AFRISEND PRIVACY POLICY

We may collect, record and use information about You in physical and electronic form and will hold, use and otherwise process the data in accordance with the Data Protection Act and as set out in this Privacy Policy.

The personal data we collect and process may include, among others:

• Your name;
• Your contact information such as Your email address and telephone number;
• Your demographic information such as date of birth, age, gender;
• Evidence of Your identity (for example passport or national identify card information);
• Geolocation data such as your country and city of residence
• unique identifiers such as username, account number and password;
• Your profiles and postings on any other social media applications and services that we provide or that You make available to us;
• Your payment details or other financial data, e.g. Your bank or payment method provider’s name, or your account number, sort code and billing address; and
• information about Your visit to our website, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.

We also collect from You information in relation to other people (e.g. details of the recipients of Your money transfers), where You provide us with such information. By providing us with such information You confirm that You have obtained any necessary permissions from such persons to the reasonable use of their information for such purposes in accordance with this notice, or are otherwise permitted to give us this information on their behalf. Please also ensure that those other people are aware of this notice and that the provisions of this notice are clearly communicated to them.

• Information You give to us when You use our services. If You use our services You will need to provide certain information including Your name, address and card number, as well as the name and other details the recipients of the money transfers that you instruct us to carry out.
• Other information You give to us. This is information about You that You give us by filling in forms on our site (e.g.: the ‘contact us’ section) or by corresponding with us by phone, e-mail or otherwise. It includes, for example, information You provide when You register on the site for us to contact You, and when You report a problem with our site. The information You give us may include, among other data, Your name and e-mail address.
• Social Media. Depending on Your settings or the privacy policies for social media and messaging services such as Facebook, LinkedIn and Instagram, You might give us permission to access information from those accounts or services.
• Information we collect about You
  • Cookies - like most websites, we use "cookies" to help us make our site – and the way You use it – better. Cookies mean that a website will remember You. They're small text files that sites transfer to Your computer (or phone / tablet). They improve website use and speed – for example by automatically filling Your name and address in text fields.
  • Log Files - In addition, with regard to each of Your visits to our site, we will automatically collect certain information (e.g.: browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data). We may combine this automatically-collected log information with other information we collect about You.
  • Social Media Widgets - Our website includes Social Media Widgets or Features, such as the Facebook Like button and Twitter button which are interactive mini-programs that run on our site to provide specific services from another company (e.g.: displaying the news, opinions, music, etc). Personal information, such as Your email address, may be collected through the Widget. Cookies may also be set by the Widget to enable it to function properly. Information collected by this Widget is governed by the privacy policy of the company that created it.

Our primary purpose in collecting user information is to provide You with a safe, smooth, efficient and customized experience and to provide the services You have requested from us. We may also use the information that You have provided to ensure that the content on our site is presented in the most effective manner for You and Your computer device.

We use Your information for the following specific purposes: -

• to carry out our obligations arising from any contracts entered into between You and us or from applicable law, and to provide You with the services in accordance with our terms and conditions and with this Privacy Policy;
• to register You with a Afrisend account;
• to fulfil Your Transaction / (Airtime Top Up) Request;
• to send You confirmations;
• to notify You about changes to our services;
• to prevent fraud;
• to ensure that content from our site is presented in the most effective manner for You and for Your computer;
• to send You marketing communications, provided that You have given us Your contact details in the course of a sale (or of negotiations for a sale) of our products or services and that You do not decide to opt out from this type of communications, in accordance with Data Protection Legislation;
• to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• as part of our efforts to keep our site and our services safe and secure;
• to measure or understand the effectiveness of advertising we serve to You and others, and to deliver relevant advertising to You;
• to make suggestions and recommendations to You and other users of our site about services that may interest You or them; and
• to display personal testimonials of satisfied customers on our website in addition to other endorsements, where You have agreed with a third-party review site that we may do so. If You wish to update or delete Your testimonial, You can contact us using this form.

The law permits us to process Your personal data in the way we do because processing is:

• necessary for the purposes of the legitimate interests that we pursue, which are:
  • to run and administer our business;
  • to prevent fraud;
  • to provide You with our services;
  • to evaluate, develop or improve our services;
  • to keep You informed about relevant products and services You are using;
• to discharge our legal obligations to store and disclose information where necessary; and/or
• to provide You with an efficient and smooth customer experience;
• necessary for the performance of our contract with You to provide You with our services;
• necessary in order to comply with a legal obligation to which we are subject; or
• permitted by You, because You have given us consent.

