PYCS (“we” or “us” or “our”) respects the privacy of our users (“user” or “you”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our mobile application and website (the “Application”). Please read this Privacy Policy carefully. 

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the “Last updated” date of this Privacy Policy. You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Application after the date such revised Privacy Policy is posted.

This Privacy Policy (“Policy”) therefore explains our privacy practices with respect to how we process your Personal Data and describes your rights as a user of any of our services and Platforms.   Our Online Platform – Privacy Policy applies to all our Platforms, and all related sites, applications, services and tools regardless of how they are accessed or used.  

Data/Information means any information relating to you, including your name, identification number, location data, online identifier address, photo, email address, pins, passwords, bank details, posts on our Platforms, religion, date of birth, health, race/tribe, nationality, ethnicity, political views, trades union membership, criminal records, medical information, and other unique identifiers such as but not limited to MAC address, IP address, International Mobile Equipment Identity (IMEI) number, Bank Verification Number, International Mobile Subscriber Identity (IMSI) number, Subscriber Identification Module (SIM) and others. It also includes factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity.   

Process/Processing means any operation or set of operations which is performed on your Personal Data or sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. 

CONSENT 

We kindly request that you carefully read through this Policy and click on the ‘Agree’ icon below, if you consent to the terms of this Policy, particularly with respect to the processing of your Personal Data. That notwithstanding, if you proceed to use any of our Platforms and services, it will be deemed that you have provided your express consent to the terms of this Policy.  

AGE 

You must be at least 18 years old to use our services or any of our Platforms. Individuals under the age of 18, or applicable age of maturity, may utilize our Platforms services only with involvement of a parent or legal guardian, under such person’s account. Regardless, all Personal Data which we may process shall be in accordance with this Policy and other applicable laws.  

COLLECTION OF YOUR INFORMATION

We may collect information about you in a variety of ways. The information we may collect via the Application depends on the content and materials you use, and includes:

Personal Data: Demographic and other personally identifiable information (such as your name and email address) that you voluntarily give to us when choosing to participate in various activities related to the Application, such as chat, posting messages in comment sections or in our forums, liking posts, sending feedback, and responding to surveys. If you choose to share data about yourself via your profile, online chat, or other interactive areas of the Application, please be advised that all data you disclose in these areas is public and your data will be accessible to anyone who accesses the Application.

Financial Data: Financial information, such as data related to your payment method (e.g. valid mobile money account details) that we may collect when you register, apply for a loan, or request information about our services from the Application. We store only very limited, if any, financial information that we collect. Otherwise, all financial information may be stored by our payment processor or third parties and you are encouraged to review their privacy policy and contact them directly for responses to your questions.

Data from Social Networks: User information from social networking sites, such as social media sites that your mobile app connects to, including your name, your social network username, location, gender, birth date, email address, profile picture, and public data for contacts, if you connect your account to such social networks. This information may also include the contact information of anyone you invite to use and/or join the Application.

Geo-Location Information: We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using the Application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.

Mobile Device Access: We may request access or permission to certain features from your mobile device, including your mobile device. If you wish to change our access or permissions, you may do so in your device’s settings.

Mobile Device Data: Device information such as your mobile device ID number, model, and manufacturer, version of your operating system, phone number, country, location, and any other data you choose to provide.

Push Notifications: We may request to send you push notifications regarding your account or the Application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.

Third-Party Data: Information from third parties, such as personal information or network friends, if you connect your account to the third party and grant the Application permission to access this information.

Data From Contests, Giveaways, and Surveys: Personal and other information you may provide when entering contests or giveaways and/or responding to surveys.

PROCESSING YOUR INFORMATION  

In order to execute our obligations to you or process your transactions, we may be required to process your Information, such as your name, account number, account ID, e-wallet account, contact details, shipping and billing address, or other information needed to complete the transaction. We also work with third parties, including financial institutions, vendors, service providers, who at one point or the other facilitate transactions executed on our Platforms. For completeness, in the course of your engagement with us or use of our services and Platforms, we may share your information with different stakeholders, including but not limited to Financial institutions; service providers; Credit bureaus and collection agencies to report account or credit information; PYCS (including subsidiaries and affiliates); Regulatory or judicial authorities; or other third parties pursuant to a subpoena, court order, or other legal process or requirement applicable to PYCS. Please note that the parties mentioned above may be within or outside your country of residence.  

We may also process your Information when we believe, in our sole discretion, that the disclosure of your Information is necessary to comply with applicable laws and judicial/regulatory orders; conduct investigations; manage existing or imminent risks, prevent fraud, crime or financial loss, or for public safety or to report suspected illegal activity or to investigate violations of our Terms and Conditions.  In all cases, we will ensure that your Information is safe, and notify the receiving party of the confidential nature of your Information, particularly the need to maintain the confidentiality of the same and prevent unlawful or unauthorised usage.   

