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Privacy Policy

Privacy Policy – MoMani
Effective Date: March 11, 2026 (last updated)

  1. Introduction

MoMani (a brand of Zenka Finance Limited, also referred as “we”, “us”) is a digital financing provider specialized in smartphone and phone financing. With the MoMani app you can manage your financed phone loan, make repayments, monitor your loan status, and receive support related to your financing agreement. More information about the MoMani app can be found in our Terms of Use and the Services Agreement.

This policy explains what personal information we collect, how it is used and shared, and how you can control it. Please read this policy carefully. If you have any questions, feel free to contact us using the details provided at the end of this Policy.

We do not knowingly collect data from children under 18. You must be at least 18 to use the Services.

By accepting this Privacy Policy you certify that all the provided information is true and correct to the best of your knowledge, and that you will immediately notify MoMani of any inaccuracies or changes in the data provided.

  1. Data Categories

Your privacy is of utmost concern to us. We use your personal data to provide the Services, improve quality, send notifications, protect rights, and comply with laws. We collect the following categories of data:

  • Identity Data: name, photograph, ID number, date of birth, gender.
  • Contact Data: address, email, telephone number.
  • Demographic Data: marital status, employment status.
  • Financial Data: bank details, payment information, M-Pesa statement, income and employment history, loan repayment history, credit Reference Bureau (CRB) data, tax PIN (in some cases).
  • Loan Data: payments and loan history.
  • Technical Data: IP address, device identifiers (including IMEI or serial number of the financed phone to bind it to your loan account and enable device locking), browser type, operating system, etc.
  • Profile Data: username, transaction history, credit information, income details.
  • Usage Data: app usage, interaction data, location data, behavioral data.
  • Device data: contact list, SMS and call logs (where permitted), SIM card details, OS version, model.
  • Marketing and Communications Data: preferences, email, phone number.
  1. How we Use Your Data

Please see a description of how we use your data below.

Purpose/Activity Type of data Lawful basis
Register you as a new customer / process phone financing application Identity, Contact Performance of contractual obligations
Process repayments, manage fees, monitor loan and credit status Identity, Contact, Financial, Transaction, Loan, Usage Performance of contract
Link the financed smartphone to your account and to support the device locking feature in case of non-repayment Device information Performance of contractual obligations
Enforce financing agreement (including activating device lock on financed phone if repayments are overdue) Identity, Contact, Technical, Device Performance of contractual obligations
Manage relationship with you (notifications, surveys) Identity, Contact, Profile Performance of contractual obligations, legal obligation
Administer and protect business (troubleshooting, fraud prevention) Identity, Contact, Technical Performance of contractual obligations, legal obligation
Deliver marketing and improve services via analytics Identity, Contact, Usage, Technical, Marketing and Communication Performance of contractual obligations and consent (where applicable)
Loan enforcement Identity, Contact, Financial, Transaction, Loan, Usage Performance of contractual obligations
Credit scoring Identity, Contact, Financial, Transaction, Loan, Usage Performance of contractual obligations, legal obligation
Comply with legal requirements (such as AML, security, accounting, verifying usage with Uganda) All categories Legal obligation
Respond to requests and claims All categories Performance of contractual obligations, legal obligation

The provision of all the personal data is mandatory, where the law requires it, and non-provision may be followed by the applicable legal sanctions. In all other cases, the provision of your personal data to us is required to be able to provide you with the requested services.

  1. Sharing of Your personal data

We may share your data with:

  • Debt collection agencies (for recovery or enforcement of device-related obligations).
  • Credit reference bureaus.
  • Mobile money providers.
  • Members of the Sun Finance Group,
  • Service providers (marketing, fraud prevention, payment processing, device management support, IT).
  • Government or law enforcement when required by law.

Where we need to transfer your data outside Uganda — for example, for cloud storage or credit scoring analysis —we will ensure:

  • The recipient country has adequate data protection laws, or
  • We have data protection agreements in place with the recipient, or
  • We have obtained your explicit, informed consent before such transfer
  • Your personal data will only be transferred in compliance with the Data Protection and Privacy Act, 2019.

We may also receive Your personal data from third parties, for example, (credit bureaus, mobile money providers, government agencies, employers, business associates).

  1. Your Rights and Obligations
  • Request access to your data.
  • Request correction or erasure of your personal data.
  • Object to processing or request restriction the usage of your personal data.
  • Request to ensure portability of your personal data.
  • Withdraw consent where you have given such consent (such withdrawal may affect our services, including device unlocking capability).
  • Lodge a complaint with the National Information Technology Authority of Uganda (NITA-U).

You must keep your data accurate and inform us of changes promptly (at least within 3 days of the corresponding change). To exercise rights and inform us about the changes, contact us at the details below. We will respond within reasonable timeframes.

  1. Retention Term

We retain data as long as necessary for the purposes, legal requirements, or to defend claims. After the relationship ends, basic information is kept for legal periods. You can request deletion where applicable.

  1. Data Controller and Contacts

Zenka Finance Limited (trading as MoMani) is the data controller of your personal data.

You may contact us (the controller) for privacy questions, data requests, or complaints by using the following details:
Email: info@momani.co.ug
Phone / SMS: +256 (0) 205479830 You can also reach our Data Protection Officer at dpo@zenka.co.ug (shared group contact).

  1. Changes to this Policy

We may update this Policy. Updated versions will be posted in the MoMani App or on our website. Continued use after changes constitutes acceptance.

  1. Consent and authorizationBy downloading and using the MoMani App, you hereby give the following consents and authorizations:
    – consent to the collection and processing of your personal information as described in the Privacy Policy and the Data Protection and Privacy Act, Cap 97, and the Regulations thereunder
    – authorization for MoMani to verify and investigate provided information. For this purpose, you consent to the processing of any personal information and records relating to you that might be obtained from third parties, including government agencies, employers, credit bureaus, business associates and other entities we may deem proper and sufficient in the conduct of the proper verification process