The following categories of recipients may receive Your personal information and process it for the purposes outline in this Privacy Policy:

• We may disclose data to provide our services, to respond to legal requirements, enforce our policies, liaise with judicial or regulatory authorities where required under applicable law, and protect our rights and property.
• The personal information You provide to us may also be shared with third party companies, agents, contractors, service providers or related companies, including without limitation:
  • with credit reference agencies to verify Your identity or recipients of the money transferred through the Service, if this is necessary to provide You with our services, respond to Your enquiries or for any other related purposes, and
  • with fraud prevention agencies who may use it to prevent fraud and money-laundering and to verify Your identity (please note that those who commit fraud can be refused services, finance or employment.
  • Banks, payment card processors and other service providers that process bank transfers, credit and debit card payments or otherwise provide financial infrastructure services to enable us to provide our services;
  • Our service providers, including those who provide data hosting services, fraud prevention services; technology services, and technology tools that allow us to monitor, test and improve our services, sites and Mobile Apps;
  • with regulators or public authorities in order to fulfill regulatory, legal or professional obligations.
• We may also share Your personal information with:
  • other companies we have instructed to provide services to or for us;
  • other third parties for those purposes that may be reasonably ascertained from the circumstances in which the information was submitted;
  • other business entities, should we plan to merge with, or be acquired by, or be invested in by that business entity, or if we undergo a corporate re-organisation;
  • any successor in interest, in the event of a liquidation or administration of Afrisend; and
  • to any other third party, but only subject to Your prior consent.

Our website may contain links to other sites, including via our social media buttons. While we try to link only to websites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other websites and a link does not constitute an endorsement of that website.

Once You link to another website from our website You are subject to the terms and conditions of that website, including, but not limited to, its internet privacy policy and practices. Please check these policies before You submit any data to these websites.

We ensure that there are appropriate technical, physical, electronic, and administrative safeguards in place to protect Your personal details from unauthorised access. When You enter certain information such as a debit or credit card number on our order forms, we encrypt the transmission of that information using reasonable security measures. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.

Unfortunately, the transmission of information via the internet (including by email) is not completely secure. Although we will do our best to protect Your personal data, we cannot guarantee the security of Your data transmitted to our site; any transmission is at Your own risk. Once we have received Your information, we will use strict procedures and security features to try to prevent unauthorised access.

We will only keep the information we collect about You for as long as required for the purposes set out above, or as required to comply with any legal obligations to which we are subject. This will involve us regularly reviewing our files to check that information is accurate, up-to-date and still required.

The period for which we will retain information about You will vary depending on the type of information and the purposes that we use it for. In general, we will keep our records for up to seven (7) years after you have terminated your relationship with us, in order to comply with our legal obligations.

Data that You submit via our site is sent to You and stored on secure servers owned by, or operated for, us in Kenya. Data may be transferred to, or stored at, a destination outside Kenya and may also be processed by one of our service providers, agents or contractors. Such transfers may be made in order to operate the service, improve our site, or to assist in our security or fraud protection activities.

Where recipients are outside Kenya, we ensure that they provide adequate level of protection for Your personal data or that the transfer is otherwise permitted under applicable Data Protection Legislation, by methods including using standard contractual clauses, binding corporate rules, or in accordance with applicable Data Protection Legislation.

Where we feel it is necessary or appropriate, we may seek to rely on Your consent as the legal basis for transferring Your personal data to outside Kenya, however we do not generally do so. Where we do, You may withdraw Your consent at any time.

Where required by Data Protection Legislation, You will be given a choice when You provide us with Your personal information to opt in or opt out of receiving marketing communications.

You have the option of "unsubscribing" from our mailing list for marketing communications, alerts and updates at any time, thereby disabling any further marketing e-mail communication from being sent to You.

Details of how to unsubscribe will be included on each electronic mailing we send You.

We will action any opt out request from You without delay.

At any time, You have the right:

• to be informed about the processing of Your personal data (i.e., for what purposes, what type of personal data, to what recipients it is disclosed, storage periods, any third-party sources from it was obtained, confirmation of whether we undertake automated decision-making, including profiling, and the logic, significance and envisaged consequences). Reading this Privacy Policy forms part of Your right to be informed;
• to request access to or a copy of any personal data which we hold about You;
• to rectification of Your personal data, if You consider that it is inaccurate or not up-to-date;
• to ask us to delete Your personal data, if You consider that we do not have the right to hold it;
• to withdraw consent to our processing of Your personal data (to the extent such processing is based on previously obtained consent);
• to ask us to stop or start sending You marketing messages at any time by using the below contact details;
• to restrict processing of Your personal data;
• to data portability (moving some of Your personal data elsewhere) in certain circumstances; and
• to object to Your personal data being processed in certain circumstances.

You can contact us if you want to enforce any of these rights. We will comply with our legal obligations as regards Your rights as a data subject.

Any request for access to Your personal data must be in writing and we will endeavour to respond within a reasonable period and in any event within one month (three months for complex or numerous requests), in compliance with Data Protection Legislation. We reserve the right to charge a reasonable fee (reflecting the costs of providing the information) or to refuse to respond where requests are manifestly unfounded or excessive: in this case, we will explain the situation to You and we will inform You about Your rights.

We aim to ensure that the information we hold about You is accurate at all times. To assist us in ensuring that Your information is up to date, You will need to let us know if any of Your personal details change. Upon Your request, we will take reasonable steps to ensure that the data is accurate, and we will rectify any personal data that is incorrect promptly and in any case within one month of Your request.

Any changes we make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to You by e-mail. Please check back frequently to see any updates or changes to our Privacy Policy.

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to:

Afrisend Money Transfer Ltd,
Stellato Building,
1st Floor, Muthithi Road,
Nairobi, Kenya
Email: dataprivacy@afrisend.com

You may also use these contact details if You wish to make a complaint to us relating to Your privacy.