Privacy Policy

Policy version: 23/09/2025

Introduction

This Privacy Policy is provided by Eshango Ltd, a company registered in England and Wales under company number: 12586343 with registered office 25a Burma Road, London, England, N16 9BH (‘we’, ‘our’ or ‘us’) for use of our products and services including our app (Services).

We provide mobile financial services through the Eshango app (the “App” or “Services”), which allow users to record income, track savings and withdrawals, apply for and manage loans, and monitor cash flow.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on how and why we collect, store, use and share any information relating to you (your personal data).

It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your personal data is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).

We are the controller of personal data obtained via the Services, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

​If you wish to delete or remove your data please contact us support@eshango.co

What this policy applies to

This privacy policy relates to your use of the Services only.

The Services may link to or rely on other apps, websites, APIs or services owned and operated by us or by certain trusted third parties to enable us to provide you with Services. These other apps, websites, APIs or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate. For more information see the section ‘Who we share your personal data with’ below.

Personal data we collect about you

The personal data we collect about you depends on the particular activities carried out through the Services. We will collect and use the following personal data about you:

  • Account Information: Name, phone number, email, date of birth, business type, education level, and a valid form of identification (such as a National ID or passport).
  • Financial Data: Information about your business income and expenses, savings deposits and withdrawals, loan applications, loans taken and repaid (including amounts, terms, and outstanding balances), and overall business cash flow.
  • Usage Data: Transaction history, preferences, usage patterns, and technical information about your device (device ID, operating system, network, app version, time zone).
  • Location Data: With your consent, we collect your location to verify business activities or for fraud prevention and security checks.
  • Communication Data: Information you provide when contacting us by phone, email, or through in-app support.
  • Posted Materials: Any content you share with us through the App (e.g. feedback, suggestions, or uploaded content).

​​Sensitive Data

Sensitive personal data (also known as special category data) means information related to personal data revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data (where used for identification purposes); data concerning health; data concerning a person’s sex life; and data concerning a person’s sexual orientation.

Please note that we do not knowingly or intentionally collect sensitive personal data or information about criminal convictions from individuals and that you should not submit sensitive data to us.

If, however you do submit sensitive data to us, such as if you make this sensitive data available to other users of the Services (such as by publishing it through any forum feature we may make available from time to time) we will assume that you have purposefully made any such sensitive data manifestly public.

Location services/data

The Services will request your consent to use location services to precisely identify your location each session (i.e. each time the Services is opened or has been placed in the background for more than 30 seconds We do this in order to to verify the location of your business

If you do not provide your consent, you may use the Services but that will mean the “maps” feature on the Services will not be available. To withdraw your consent at any time you can turn off the localisation permissions for our app on your device.

The location services in the Services will not operate unless location services/data are generally enabled on your device. You may disable such functionality at any time by turning your device’s location on “off” using the device’s settings app. When you allow your device to use location services/data, data will also be collected by Google in accordance with their Privacy Policy, as this is the map service we integrate to our app.

We exert no control over Google’s Privacy Policy and we therefore recommend that you consult their privacy policy for further information on how Google protect personal data please visit their site – https://policies.google.com/privacy?hl=en-US. For more information see the section ‘Who we share your personal data with’ below.

How your personal data is collected

We collect personal data from you directly when you sign up to the Services, contact us directly or reach out to us via social media, make submissions via the Services when a forum element is available, or indirectly, such as your activity while using the Services.

At this point in time, we do not collect any personal information about you using cookies or similar technologies. In the event that this were to change and if we were to decide to collect personal data about you using cookies, you would be notified of this change by means of in-app notification, with detailed information regarding our use of cookies and similar technologies to be made available in the relevant cookies policy.

How and why we use your personal data

We use your personal data for the following purposes:

  • Providing services: To operate, deliver, and improve the App and its features.
  • Financial tracking: To record income, savings, and loan transactions.
  • Loan applications: To assess eligibility, process applications, and share information with financial institutions you select.
  • Identity and fraud prevention: To verify identity, detect fraud, and enhance security.
  • Customer support: To respond to enquiries and provide assistance.
  • Communications: To send updates about your account, our terms, or our services.
  • Legal compliance: To meet legal, regulatory, and audit obligations in the UK and in countries where services are delivered (including Liberia).
  • Analytics: To conduct anonymised statistical analysis to improve services.
  • Marketing (with consent): To send you promotional messages, which you can opt out of at any time.

Legal Grounds for Using Your Data

Under data protection law, we may only use your personal data where we have a valid legal basis, such as:

  • Where you have given consent.
  • To comply with legal or regulatory obligations.
  • To perform a contract with you (or take steps before entering into a contract).
  • For our legitimate interests or those of a third party. A legitimate interest means we have a business or commercial reason to use your data, provided this is not overridden by your rights and interests. We carry out balancing assessments when relying on this basis, which you can request by contacting us (see How to Contact Us).

