use of our Services, including through our mobile application (Cashpal Pro) and website (https://www.favjayglobal.com/). The extent and manner in which we may utilize, process and transfer this information is governed by this policy. Our Services primarily facilitate small loan applications, subject to mutually agreed Terms of Use. Your decision to visit or use our Services indicates your acceptance of and consent to the data practices described in this Privacy Policy.
1. Definitions
The following terms, when used in this Privacy Policy, shall be interpreted and defined as set forth below, unless otherwise specified in other sections of this document:
1.1 "Personal Information/Data" refers to all electronic or non-electronic data, documents and information pertaining to the User and/or their related parties (including but not limited to family members, associates, employees, companies or service providers, when required for emergency contact or other legitimate purposes) that Cashpal Pro obtains from the User or third parties, or that the User submits, provides or discloses to Cashpal Pro, all subject to the User's consent and maintained in connection with the provision of Services.
1.2 "User" means any individual who registers for or utilizes services offered through Cashpal Pro's Application.
1.3 "Terms of Use" refers to the usage terms established by Cashpal Pro that Users must accept when registering for and using the Product.
1.4 User's Information encompasses both (i) Personal Information/Data as defined above and (ii) any other data specified in this Privacy Policy..
1.5 "Law" includes all applicable legislation, regulations, implementing rules, decrees and policies with legal force in the Republic of Ghana, including regional regulations and other derivative legal requirements.
1.6 "Cookies" are small data files sent by websites/applications to a user's device that record specific visit information, including but not limited to: browser and operating system types, access dates/times, and website navigation patterns. These files facilitate improved user experience during future visits.
1.7 "You" (including all grammatical variations) refers to any individual accessing or using the Product and/or Services, regardless of registration status..
1.8 "Process/Processing" encompasses all actions related to personal data, including:
a. collection and acquisition;
b. processing and analysis;
c. storage, correction and updating;
d. display, transfer, distribution or disclosure; and/or
e. deletion or destruction.
2. How We Collect Information
2.1 Data Collection Methods
Cashpal Pro gathers personal data through multiple channels to process requests and meet regulatory obligations:
a. User Registration, refers to Direct submission of personal details during account creation;
b. Automated Collection refers to (i) Technical information (usage patterns) during Product interaction, (ii) Transaction records from payment activities and (iii) Data generated through API connections.
c. Third-Party Sources, refers to indirect collection via verified external partners operating under legal frameworks.
d. Other users, refers to those information shared between registered Cashpal Pro users.
e. Public records, refers to Legally accessible public data sources.
3. Permissions on Your Device for Collection
For the purpose of collecting your information via Cashpal Pro directly, we may have access to the following permissions:
3.1 Financial SMS. The collected information will include timestamps, sender phone numbers, and the content of financial SMS messages. We will filter messages according to rules. We will exclude messages containing personal/non-financial keywords.The collected financial SMS data will be used in our credit, risk, and verification models to assess your eligibility for our services. Automated processing will be applied to analyze your financial activity and support our fraud prevention and identity verification systems. You maintain the right to revoke SMS access permissions at any time through your device settings, though doing so may affect your ability to use certain features of our service.
3.2 Emergency Contacts. To verify your identity and help prevent fraud, we require to collect two emergency contacts. You can either manually enter these contacts or choose them from your address book. Only the selected contacts are accessed—no other information from your address book is collected.
3.3 Device Information. To facilitate your loan application and for fraud prevention purposes, our app will collect specific device information including device name, device type and model, operating system version, status. This data collection is strictly limited to device authentication and risk assessment purposes. We maintain strict confidentiality of this information, which is never shared beyond our authorized verification partners and is never utilized without proper authorization. You retain full rights regarding this data collection, though certain application features may require this verification process to function optimally.
3.4 Advertising ID. To serve targeted ads or track the effectiveness of advertising conversions, we will collect your device's advertising identifier (AD_ID). You may view and adjust this permission in your device settings at any time to manage our access. We may share this data with our third-party partners to identify user sources and optimize advertising campaigns.
