All those subject to this policy are referred to as “users” or ‘you’ for purposes of this policy. Money254 is referred to as ‘our’ or ‘we’.
In this policy we will explain the following:
It is the individual user’s responsibility to read through the following provisions in order to gain a thorough understanding of Money254’s views and practices relating to the user’s personal data and how it will be treated.
Version 1.0 March/2021
This policy is subject to change based on legislative changes, need or in response to changes in our working arrangements. Any changes to this policy will be approved by the authorized officers and updated on the website with the update being communicated to you in the event of significant changes.. Older versions of the Policy will be available on the website.
This document contains information on how Money254 collects, uses, and processes personal data and is for distribution to all individuals who share their personal data with Money254.
Money254 will collect information through;
a) Information provided by the individual user about the user themselves (Submitted Information).
b) correspondence with Money254, by email or instant message or chat or other means of communications.
c) information which is to include information provided by the individual user when they share data when subscribing to any of Money254’s Services, share data through the website’s social media capabilities, enter a competition, promotion or survey, when the user may decide to report a problem with the website, Money254’s Services, or any of Money254’s other websites.
d) when you access, use or visit our website or third-party websites.
When you visit one of Money254’s websites, the following information may be automatically collected:
a) Information that is identifying in nature when you contact Money254 or subscribe to our services which includes name, gender, age, email address, telephone number, social media names or handles.
b) Information relating to the individual user’s use of any of Money254’s Apps or any visits by the user to any of Money254’s websites. This includes but is not limited to location data, IP address and other device ID, traffic data, web browser and/or device type, weblogs and other data (Log Information).
c) Other data we may collect from your interaction with us includes financial information such as income brackets.
We may collect special or sensitive data about you such as gender/sex, financial information. Where we collect such information, we shall collect, process and store that data in accordance with the provisions of the Data Protection Laws as provided in clause 11 below.
We may use website cookies in an effort to distinguish the individual user from other users of the App, App Site, or Service Site. This assists us in providing you with a positive experience when you use our website and also gives us the tools to continuously improve the website. You may modify your cookie preferences on the website when prompted to do so. If you delete, or choose not to accept cookies from the Services, you may not be able to utilize the features of the Services to their fullest potential.
We may include or offer third-party products or services on our application or website. We may also provide hyperlinks to third-party sites. These third-party sites are operated by independent entities who have no affiliation to us, who have separate and independent terms, and are only provided to enhance your experience or presented for informational purposes only. We therefore have no responsibility or liability for the content and activities of these linked sites.
Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
We only retain personal data for as long as it is necessary to do so in line with the Data Protection Laws. This means that we retain data:
a) For as long as you continue to use our services
b) For any period required by law.
c) For purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
d) For the purposes of any legal proceedings. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation arising out of our relationship with you.
We may hold anonymized information that is no longer associated with you indefinitely.
With regards to the personal data we collect about you, as a data subject you have the following rights;
a) to be informed of the use to which your personal data is to be put;
b) to access your personal data in our custody;
c) to object to the processing of all or part of your personal data;
d) to correct false or misleading data; and
e) to delete any false or misleading data.
In order to exercise any of the rights of the user Money254 has in place procedures to enable you to do the following:
a) Access personal data held by Money254
b) Object to processing of personal data by Money254
c) Correct or delete false or misleading data held by Money254
d) Restrict of processing of personal data
e) Data Portability
f) Share complaints
g) Get information on automatic individual decision making
To access the procedure please contact the data protection officer/ officer in charge at the following: firstname.lastname@example.org.
You may update and correct your data from the App or website from your device.
We use information we collect in the following ways;
a) To facilitate your access to Money254 services.
b) Responding to any of your queries or concerns.
c) Quality control and ensuring maintenance of optimal system operations.
d) To understand how you use our services, products and services for purposes of developing or improving products or services.
e) We may associate one or more categories of information with any other category of information and this combined information will be treated as personal data in accordance with the provisions set out in this policy, for as long as it is combined.
f) We will use the personal data of the individual user to compile statistics regarding the website user base. Money254 may decide to provide this information to any third party for this purpose, on the condition that the information will always be anonymous.
g) Keeping you informed about new products, services, news or other information related to our services.
h) To administer our online platforms or websites.
i) To comply with any legal, governmental or regulatory requirements or for use in connection with any legal proceedings.
j) Where Money254 would like to utilize your information for the purposes of marketing, you will be informed before such a use takes place. You have the right to prevent a usage of this nature from taking place by informing Money254 that you are opposed to the use of such information for marketing purposes. The user is also entitled to exercise this right at any time by contacting Money254 at email@example.com.
