PERSONAL DATA THAT WE MAY COLLECT
When you register with us, you are only required to provide your mobile phone number to us. You may also provide other personal data such as your age, gender, email address, name, location and profession to us should you wish to access certain Services.
HOW WE USE YOUR PERSONAL DATA
You agree and consent to us processing, collecting, using and disclosing personal data held about you for the following purposes:
To process, administer and/or manage the Services;
Your phone number, which will be verified, will be used for identification purposes as your Application ID;
To verify your identity;
To connect you with other parties as enabled by the Service;
To provide you with any Services that you may request from us from time to time and to communicate with you in relation to those Services;
To deliver to you any administrative notices, updates, notifications, alerts and communications relevant to your use of the Service;
To facilitate the delivery of our and third party advertising on or through the Services tailored to your benefit or interests;
To store, host and/or back up (whether for disaster recovery or otherwise) your personal data, whether within or outside Kenya.
For record-keeping purposes:
To conduct research, analysis and development activities (including but not limited to data analytics, surveys and/or profiling) to improve the Services in order to enhance the Services provided to you;
To responding to legal process, pursuing legal rights and remedies, defending litigation and managing any complaints or claims;
To respond to requests for information from public and governmental / regulatory authorities, statutory boards, related companies and for audit, compliance, investigation and inspection purposes;
To comply with any applicable law, regulation, legal process or government request.
(Collectively, the “Purposes”).
WHO WE DISCLOSE YOU’RE PERSONAL DATA TO
You agree and consent that your personal data may be used, disclosed, maintained, accessed, processed and/or transferred to the following third parties, whether sited in Kenya or outside of Kenya, for one or more of the Purposes:
Our shareholders, subsidiaries and group companies;
Our business partners, customers and advertisers;
Third party vendors or service providers which require the processing of your personal data, for example, third party service providers which have been engaged by us to : (i) to provide and maintain any IT equipment used to store and access your personal data; (ii) to host and maintain the Application, the Services and/or our website; or (iii) otherwise in connection with the provision of the Application and/or the Services;
Our auditors and legal advisors;
Financial institutions, credit card companies and payment processors;
Public and governmental / regulatory authorities, statutory boards, industry associations;
Courts and other alternative dispute forums; or
Any third party in connection with (i) the sale of any of our business or assets, in which case we may disclose your personal data to the prospective buyer of such business or assets; or (ii) the acquisition of us or substantially all of our assets by a third party, in which case personal data held by us about you and our other customers will be one of the transferred assets.
(Collectively, the “Permitted Parties”).
In certain circumstances we may provide third parties (whether or not located in Kenya) with aggregate information about the subscribers or users of the Application and/or the Services. This may include information about your Device, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our customers and advertisers. This is anonymised statistical data about our subscribers’ or users’ actions and patterns, and does not identify any individual.
THIRD PARTY WEBSITES
In addition, our website and SMS sent to you may, from time to time, contain links to and from the websites of our business partners, customers and advertisers or other third parties (the “Third Party Websites”). If you follow a link to any of these Third Party Websites, please note that these Third Party Websites have their own privacy policies. As these Third Party Websites are not owned or operated by us, we do not accept any responsibility or liability for the contents of these Third Party Websites and their privacy policies and you access and provide your personal data to these Third Party Websites at your own risk. Please check these policies before you submit any personal data to any such Third Party Websites.
DISCLOSURE OF THIRD PARTY PERSONAL DATA
If you choose to disclose the personal data (including the telephone number) of any third party to us in the course of your use or access of the Services, you hereby represent and warrant that you would have, prior to disclosing such personal data to us, informed these third parties that their personal data will be disclosed to, and obtained the consent from these Individuals for their personal data to be disclosed to, us for one or more of the Purposes.
ACCURACY OF PERSONAL DATA
Where you submit personal data on the Application, you should try to ensure such personal data is accurate, and let us know if such personal data changes so that we are not holding any inaccurate personal about you.
PROTECTION OF PERSONAL DATA
We will protect personal data in our possession or under its control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. However, you acknowledge and agree that no method of transmission over the telecommunications networks or the Internet, or method of electronic storage, is 100% secure.
You may withdraw your consent for us to use your personal data for one or more of the Purposes by writing to our Data Protection Officer using the contact details below. However, please note that your failure to supply certain personal data to us (or if we are not permitted by you to process your personal data), may/would result in us being unable to provide you with the Application and the Services. Depending on the extent by which you do not permit us to process your personal data or the extent of personal data which you do not provide to us, it may mean that we will not be able to provide you with the Application and the Services.
You may request to access and/or correct the personal data currently in our possession by writing to the Data Protection Officer using the contact details provided below. Please note that we may charge you a reasonable fee for the handling and processing of your requests to access your personal data.
DATA PROTECTION OFFICER