Privacy Policy

1. Introduction

Prima Finance and Investment (Prima), LLC ("Prima Finance", "we", "our" or "us") is a Class II Microfinance Institution (EMF) licensed by the Ministry of Finance of Cameroon under license No. 000485/MINFI/28/03/2024. Our headquarters are located at Lycee de Biyem-Assi, Yaounde, Cameroon.

This Privacy Policy describes how we collect, use, share and protect your personal data when you use our services, our website https://primamf.com, our Prima Finance mobile application available on Google Play Store and any other related service (collectively, the "Services").

By using our Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with this policy, please do not use our Services.

2. Data we collect

We collect different categories of personal data depending on how you use our Services:

2.1 Identification data

• Last name, first name, gender, date of birth, nationality, place of birth
• Profile photo, electronic signature
• Identity documents (ID card, passport, driver's license) - number, validity dates, front/back photos

2.2 Contact data

• Postal address, city, region, country
• Email address
• Phone number (mobile, landline, WhatsApp, Telegram)
• Designated beneficiary and their contact details

2.3 Professional and financial data

• Occupation, employer, industry
• Declared monthly income, source of income
• Account history, transactions, deposits, withdrawals, transfers
• Credit applications, guarantees, loan simulations
• Bank details and Mobile Money account numbers (MTN MoMo, Orange Money)

2.4 Technical data (mobile app and website)

• Unique device identifier, model, operating system, app version
• IP address, internet service provider, connection type
• Usage logs, pages visited, actions performed, connection dates and times
• Session identifiers, authentication tokens
• Push notification tokens (Firebase Cloud Messaging) to send you alerts related to your account

2.5 Location data (optional)

With your explicit consent, we may collect your approximate or precise geographic location to point you to the nearest Prima Finance branch or to prevent fraud. You can withdraw this consent at any time in the app settings.

2.6 Biometric data (optional)

If you enable biometric authentication (fingerprint, face recognition) on the mobile app, this data remains on your device and is NEVER transmitted to our servers. It is used only by your operating system to unlock the application.

2.7 Communication data

• Exchanges with our customer service (email, SMS, WhatsApp, contact form, FINAP chatbot)
• Customer service call recordings (after clear notice)
• Responses to satisfaction surveys

3. How we use your data

We use your personal data for the following purposes:

• Verify your identity and comply with our Know Your Customer (KYC) obligations imposed by COBAC, MINFI regulations and Cameroonian law on anti-money laundering and counter-terrorism financing
• Create, manage and maintain your accounts (savings, current, salary, fixed deposit)
• Execute the transactions you request (deposits, withdrawals, transfers, bill payments)
• Evaluate your credit application and assess your repayment capacity
• Provide personalized customer service and answer your questions through all our channels (FINAP chatbot, WhatsApp, email, phone, branch)
• Send you transactional notifications (deposit, withdrawal, transfer confirmations, balance alerts)
• Send you, with your consent, our newsletter and information about our products, services and events
• Detect and prevent fraud, identity theft attempts and suspicious operations
• Improve our Services, measure their use and develop new features
• Comply with our legal, regulatory and tax obligations (COBAC, ANIF, MINFI, tax declarations)
• Respond to any legally formulated judicial or administrative request

4. Legal basis for processing

We process your personal data based on:

• Contract performance — the provision of banking products and services you have subscribed to
• Legal obligation — KYC, anti-money laundering, regulatory reporting, accounting retention
• Consent — newsletter, marketing, geolocation, contact via WhatsApp/Telegram. You can withdraw your consent at any time
• Legitimate interest — fraud prevention, system security, Services improvement

5. Sharing your data

We NEVER sell your personal data. We may share it only in the following cases:

• Regulatory authorities — COBAC, MINFI, ANIF, BEAC, tax administration and any authority legally entitled to access it
• Service providers — hosting (Hetzner / Infomaniak), email delivery (Infomaniak SMTP), SMS and WhatsApp delivery (WaSender), push notifications (Firebase), electronic signature (Documenso). These providers are contractually bound to protect your data
• Financial partners — Mobile Money operators (MTN MoMo, Orange Money), partner banks (Afriland First Bank), solely to execute the transactions you request
• Strategic partner SGC Investment Group — for Trade Finance, Project Finance, Infrastructure Finance and Corporate Finance products that Prima Finance distributes, and only with your explicit consent
• Legal or judicial obligation — judicial requisition, court decision, criminal or tax investigation
• Merger / acquisition operation — in the event of transfer or restructuring, your data could be transferred to the successor, subject to equivalent protection commitments

6. Data retention

We retain your data for the following periods:

• Active account data: throughout the duration of the contractual relationship
• After account closure: 10 years (legal accounting and COBAC regulatory obligation)
• Commercial prospecting data: 3 years after the last active contact
• KYC documents (ID card, passport): 10 years after account closure
• Application technical logs: 12 months
• Geolocation data: immediate deletion after use, not retained

7. Your rights

In accordance with applicable Cameroonian and international legislation (notably Law No. 2010/012 of December 21, 2010 on cybersecurity and cybercrime and Law No. 2010/021 of December 21, 2010 governing electronic commerce in Cameroon), you have the following rights:

• Right of access — obtain a copy of your personal data
• Right of rectification — correct inaccurate or incomplete data
• Right to erasure — request the deletion of your data, within the limits permitted by regulations (for example, the 10-year retention is mandatory)
• Right to object — object to processing for legitimate reasons or for marketing purposes
• Right to restriction — request the temporary suspension of processing
• Right to portability — receive your data in a structured, machine-readable format
• Right to withdraw consent — at any time, for processing based on consent
• Right to define post-mortem directives — concerning the retention, deletion and communication of your data after your death

To exercise these rights, contact us at support@primamf.com or by mail at the headquarters address. Proof of identity may be required. We respond within a maximum of 30 days.

8. Security

We implement appropriate technical and organizational measures to protect your data against unauthorized access, modification, disclosure or destruction:

• TLS 1.3 encryption for all communications between your device and our servers
• Encryption of sensitive data at rest (Documenso encryption keys)
• Strong authentication via password + OTP (one-time password) by SMS or email
• Optional biometric authentication on the mobile app (fingerprint, face)
• Data segregation, role-based access control, sensitive action logging
• Regular encrypted backups, business continuity plan
• Continuous system monitoring, intrusion detection, regular security patch updates
• Regular training of our employees in security best practices

No system is completely infallible. In the event of a breach likely to result in a high risk to your rights, we will inform you as soon as possible and notify the competent authorities in accordance with our legal obligations.

9. Cookies and similar technologies

Our website uses cookies and similar technologies for:

• Strictly necessary cookies: session, security, language preferences. They cannot be disabled.
• Audience measurement cookies: to understand site usage and improve it. Subject to your consent.

Our mobile app does not use cookies in the classic sense but stores local data (authentication tokens, preferences) on your device. You can delete this data by uninstalling the app.

10. Minors

Our Services are not intended for persons under 18 years of age, except minor accounts opened by a legal representative in compliance with our KYC procedures. We do not knowingly collect personal data from minors without the verifiable consent of the legal representative.

If you believe that a minor has transmitted their data to us without authorization, contact us immediately at support@primamf.com so that we can proceed with their deletion.

11. International transfers

Your data is primarily stored in Cameroon and Europe (Infomaniak Switzerland, Hetzner Germany) with providers offering an adequate level of protection.

Some providers (Google Firebase for push notifications, Documenso for electronic signature) may process your data outside the CEMAC zone. In this case, we ensure that equivalent contractual guarantees (standard contractual clauses, certification) are in place.

12. Changes to this policy

We may modify this Privacy Policy to reflect legal, technical or business changes. The last update date appears at the top of the document.

In case of substantial modification (for example, new purpose or new recipient), we will inform you by email and/or by notification in the application 30 days before the entry into force. Your continued use of the Services after this date will constitute acceptance of the modifications.