Contents
- Overview & Architecture
- Financial Non-Intermediation & Regulatory Posture
- Independence & Non-Affiliation Statement
- Information We Do Not Collect
- On-Device Local Data Storage
- Device Permissions & Technical Justifications
- Advertising & Google UMP Consent Framework
- Third-Party Platform Services
- Data Retention & Deletion
- Children's Privacy Protection
- Changes to This Privacy Policy
- Contact & Publisher Information
1 Overview & Architecture
This Privacy Policy explains how Tech2U Savannah ("we", "us", "our") manages information in connection with the LoanTruth: Kenya Loan Cost mobile application (the "Application" or "App", Package: com.tech2u.loantruth).
LoanTruth is built as an offline-first, consumer-empowering comparison calculator designed to help Kenyan borrowers normalize and evaluate the real cost of borrowing (interest, facility fees, excise taxes, access charges) across mobile money credit, digital credit providers, and SACCOs.
2 Financial Non-Intermediation & Regulatory Posture
Strict Informational & Educational Scope: LoanTruth is strictly a financial calculation and comparison utility. It is NOT a lender, Digital Credit Provider (DCP), bank, SACCO, credit broker, loan originator, or loan arranger.
- No Loan Origination: The App does not offer loans, extend credit, process loan applications, or disburse funds.
- No Account Linkage: The App never connects to bank accounts, mobile money wallets (M-Pesa, Airtel Money), or lender customer accounts.
- No Financial Advice: All calculations, APR equivalents, and shilling totals are mathematical estimates based on published tariffs and user-entered scenarios. They do not constitute formal financial, credit, or legal advice.
3 Independence & Non-Affiliation Statement
Independent Analysis: LoanTruth is completely independent. It is not affiliated with, endorsed by, sponsored by, or partnered with Safaricom (Fuliza/M-Shwari), NCBA Bank, KCB Group, Tala, Branch International, Absa (Timiza), the Government of Kenya (Hustler Fund), or any SACCO or financial institution.
All lender product names and figures are used solely as descriptive labels for comparative consumer clarity under fair nominative use. LoanTruth does not accept lender commissions, referral fees, or sponsored rankings.
4 Information We Do Not Collect
In accordance with strict privacy-by-design principles, LoanTruth does NOT collect, transmit, or sell:
- Personally Identifiable Information (PII) such as your name, email, phone number, national ID, or physical address.
- Financial credentials, M-Pesa PINs, bank account numbers, credit card data, or account balances.
- Sensitive device data including contacts, SMS messages, call logs, camera, microphone, or precise GPS location.
- Credit history, credit scores, or borrowing eligibility data.
5 On-Device Local Data Storage
All user preferences, custom rate overrides, and calculation histories are stored exclusively on your physical device using Android's encrypted private application storage (SharedPreferences):
- Custom Rate Overrides: If you manually edit a lender's fee or interest rate, that value is saved only on your device to personalize your future comparisons.
- Comparison History: Any saved calculation history remains strictly on your device and can be cleared instantly in Settings.
- UI Preferences: Theme settings (Light, Dark, or System Default) are stored locally.
This data never leaves your device and is never uploaded to any remote server or cloud database.
6 Device Permissions & Technical Justifications
7 Advertising & Google UMP Consent Framework
LoanTruth is free to use and monetized via non-intrusive advertisements provided by Google AdMob.
To adhere to global privacy regulations including the European Union General Data Protection Regulation (EU GDPR), UK GDPR, Swiss DPA, and California Consumer Privacy Act (CCPA/CPRA), we implement the official Google User Messaging Platform (UMP) SDK.
- Consent Dialog: Users in applicable jurisdictions are presented with a consent form upon launch before any personalized ads are requested.
- On-Demand Revocation: You can review, modify, or revoke your consent preferences at any time by tapping Consent preferences in the app's Settings screen.
8 Third-Party Platform Services
Google Mobile Ads (AdMob) & UMP SDK
Google may collect pseudonymous identifiers (such as Android Advertising ID) and telemetry to deliver relevant advertisements and monitor ad fraud in accordance with your consent preferences.
9 Data Retention & Deletion
Because all scenario inputs and rate customizations are stored strictly on-device, you maintain total control over your data:
- You can reset rate overrides or wipe comparison history at any time from the in-app Settings menu.
- Clearing application storage or uninstalling the app permanently erases all stored preferences and history from your device.
10 Children's Privacy Protection
LoanTruth is intended for adult consumers (ages 18 and older) making informed borrowing decisions. We do not knowingly collect personal data from or direct content to children under 13 (or under 16 in applicable jurisdictions).
11 Changes to This Privacy Policy
We may periodically update this Privacy Policy to reflect app updates, regulatory requirements, or changes to third-party SDK guidelines. Any revisions will be published at this URL with an updated "Last Updated" date.
12 Contact & Publisher Information
Developer: Tech2U Savannah
Email: developer.tech2u@gmail.com
Policy Repository: tech2u-privacy-policies/loantruth