We will process the personal data we collect based on lawful basis allowed under Data Protection Laws being;
a) Your consent;
b) Performance of a Contract or Agreement with you;
c) To support our legitimate business interests;
d) In compliance with a mandatory legal obligation;
e) In your vital interest;
f) Public interest.
We will not share personal information with any other individual, company or organization except in the following cases:
a) Where we have gotten your consent;
b) For legal reasons where there is a court order or a legal obligation which we have to comply with;
c) where it is necessary to do so in order to enforce the Terms and Conditions and other agreements, or where it is necessary in order to investigate potential breaches;
d) In order to publish statistics regarding the website’s usage, where information relating to users will be aggregated and made anonymous.
e) to any member of our business group, which includes subsidiaries, the group’s ultimate holding company and its subsidiaries, developers, partners who are involved in the delivery of Money254 services that you use;
f) Money254 may disclose anonymous aggregate information concerning the users.
g) Any other person we deem legitimately necessary to share the information with.
h) Where we share personal data in the cases listed above we take all necessary steps to ensure that:-
i) The data is processed lawfully;
j) We only disclose what is necessary ;
k) The data is kept secure and all safeguards are put in place to ensure its protection.
You may be required to opt in or give any other form of explicit consent before receiving marketing messages from us. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product, service already taken up.
We will not share your information with any Third Parties for marketing purposes except with your express consent.
We recognize the right of every data subject not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning or significantly affects the data subject.
Therefore we only engage in automated processing where:
a)It’s necessary for entering into or performing a contract between you, the data subject, and the Company.
b) It is authorized by law which we are subject to and lays down suitable measures to safeguard your rights, freedoms and legitimate interests.
c) Where we have gotten your consent.
When we engage in automated processing that affects you we will notify you in writing. You then have 7 days from the day of notification to request that we consider the decision or take a decision that is not based solely on the automatic processing.
Once we receive that request we will consider it and notify you in writing of the steps we have taken to comply with the request and the outcome of complying with the request.
We have put in place technical and operational measures to protect your information from unauthorized access, accidental loss or destruction.
We restrict access to personal information to our employees, contractors, and agents who need that information to process it and facilitate service delivery. Anyone with this access is subject to strict contractual confidentiality obligations.
However, we cannot ensure or warrant the security of any information provided to us by a data subject. We do not accept liability for unintentional disclosure.
In the event of a security breach that involves a data subject’s personally identifiable information we will communicate to the data subject in writing within a reasonably practicable period and take all other action that is necessary to mitigate the breach.
This communication may be limited where it is necessary and appropriate for purposes of prevention, detection or investigation of an offence.
Data which is collected by Money254 from the individual user may be moved to and stored at a location outside Kenya. Staff that operate outside Kenya who are employed by Money254, any member of our business group, or one of our suppliers may be charged with processing the data. Such staff members may be tasked with dealing with requests made by the individual user.
You acknowledge that by submitting your personal data, you accept its transfer, storage or processing.
Money254 notes that the passing of information over the internet is not entirely secure. While Money254 will endeavour to ensure that the individual user’s personal data is protected, the security of the user’s data transmitted to our websites cannot be guaranteed. Any transmission is at the user’s risk. When the individual user’s information has been received, Money254 will use strict security features and procedures in an effort to ensure that unauthorized access does not occur.
All complaints from data subjects regarding the way data is handled will be forwarded to: firstname.lastname@example.org.
A complaint can be made either orally or in writing but where an oral complaint is made the designated officer will as soon as practicable reduce the oral complaint into writing.
We will investigate every complaint that we receive and get back to you within 14 days of receiving the complaint.
If you are not satisfied with the findings you have the right to appeal or to lodge a complaint to the Data Commissioner established under the Data Protection Act of Kenya, 2019.