Acceptable Use Policy
Preamble
This Acceptable Use Policy ("AUP") applies to everyone who accesses the Ustawi platform — tenant staff, field collection agents, and any other authorized user — and is incorporated into the Terms of Service (/legal/terms-of-service). Violating this AUP may result in suspension of the offending user's access or, for serious or repeated violations, suspension of Customer's account.
1. Permitted Use
- Using the Service to originate, service, and collect loans or savings products your institution is legally authorized to offer.
- Configuring loan products, branches, and staff roles for your own institution's legitimate operations.
- Exporting your own institution's data for your own regulatory filings and business purposes.
- Using the mobile field-collection app for genuine borrower visits within your assigned branch/route.
2. Prohibited Use
- Attempting to access another tenant's data. Each tenant's data is isolated in its own database; attempting to probe, access, or exfiltrate another tenant's data by any means is a severe violation.
- Circumventing AML/KYC controls — e.g. structuring transactions to avoid sanctions/PEP screening, disabling or ignoring screening alerts without documented resolution, or "tipping off" a subject of a Suspicious Transaction Report.
- Falsifying records — e.g. backdating loan documents, fabricating collection visit GPS data, or misrepresenting collateral valuations.
- Circumventing dual-control (maker-checker) approval flows on sensitive role grants or other actions designed to require a second authorizer.
- Unauthorized data export or sharing — extracting borrower PII, KYC documents, or loan data for purposes outside your institution's legitimate business, or sharing platform credentials/device-bound sessions with unauthorized individuals.
- Using the Service for unlawful lending practices — e.g. usurious rates prohibited by law, lending to ineligible or sanctioned individuals, or discriminatory lending practices.
- Interfering with platform security — attempting to bypass device-trust/device-binding controls, probing for vulnerabilities without following the Vulnerability Disclosure Policy (/legal/vulnerability-disclosure-policy), or introducing malware.
- Excessive automated use that degrades Service performance for other tenants (e.g. unauthorized scraping or bulk API abuse outside agreed integration terms).
3. Staff & Field Agent Conduct
Field agents must only capture GPS location data during legitimate collection visits and must not misrepresent their location. Staff must not share device-bound login sessions and must report a lost/stolen device immediately so it can be revoked from the device-trust registry.
4. Monitoring & Enforcement
Ustawi logs sensitive actions via full audit logging and may investigate suspected AUP violations, including reviewing audit-log entries. Ustawi may suspend an individual user's access immediately where there is reasonable suspicion of a severe violation (e.g. cross-tenant access attempts, AML circumvention), pending investigation, and will notify Customer's designated admin promptly.
5. Reporting a Violation
Customer admins or any user who suspects an AUP violation should report it via /contact or legal@ustawi.co.tz. Security vulnerabilities specifically should go through the Vulnerability Disclosure Policy (/legal/vulnerability-disclosure-policy) instead.
6. Consequences of Violation
Depending on severity: a warning and required remediation; suspension of the individual user's access; suspension or termination of Customer's account per the Terms of Service; and, where the violation involves unlawful activity, referral to relevant authorities.
Frequently asked questions
Can staff share login credentials?
No — see Section 3.
What happens if a user violates this policy?
See Section 6 for the range of consequences by severity.
How do I report suspected misuse?
See Section 5 — use /contact, or the Vulnerability Disclosure Policy for security issues specifically.