3.5 Application Interaction. When you use our application, we collect data about how you interact with it to improve your service experience. By analyzing user behavior patterns, feedback, and other relevant information, we gain insights into preferences and feature performance. This helps us detect unusual activity, deliver personalized services, and enhance product functionality. The collected interaction data also supports our credit risk evaluation and fraud prevention model.
3.6 Application List. When using our service, we analyze the installed apps on your device for credit assessment purposes. This process collects limited technical data, including application names, categories, installation/update dates, and version numbers. This data enables us to evaluate creditworthiness and process your application efficiently. We emphasize that this process never accesses your complete app inventory, and all collected data remains confidential, without being shared with third parties.
3.7 Calendar. The collected information will include event title, event start/end date, and event description. We will filter the event title according to rules. We will exclude events containing personal/non-financial keywords. The collected financial calendar data will be used in our credit, risk, and verification models to assess your eligibility for our services. This access is also used exclusively to create reminders that support your credit health and enhance your eligibility for future loans. All reminders are made only with your explicit consent and are strictly for service-related purposes. You maintain the right to revoke calendar access permissions at any time through your device settings, though doing so may affect your ability to use certain features of our service.
3.8 Approximate Location. When you enable location services, we will collect your location data to determine if your usage is within Ghana. You can disable this feature at any time through your device settings.
3.9 Application Screen Time. When using our service, we collect information about how you use applications on your device for credit assessment purposes. This process collects limited technical data, such as how often and how long you use financial apps. This data enables us to better understand your usage patterns and to enhance your credit evaluation and fraud risk profile. Before accessing this data, we will display a prompt asking for your explicit permission. You maintain the right to revoke Application Screen Time access permissions at any time through your device settings, though doing so may affect your ability to use certain features of our service.
4. Collected Information
4.1 Cashpal Pro, acting as data controller, either independently or through authorized third-party partners, will collect personal data directly or indirectly from individuals. Such collection will only occur after establishing a proper legal basis under Article 7 (Legal Basis for Processing) and in full compliance with all relevant data protection laws and regulations.
4.2 For all data subjects (including Users), Cashpal Pro or its approved partners will obtain explicit consent prior to data collection, except (i) specifically permitted by law or (ii) legally exempt from consent requirements. All the collection shall strictly adhere to applicable legal standards.
4.3 To ensure the security and in accordance with the best practice in the industry, any and all of your data shall be securely encrypted each time transmitted and/or transferred, including the data flow among you, us and any third party disclosed and described in this Policy. When collecting your data via the application by us directly, the data shall be encrypted and then uploaded to our server (https://app.favjayglobal.com/) via the HTTPS protocol. We will not share your data with any third party without legal basis listed above.
4.4 The Personal Data collected shall include:
a. Identification information, includes full name; identification number; date of birth; gender; residential status; contact telephone number; email address; emergency contact details including their relationship to you, full name and phone number;
b. Employment information, includes company name, company address, monthly income, length of employment, occupation;
c. Financial SMS.
d. Device information.
e. Advertising ID.
f. Approximate location.
g. Application list, including but not limited to application name, installation time, update date, version information, etc.
h. Calendar
i. Application screen time
j. other additional personal data required by the government pursuant to the Law from time to time;
k. any past or update of the above-mentioned personal data.
4.5 We collect various types of information to provide and improve our services, including:
a. Transaction records from product usage, telecom service data, and anonymized mobile activity (call/SMS patterns, location data, and transaction history) obtained from authorized third parties;
b. Service usage patterns, configuration settings, and interaction data;
c. Credit background and repayment history;
d. Customer service interactions including support requests, complaints, and any call recordings;
e. Financial particulars such as banking details, account numbers, social insurance records, and payment card information;
f. Additional details specific to promotions, campaigns, or special features you engage with;
g. Any supplementary documentation mandated by government regulations.
h. Customer service communications including voice recordings; and
i. All data collection complies with applicable laws and our Privacy Policy.
4.6 The User acknowledge that the relevancy of collecting the type of Personal Data as mentioned in this article is for processing the User' Personal Data as described in Article 11 on Disclosure of Information We Collect, Article 7 on Purpose or any article herein.
