Privacy Policy

Last updated: 19 June 2026

This Privacy Policy explains how Komjey ("we", "us") handles information in connection with the Komjey microloan and lending management platform (the "Service"). It applies both to the people who hold a Komjey account (operators) and to the borrower data that operators store in the Service.

1. Roles

When you create an account, we are the controller of your account data. When you, as an operator, enter information about your customers (borrowers), you are the controller of that borrower data and Komjey acts as a processor that stores and processes it on your behalf. You are responsible for having a lawful basis and any consent required to collect and upload it.

2. Account data we collect

To provide and secure your account, we collect:

  • Your email address, username and (optionally) name;
  • A securely hashed password (we never store it in plain text);
  • Your Google account identifier and avatar, if you sign in with Google;
  • Your Telegram chat ID, if you opt in to Telegram reminders;
  • Email-verification tokens and related timestamps, and account created/updated timestamps.

3. Borrower data operators store

Operators may record information about their customers and loans, which can include:

  • Customer name, phone number, address and national ID number;
  • Guarantor name and phone number;
  • Profile photos and photographs of identity documents and collateral, contracts and notes;
  • Loan details (principal, interest, dates and status) and payment history (amounts, dates, methods and balances).

4. How information is used

We use information to:

  • Operate, maintain and secure the Service;
  • Authenticate users and protect against abuse (including with Cloudflare Turnstile);
  • Send reminders about due, due-soon and overdue payments via SMS and Telegram where enabled;
  • Power dashboards, the collection calendar, search indexing and reporting;
  • Create and restore backups of your data.

5. Third-party processors

We share data with service providers only as needed to run the Service, including Google (authentication for Google sign-in), Cloudflare (Turnstile bot protection), and SMS and Telegram providers (delivery of reminders). These providers process data on our or your behalf and are not permitted to use it for their own unrelated purposes.

6. How we protect data

  • Passwords are stored using one-way hashing;
  • Uploaded documents and photos are stored with secure, access-controlled delivery;
  • Email verification helps confirm account ownership;
  • Backups are created on a scheduled basis to prevent loss.

No method of transmission or storage is completely secure, but we work to protect information using appropriate safeguards.

7. Data retention

We retain account and borrower data for as long as your account is active or as needed to provide the Service, and as required to comply with legal obligations, resolve disputes and enforce our agreements. Operators control the borrower records they create and can update or delete them within the Service.

You can request deletion of your account at any time from your account settings. When you do, your account is immediately marked for deletion and you are signed out. For a limited recovery period you can reactivate it by signing back in; if you do not, the account and all associated borrower data and documents are permanently deleted from the Service, except where we are required to retain certain information to comply with legal obligations.

8. Your rights

Depending on your location, you may have rights to access, correct, export or delete personal data. Operators can exercise many of these directly in the Service, including requesting deletion of their account from settings. If a borrower wishes to exercise rights over data an operator holds, they should contact that operator (the controller). For account data, contact us using the details below.

9. Changes to this policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last updated" date above and, where appropriate, provide additional notice.

10. Contact

Questions about this Privacy Policy, or want to report a bug or request a feature? Message us on Telegram at @KoeungKosal.