- Wakandi is committed to safeguarding the privacy of visitors to our website and the users of our application (“our services”).
- We recognize the importance of protecting your privacy in respect of your personal information as defined in the relevant legislation collected by us when you use our services.
- “Personal information” means any information which uniquely identifies you, and includes information such as your name, email address, telephone number, MSISDN, biometric information and password, banking as well as any other personal data collected.
2. Personal Information we may collect
The information we collect about you and how we collect it can vary depending on the specific services that you use and subscribe to, how you have used the services, and how you have interacted with us even if you aren’t a customer, or what we have obtained from a third party with permission to share it with us.
2.1. We may get your personal information when you
- Transact with your mobile money wallet or acquire any other service from us.
- Register for a specific service (with your name and email address, mobile money wallet).
- Subscribe to newsletters, alerts, or other services from us.
- Ask us for more information about our services, or contact us with a question or complaint.
- Take part in a competition, prize draw, or survey.
- Access our application or visit our website.
- Visit other websites after or before you visit our website under the permissions by law.
2.2. The information about you that we may collect and process includes but is not limited to the following:
- Your name, date of birth, home language, address, account information, and email address.
- Your preferences for particular services or lifestyle activities when you tell us what they are – or when we assume what they are, depending on how you use our services.
- Your contact information.
- Your account information.
- How you use our services.
- The device or phone numbers that you use to access our services.
- The level of service you receive.
- Your browsing information including information about the websites you visit, and how you use our website on your device.
- The date, time, and length of your internet browsing, and your approximate location at the time of browsing.
2.3 By continuing to use this website:
- Breach Notification- Where there are reasonable grounds to believe that your personal information has been accessed or acquired by any unauthorized person, we will notify you and the relevant regulator, unless a public body responsible for detection, prevention, or investigation of offenses or the relevant regulator informs us that notifying you will impede a criminal investigation.
3. How and when will we process your personal information?
3.1 We may use and analyze your information to:
- Process services, and keep you updated on the services including any updates thereto.
- Keep you informed generally about new products and services (unless you choose not to receive our marketing messages).
- Provide the relevant service or product to you. This includes services that use information about where you are when using your mobile equipment (location information) and to contact you with messages about changes to the service or product.
- Contact you with offers or promotions based on how you use our products and services. This includes calling and messaging details, location information, and browsing information (unless you choose not to receive these messages).
- Bill you for using our products or services, or to take the appropriate amount of credit from you.
- To administer our website and our application and help us improve our services.
- Respond to any questions or concerns you may have about using our services.
- Promote other companies’ products and services we think may interest you including offers and discounts we’ve specially negotiated for our customers.
- Protect our application and its network and manage the volume of transactions. For example, we identify peak periods of use so we can try and ensure the application can handle the volume at those times.
- Understand how you use our application, products, and services. That way, we can develop more interesting and relevant products and services, as well as personalize the products and services we offer you.
- Carry out research and statistical analysis including monitoring how customers use our application and services on an anonymous or personal basis.
- Prevent and detect fraud or other crimes, recover debts or trace those who owe us money.
- Provide aggregated reports to third parties (such reports do not contain any information which may identify you as an individual).
- Training purposes.
3.2. The relevant device information we use may include:
- Your approximate device location.
- Your telephone number, if you access our websites or apps.
We’ll store your information for as long as we have to by law. If there’s no legal requirement, we may only store your information in the interest of the security of our customers, third parties, and other subsidiaries.
4. Sharing of your personal information
- You consent that we may disclose your personal information to approved third-party providers where necessary.
- You agree that once your information has been de-identified, i.e.: delete any information that identifies you, personal information may be shared under the following circumstances:
- Our agents, advisers, service providers, and suppliers (our SEO agency, creative, brand, digital and media agencies, Microsoft, Google, and other research agents).
- Partner companies of Wakandi, including partners or agents involved in delivering the products and services you’ve ordered or used.
- Partners or agents that conduct network performance and customer satisfaction surveys and any other surveys related to or services provided to you.
- Credit reference, fraud prevention or business scoring agencies, or other credit scoring agencies.
- Debt collection agencies or other debt recovery organizations.
- Law enforcement agencies, regulatory organizations, courts, or other public authorities if we have to, or are authorized to by law.
- To protect us against fraud, defending our rights or property, or protecting the interests of our customers;
- Third parties making legitimate requests for the purpose of protecting or exercising their rights in terms of the applicable legislation and upon production of the supporting documentation in respect thereof.