5. Software Development Kits (“Sdk”) on Your Device
In order to facilitate the process for you to obtain our services, we use the following SDKs in our application:
5.1 Adjust SDK
Adjust SDK, provided by Adjust GmbH, has been registered in Google Play SDK Console. We use this SDK in our application to collect advertising identifier, approximate location, to solely record activations, app opens (sessions) and in-app events. In-app events mean user behaviors such as in-app purchases or game completions. We will use these events to measure ROI and users quality. This SDK adopts end-to-end encryption on all data transmitted through it and will delete specific end-user data to ensure the security of your personal data.
5.2 Google Analytics SDK
Google Analytics SDK, provided by Google LLC, has been registered in Google Play SDK Console. We use this SDK in our application to collect advertising identifier, application instance ID, operating system, operating system version, language, platform, device category, device model, device brand name and application activities (webpage visits and clicks within the application and other actions) solely to create report analyzing the user behavior, making informed decisions on application marketing and performance optimization, and further providing data analysis on application usage and user interaction. This SDK will integrate with various Firebase features, leveraging Firebase SDK to define users’ in-app events and then provide unlimited reports. This SDK uses HTTPS to encrypt data in transit and logically isolate users/clients data to ensure the security of your personal data.
5.3 Firebase Crashlytics
Firebase Crashlytics SDK, provided by Google LLC, has been registered in the Google Play SDK Console. We use this SDK in our application to collect Crashlytics installation ID, Firebase installation ID and crash and device information in order to optimize application performance, improve the smoothness of application operation and ensure the user experience by improving application response speed and stability, quickly locating and solving problems such as crashes and freezes. We will not collect your sensitive information and will not obtain any sensitive permissions from you. This SDK uses HTTPS to encrypt data in transit and logically isolate users/clients data to ensure the security of your personal data.
5.4 Facebook Android SDK
Facebook Android SDK, provided by Facebook, has been registered in the Google Play SDK Console. We use this SDK in our application to collect advertising identifier and application activities webpage visits and clicks within the application, other actions) solely to understand your actions in your app and measure the performance of your mobile applications ads.
6. Cookies Policy
6.1 Cashpal Pro employs cookies for multiple purposes including recognizing returning users, tracking visitor numbers, and enhancing user experience when accessing our services. These cookies are automatically activated whenever you use our platform.
6.2 When enabled, cookies record limited data about your website interactions, helping us identify your preferred features and previously viewed content. This allows us to personalize your future visits to better suit your needs.
6.3 You have the option to manage cookie settings through your web browser. By adjusting your browser's "Options," you can choose to block cookies or receive notifications when cookies are being set. Please note that disabling cookies may affect certain features and services available on our platform.
6.4 For more detailed information about managing cookie preferences, please refer to the "Help" section in your browser. Be aware that restricting cookies may limit your access to some functionalities.
6.5 While other companies may use their own cookies subject to their privacy policies, Cashpal Pro's cookies remain separate and are not accessible to advertisers or third parties.
7. Purpose
7.1 You expressly authorize Cashpal Pro to collect, process, analyze, store, disclose, and utilize your information for the following legally permitted purposes:
a. sharing data with third-party service providers to facilitate registration, credit scoring, and electronic signature verification as outlined in Policy;
b. assessing and validating your registration applications, loan requests, and user profile through our verification methods;
c. performing statistical analysis, credit risk assessments, anti-money laundering checks, background screenings, and maintaining your credit history;
d. verifying information accuracy with authorized third-party providers;
e. contacting you to confirm provided details and evaluate potential fraud risks;
f. requesting updates to your personal information from you or relevant third parties when necessary;
g. monitoring transactions to detect, prevent, and investigate suspicious activities, fraud, or violations of our Terms of Use, including taking appropriate follow-up actions. All data processing will be conducted in compliance with our Privacy Policy and applicable data protection regulations;
h. detecting and preventing abuse, malicious activities, fraud, spam, and illegal conduct on our platform;
i. conducting investigations required by law, including anti-money laundering and counter-terrorism financing in financial services;
j. developing, training, and enhancing credit assessment models using AI/ML technologies for our services and partner offerings;
k. delivering marketing/promotional content via SMS, WhatsApp, email, or AI-powered calls;
l. sending relevant newsletters about our products/services or those of partners;
m. sharing information with partners for their product promotions;
o. analyzing marketing effectiveness through research, studies, and product development to better understand user needs and improve our offerings. All processing complies with applicable data protection regulations;
p. delivering loan-related reminders within the Product;
q. verifying emergency contacts to confirm your whereabouts when necessary;
r. authenticating your identity when you contact us or access the Product;
s. addressing your inquiries, requests, or complaints, and notifying you of Product/service updates;
t. complying with legal obligations, including anti-money laundering (AML), counter-terrorism financing (CFT), and loan/funding agreements;
u. enforcing and supervising Loan Agreement terms;
v. conducting Cashpal Pro's legitimate business operations in good faith;
w. conducting surveys, research, and product/service development for Cashpal Pro or affiliated parties;
x. managing third-party services integrated with Cashpal Pro's offerings; and
y. any other purpose for which you explicitly provide consent.