Marketing

We intend to send you email marketing to inform you of our services such as promotions.

We will always ask you for your consent before doing sending you marketing communications, except where you have explicitly opted-in to receiving email marketing from us in the past or except where you were given the option to opt-out of email marketing when you initially signed up for your account with us and you did not do so.

You will have the right to opt out of receiving marketing communications at any time by:

  • contacting us at support@eshango.co
  • using the ‘unsubscribe’ link included in all marketing emails you may received from us

We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.

For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.

Who we share your personal data with

We may share your personal data with selected third parties. Whenever we do so, we ensure sharing complies with the UK GDPR and other relevant data protection laws.

Service Providers

We routinely share data with trusted service providers who help us operate our business and deliver the Services, including:

  • Developers, hosting, storage, and security providers who support the App.
  • Google Maps (Google, Inc.) for location functionality. We do not control Google’s privacy practices and recommend you review their Privacy Policy.

We only allow service providers to handle your data where we are satisfied they apply appropriate protections. They are bound by contractual obligations to use your personal data only for providing services to us (and to you).

Other Third Parties

We may also share your data, where necessary, with:

  • Financial institutions: To provide access to savings and loan services.
  • Professional advisers: Such as auditors, lawyers, or consultants, who are bound by confidentiality obligations.
  • Regulators, authorities, and law enforcement: To meet legal or regulatory requirements.
  • Courts or tribunals: Where disclosure is legally required.
  • Corporate transactions: In connection with a merger, acquisition, restructuring, asset sale, IPO, or insolvency. Wherever possible, information will be anonymised, and recipients will be subject to confidentiality obligations.

For location services, we use Google Maps, which collects data in accordance with Google’s Privacy Policy: Google Privacy Policy.

How long your personal data will be kept

We will keep your personal data for as long as you have an active account with us and for a period of up to 6 years thereafter to comply with any accounting or legal obligations including in the event of the pursuit or defence of legal claims. Once you have closed your account with us, we will move your personal data to a separate database so that only key stakeholders in our business on a ‘need to know basis’ have access to such data.

Following the end of the of the aforementioned retention period, we will delete or anonymise your personal data.

Transferring your personal data out of the UK

We may transfer your personal data outside the United Kingdom (UK) and European Economic Area (EEA). Where we transfer your personal data outside of the UK and the EEA, we will only do so for the purposes mentioned in this Policy and any contract that we have entered into with you or the entity that you are representing.

Countries outside of the UK and the EEA do not have the same data protection laws as the UK and EEA. Therefore, when making such a transfer of data, we will always rely on a safeguard mechanism under the UK GDPR and/or the EU GDPR. We will only transfer your personal data to a country which the European Commission or the UK authorities have given a formal adequacy decision/regulation that confirms this third-country provides an adequate level of data protection similar to those which apply in the UK and EEA. If the third-country does not have an adequacy decision awarded to it, any transfer of your personal information will be subject to entering into the European Commission’s Standard Contractual Clauses (the SCCs) which are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal data.

Transfers of personal data from the UK to the EEA shall be done on the basis of the adequacy regulation awarded to the European Union by the UK pursuant to the withdrawal of the UK from the European Union which was granted in June 2021.

If you would like further information please contact us using the details provided at the end of this Policy. We will not otherwise transfer your personal data outside of the UK and the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

Your rights

You generally have the following rights, which you can usually exercise free of charge. For more information regarding these rights, please visit the ICO website here.

Access to a copy of your personal data

The right to be provided with a copy of your personal data.

Correction (also known as rectification)

The right to require us to correct any mistakes in your personal data.

Erasure (also known as the right to be forgotten)

The right to require us to delete your personal data—in certain situations.

Restriction of use

The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data.

Data portability  

The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.

To object to use

The right to object:

  • at any time to your personal data being used for direct marketing (including profiling)
  • in certain other situations to our continued use of your personal data, e.g. where we use you personal data for our legitimate interests.

Not to be subject to decisions without human involvement

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

We do not make any such decisions based on data collected by the Services.

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.

If you would like to exercise any of those rights, please complete a request form—available on our website at [insert link] or email , call or write to us—see below: ‘How to contact us’. When contacting us please:

  •         provide enough information to identify yourself (e.g., your full name and username) and any additional identity information we may reasonably request from you, and
  •         let us know which right(s) you want to exercise and the information to which your request relates

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

How to complain

Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner.

The Information Commissioner can be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.

Changes to this privacy policy

We may change this privacy policy from time to time. When we make significant changes we will take steps to inform you, for example via the Services or by other means, such as email.

How to contact us

You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:​

  • support@eshango.co