- Other businesses and companies if we’re reorganized or sold to another organization, we may transfer any personal information we hold about you to that organization.
5. Unauthorised access to your information
Despite the security measures we have in place to protect your personal information (firewalls, password access, and encryption methods) you acknowledge that it may be accessed by an unauthorized third party, e.g. as a result of illegal activity.
We cannot accept responsibility for any unauthorized access or loss of personal information that is beyond our control.
We’ll never ask for your personal or account information by an unsolicited means of communication. You’re responsible for keeping your personal and account information secure and not sharing it with others.
We will immediately notify you of a security breach relating to your personal information.
6. International data transfers
This policy is based on applicable legislation and data protection laws of the Republic of Kenya. Your data will be stored securely in the Republic of Kenya. Given that we operate in various African countries, communications between subsidiary companies, third parties may result in the transfer of information across international boundaries.
This may happen if our servers or suppliers and service providers are based outside the Republic of Kenya, or if you use our products and services while traveling to other countries. Other countries may not have appropriate or stringent data protection laws, however, we will make sure that your information is protected and enter into appropriate agreements to achieve this.
In any case of international data transfer related to our products and services done by us, we will fully comply with the applicable data protection laws of that country. We aim to ensure the proper safety and security of the personal data that we store on our servers.
7. Your rights
- You have the right to withdraw your consent for us to process your personal information at any time. The withdrawal of your consent can only be made by you on the condition that:
- It does not affect the processing of your personal information before the withdrawal of your consent; or
- It does not affect the processing of your personal information if the processing is in compliance with an obligation imposed by law on us; or
- It does not affect the processing of your personal information where such processing is necessary for the proper performance of a public law duty by a public body; or
- It does not affect the processing of your personal information as required to finalize the performance of a contract in which you are a party; or
- It does not affect the processing of your personal information as required to protect your legitimate interests or our own legitimate interests or the legitimate interests of a third party to whom the information is supplied.
- You have the right to object to the processing of your personal information at any time, on reasonable grounds relating to your particular situation, unless the processing is required by law.
- You can make the objection if the processing of your personal information is not necessary for the proper performance of a public law duty by a public body; or if the processing of your personal information is not necessary to pursue your legitimate interests; our legitimate interests or the legitimate interests of a third party to which the information is supplied.
- You have the right to object to the processing of your personal information, at any time, if the processing is for purposes of direct marketing by means of unsolicited electronic communications and you have not given your consent for that processing.
- You have the right not to have your personal information processed for purposes of direct marketing by means of unsolicited electronic communications from third parties unknown to you.
- You have the right not to be subjected to a decision that is based solely on the basis of the automated processing of your personal information intended to provide a profile of you.
- Decisions that you may not be subjected to are decisions that result in legal consequences for you or affect you to a substantial degree:
- Without being for the execution of a contract that you have received performance for; or
- Decisions made that are not in terms of law or of a code of conduct that specifies what appropriate measure must be taken to protect your legitimate interests.
- You have the right to submit a complaint to Kenya’s data protection authority about an alleged interference with the protection of personal information processed in accordance with this policy.
- We may place a cookie on your browser to store and sometimes track the information referred to the point above.
9. Use of IP address
- An Internet Protocol (IP) address is a number that is automatically assigned to a computer whenever it is connected to the Internet. We log IP addresses or the location of computers on the internet.
- We may collect IP addresses for the purposes of system administration and to audit the use of the website. We do not link IP addresses to personal information unless it becomes necessary to enforce compliance with the policy or to protect our website or its users.
10. Links to other sites
- When you are using the website or our application, you could be directed to other sites that are beyond our control. We are not responsible for the content or the privacy policies of those third-party websites.
- The same applies to any third-party websites or content you connect to using our services.
11. Contact information
- If you-
- wish to notify us of an actual or a suspected data breach; or
- are currently receiving marketing information from us which you would prefer not to receive in the future, please email us at firstname.lastname@example.org.
12. Data Protection Authority
To the extent necessary in terms of the local data laws, Wakandi undertakes to register with the relevant Data Protection Authority and the Information Regulator. The powers, duties, and functions of the office of the Authority include providing education regarding the protection and processing of personal information; monitoring and enforcing compliance with the provisions of local laws and regulations; consulting with interested parties and acting as a mediator; receiving, investigating and attempting to resolve complaints; issuing enforcement notices and codes of conduct; and facilitating cross-border cooperation.
13. Governing law
The laws of the Republic of Kenya will govern any dispute or claim arising out of or relating to your use of this website and our application.