Cashpal Pro may process your information for additional legitimate purposes beyond those explicitly stated, provided that: (1) we will inform you of such purposes when seeking your consent, except where (2) applicable laws permit processing without consent. All such processing will comply with relevant data protection regulations and our Privacy Policy standards. This ensures transparency while allowing necessary flexibility to meet evolving business needs and legal requirements. We maintain strict adherence to lawful bases for processing as defined under governing legislation.
7.2 Should you object to our use of your personal information for these specified purposes, you may submit a formal written request to Cashpal Pro. Please be advised that such objection may result in our inability to continue providing our products and services to you, potentially requiring termination of our business relationship to comply with your request. Your continued use of our services constitutes acceptance of these terms.
8. Legal Basis for Data Processing
Pursuant to the applicable laws and regulations, We process your Personal Data based on one or more of the following legal grounds:
8.1 Consent
Processing is conducted based on your explicit consent for specific, clearly defined purposes.
8.2 Contractual Necessity
Processing is required to fulfill our mutual obligations under the agreement and related contractual documents between you and Cashpal Pro.
8.3 Legal Compliance
Processing is necessary to meet our statutory and regulatory obligations as a financial service provider.
8.4 Legitimate Interests
Processing is carried out to pursue our legitimate business interests or those of third parties, provided such processing does not override your fundamental rights and freedoms.
8.5 Vital Interests
Processing is necessary to protect the life or physical safety of the data subject or another individual.
All processing activities are conducted in compliance with applicable data protection laws and regulations. You may withdraw your consent where applicable, though this may affect our ability to provide certain services.
9. Applicability and Consent
9.1 This Privacy Agreement forms an integral part of the Product's Terms of Use. All capitalized terms used herein shall carry the same meanings as defined in the Terms of Use, unless expressly stated otherwise or the context requires a different interpretation. References in the singular include the plural, and vice versa. By accessing our Product and/or submitting your Personal Information, you confirm that you have read, understood, and agreed to this Privacy Policy, including your consent for us to Process your Personal Information as described herein.
9.2 This Privacy Policy shall legally binding on Users from the occurrence of:
a. The User's affirmative action indicating acceptance (including but not limited to clicking, checking, or otherwise expressly agreeing to this Privacy Policy); and/or
b. The User's initial access or use of the Service and/or Product.
c. For clarity: (i) If amendments are made to this Privacy Policy during a User's ongoing use of the Service/Product, continued access or use after such amendments constitutes acceptance of the revised terms; (ii) The amended Privacy Policy shall take effect from the User's first subsequent access or use of the Service/Product post-amendment. By persisting in the use of the Service/Product, Users reaffirm their agreement to the current Policy and all modifications thereto.
9.3 Duration of the Privacy Policy shall be in accordance with the following rules:
a. While the User maintains an active registration on the Product;
b. While the User retains any outstanding obligations, financial liabilities, or debts under any Loan Agreement; and/or
c. During the pendency of any loan application submission and its subsequent assessment by Cashpal Pro or its authorized third-party partners.
d. Users expressly acknowledge and consent that Cashpal Pro may disclose Personal Information to: (i) Authorized government agencies; (ii) Institutions designated by government authorities. The retention period of such disclosed information shall be governed by the respective policies of these receiving entities.
e. Users further acknowledge that this Privacy Policy remains valid and enforceable for the entire duration necessary to fulfill its stated purposes, including but not limited to legal compliance, risk management, and dispute resolution.
10. Withdrawal of Consent
You may at any time object to our continued use, collection, and/or processing of your Personal Data for any lawful purpose and in the manner described by contacting us at our email address. This serves as your mechanism to terminate or grant permissions previously provided to us. Please be aware that if you object to the processing of certain Personal Data, depending on the nature and subject of your objection, it may affect the timeline of your application and/or our assessment of your creditworthiness. In such cases, our legal rights and remedies are explicitly protected by law.
11.Disclosure of Information We Collect
Cashpal Pro maintains strict confidentiality of your information while reserving the right to disclose, transfer, or grant access to your data when necessary for service provision, regulatory compliance, or other purposes outlined in this Privacy Policy, in accordance with applicable Ghanaian laws. Such disclosures may include, but are not limited to:
11.1 Internal Parties - Cashpal Pro's directors, officers, employees and/or affiliates;
11.2 Authorized Service Providers - Including payment processors, KYC providers, credit scoring agencies, fraud prevention services, digital finance innovators, AI communication platforms, advertising networks, analytics providers, and other compliant technical partners;
11.3 Financial Institutions - Banks and licensed third-party lenders;
11.4 Business Partners - For cooperative ventures and joint marketing initiatives;
11.5 Government Entities - Courts, law enforcement, and regulatory bodies as required by law or official directives;
11.6 Corporate Group - Subsidiaries, affiliates, and holding companies within Cashpal Pro's organizational structure;
11.7 Authorized Government Agencies - Officially recognized institutions under Ghanaian law;
11.8 Platform Users - Other registered users when verifying information within our system;
11.9 User-Approved Third Parties - Any external parties you explicitly authorize.
Cross-border data transfers may occur to third-party providers outside Ghana, who will process your information strictly for the purposes defined in this policy while adhering to all applicable data protection regulations. All disclosures will be limited to the minimum necessary information required for the specified purpose..
12. Security of Personal Information
12.1 Cashpal Pro values and prioritizes the protection of user privacy by maintaining strict confidentiality of all account information and related data in accordance with this Privacy Policy through the following measures: (a) prohibiting disclosure of any information except as expressly permitted under Article 11 (Disclosure of Information We Collect) and Article 7 (Purpose of this Privacy Policy); (b) implementing technological safeguards to prevent unauthorized computer or network access; (c) restricting employee access to user data on a need-to-know basis; (d) employing technical security measures to ensure safe information storage; and (e) conducting ongoing monitoring to verify that user information remains protected with appropriate safeguards in place. These comprehensive protections demonstrate our commitment to securing your personal data while enabling service delivery.
12.2 Cashpal Pro implements reasonable security measures to protect your personal information from unauthorized loss, misuse, or alteration. However, we must clarify that no security system is completely infallible - potential risks include unauthorized access, technical failures, or other security breaches beyond our control.
12.3 By using our services, you acknowledge these inherent risks and understand that Cashpal Pro cannot guarantee absolute protection against all possible security incidents. When registering, you will create a personal password which you must keep confidential and not share with others.
12.4 While we employ industry-standard protections, we cannot ensure 100% internet security. Any transmission of your personal data carries inherent risks, and we strongly advise accessing our services only through secure internet connections. You assume responsibility for data transmissions made through your account.
12.5 This disclaimer applies to the fullest extent permitted by law regarding any unauthorized access, disclosure, modification, or deletion of your information. We maintain our commitment to implementing appropriate safeguards while recognizing the practical limitations of data security.
12.6 You acknowledge and consent that we may disclose your Personal Data to authorized government agencies and/or other institutions appointed by government authorities. You understand that such entities will retain your information according to their respective data retention policies..
12.7 Please be aware that internet communications cannot be completely secured and may be intercepted, lost, or altered. Cashpal Pro cannot guarantee the security of messages transmitted online and shall not be held liable for any damages resulting from:
a. Lost communications;
b. Messages modified by third parties;
c. Undelivered messages;
d. whether sent by you to Cashpal Pro or by Cashpal Pro to you through internet channels. This limitation of liability applies to the fullest extent permitted by law.
13. Failure to Secure Personal Data
13.1 Cashpal Pro maintains a firm commitment to protecting your Personal Data in full compliance with all applicable laws and regulations regarding data protection.
13.2 Should any breach of your Personal Data security occur on our platform, or should we receive notification of such a breach from a third party, we will.
a. Make commercially reasonable efforts to promptly notify you in writing via email;
b. Provide a clear explanation of the nature and circumstances of the breach;
c. Disclose the known or probable causes of the security failure;
d. Outline any immediate remedial actions taken;
e. This notification will be provided without undue delay following our confirmation and assessment of the breach, in accordance with legal requirements and industry best practices for data breach disclosure.
14. Change, Return and Destruction of Personal Data
14.1 Users may request the deletion of their Personal Information while our official website or within the application directly, which Cashpal Pro will process unless retention is required by law. Such deletion involves permanently removing records containing the User's data from Cashpal Pro's systems to prevent future display or use, except where new information is subsequently provided by the User.
14.2 Cashpal Pro acknowledges Users may need to modify their Personal Information periodically. Update requests must be submitted in writing via email, detailing the required changes. Cashpal Pro will process these requests unless the modifications would: (i) compromise personal or public safety; (ii) risk disclosing others' Personal Information; or (iii) conflict with national security interests. All updates will be implemented in accordance with applicable data protection regulations and internal verification procedures.
14.3 These provisions ensure Users maintain control over their Personal Information while allowing Cashpal Pro to meet its legal obligations and protect legitimate security interests. Requests are typically processed within a reasonable timeframe following proper authentication measures.
15. Users' Rights
As a User of Our Product, you have the following rights regarding your Personal Data, including but not limited to:
15.1 The right to obtain historical Personal Data provided to Us, subject to the requirements of applicable laws and regulations;
15.2 The right to require Us to maintain the confidentiality of your Personal Data;
15.3 The right to submit a request for the destruction of Personal Data managed and stored by Us, except as otherwise specified by applicable laws and regulations;
15.4 The right to access, correct, or update your Personal Data to ensure its accuracy in the Product;
15.5 The right to receive information about the purposes of use and disclosure of your Personal Data as described in this Privacy Policy.
16. User Responsibility
16.1 The User undertakes to provide only accurate and non-misleading Personal Information to us, keep it updated, and notify us of any changes (see further details below). We reserve the right to request documentation to verify the information you provide. If you provide Personal Information of any third party (including but not limited to emergency contact details), you represent and warrant that you have obtained the necessary consent from such third party to share and transfer their Personal Information to us.
16.2 The User agrees to defend, indemnify, and hold harmless Cashpal Pro, its affiliates, shareholders, directors, officers, employees, subcontractors, providers, and agents from and against any claims, lawsuits, demands, losses, damages (including legal fees and expenses) arising out of or resulting from the User's breach of this Privacy Policy, the Loan Agreement, the Services, and/or other agreements with Cashpal Pro.
17. Governing Law
17.1 This Privacy Policy shall be governed by and construed in accordance with the laws of the Republic of Ghana.
17.2 In the event of any dispute arising from the interpretation or enforcement of this Privacy Policy ("Dispute"), the User agrees to first attempt to resolve the Dispute through good-faith negotiation to reach a consensus within 30 (thirty) days from receipt of notice of the Dispute.
18. Amendment
18.1 We reserve the right to revise this Privacy Policy at any time, without prior notice except as required by law. All amendments will become effective upon publication and apply to all Users. Users are advised to review this Privacy Policy periodically.
18.2 Your continued use of the Mobile Application, Website, or Services following any updates to this Privacy Policy constitutes your acceptance of the revised terms.
19. Contact Us
If you have questions, comments and requests or other matters related to the Product, you can contact Cashpal Pro's officers via the following channels:
Email: cashpalpro@favjayglobal.com