YOUR RIGHTS 

You have the following rights regarding your personal information collected by us:  

1. 1. 1. 1. Right to access your personal information being held by us. Request for such information may be sent to dpo@pycs.co.ke
         2. Right to request that your personal data be made available to you in an electronic format or that it should be sent to a third party (Kindly note that we have the right to decline such request if it is too frequent, unreasonable, and likely to cause substantial cost to us. In any event, we will communicate the reason for our refusal);
         3. Right to rectify any inaccurate, incomplete information. As such, if you discover any inaccuracy in your personal information, kindly notify us promptly and provide us with documentary evidence to enable us to update the requisite changes; 
         4. Right to withdraw consent for the processing of your information, provided that such withdrawal shall not invalidate any processing hitherto done based on the consent previously given by you; 
         5. Restrict or object to the processing of your personal data if we may be compelled to process your data where required under law, regulatory authorities, or court of law;
         6. Right to request that your personal data be deleted. We may however continue to retain the information where required under law, contract, regulatory authorities, or court of law.
         7. Right to data portability;
         8. Right to lodge complaints with relevant authorities;  
         9. Right to information regarding the existence of automated decision-making, including profiling and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing;   

SOFTWARE  

If you download or use our software, such as a stand-alone software product, an app, or a browser plugin, you agree that from time to time, the software may download and install upgrades, updates and additional features from us in order to improve, enhance, and further develop the software. 

USING YOUR PERSONAL INFORMATION

In the course of your engagements with us or through our Platforms, we collect personal information for various legal reasons, largely to enable us to personalize your experience and to provide a more efficient service to you. Some of the reasons we collect Information are to:  

1. 1. 1. 1. provide services and customer support;  
         2. process transactions, payment requests, and send notices about transactions;  
         3. create an account with us for the provision or use of our services; 
         4. verify customers’ identity, including during account creation and password reset processes;  
         5. manage your account and provide you with efficient customer service, 
         6. resolve disputes, process payments and troubleshoot problems; 
         7. manage risks, or to detect, prevent, and/or remediate fraud, violation of policies and applicable user agreements or other potentially prohibited or illegal activities; 
         8. execute our contractual obligations to you;  
         9. improve our services and functionality by customizing user experience;  
         10. measure the performance of our services and improve their content and layout;  
         11. manage and protect our information technology infrastructure;   
         12. provide targeted marketing and advertising, provide service or transaction update notices, and deliver promotional offers based on communication preferences;  
         13. obtain a means by which we may contact you; either by telephone, text (SMS), email messaging, social media, etc;  
         14. conduct background checks, compare information for accuracy and verify same with third parties; 
         15. identify or address a violation and administer our policies and terms of use; p. comply with legal, contractual and regulatory obligations; 
         16. execute your specific requests or use the same for a specific purpose as you may instruct;
         17. investigate and respond to your complaints or enquiries; 
         18. process your access to our services, Platforms, or functions from time to time;    
         19. Assist law enforcement and respond to judicial orders.
         20. Compile anonymous statistical data and analysis for use internally or with third parties.
         21. Deliver targeted advertising and other information regarding promotions and the Application to you.
         22. Monitor and analyse usage and trends to improve your experience with the Application.

If we intend to use any Personal information in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal information is required and obtain your consent. Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you via the Application to: Administer promotions, and contests.

If we intend to use any Personal information in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal information is required and obtain your consent.

STORAGE AND PROTECTION OF YOUR DATA 

We protect your personal Information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of our safeguards include ensuring that sensitive data are encrypted and stored with only authorised users having access to this information. Access to our various platforms is restricted to authorized users only. 

Your Information is also stored on our secure servers as well as secure physical locations and cloud infrastructure. All information is stored in data centres which are collocated out of our office environment, this is to ensure security of data and also availability of data when required.   

We will take all necessary measures to ensure that your Personal Data is safe, however, you are also required to ensure that access codes, PINs, passwords, usernames, and all other information or hints that may enable third party access to your accounts on our Platforms are secure. We therefore strongly advise you to keep such information secure and confidential. If you use a third party’s device (laptops, phones, public internet, etc.) to access your account, kindly ensure that you always log out. Kindly note however that certain devices are programmed to save passwords or usernames, as such, we therefore advise that you use third party devices with extreme caution. If you believe that an unauthorized person has accessed your information, please contact us immediately. 

DISCLOSURE OF YOUR INFORMATION

We may share information we have collected about you in certain situations. Your information may be disclosed as follows:

By Law or to Protect Rights: If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.

Third-Party Service Providers: We may share your information with third parties that perform services for us or on our behalf, including credit reference check with duly licensed CRBs and other third-party lending institutions, payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance.

Marketing Communications: With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by law.

Third-Party Advertisers: We may use third-party advertising companies to serve ads when you visit the Application. These companies may use information about your visits to the Application and other websites that are contained in web cookies in order to provide advertisements about goods and services of interest to you.

Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners, share transfer parties in a sale for shares in the company or other companies that we control or that are under common control with us.

Business Partners: We may share your information with our business partners to offer you certain products, services or promotions.

Social Media Contacts: If you connect to the Application through a social network, your contacts on the social network will see your name, profile photo, and descriptions of your activity.

Other Third Parties: We may share your information with advertisers and investors for the purpose of conducting general business analysis. We may also share your information with such third parties for marketing purposes, as permitted by law.

Sale or Liquidation: If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity. If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur and that the transferee may decline honor commitments we made in this Privacy Policy.

We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly.

TRACKING TECHNOLOGIES

Cookies and Web Beacons: We may use cookies, web beacons, tracking pixels, and other tracking technologies on the Application to help customize the Application and improve your experience. When you access the Application, your personal information is not collected through the use of tracking technology. Most browsers are set to accept cookies by default. You can remove or reject cookies, but be aware that such action could affect the availability and functionality of the Application. You may not decline web beacons. However, they can be rendered ineffective by declining all cookies or by modifying your web browser’s settings to notify you each time a cookie is tendered, permitting you to accept or decline cookies on an individual basis.

Internet-Based Advertising: Additionally, we may use third-party software to serve ads on the Application, implement email marketing campaigns, and manage other interactive marketing initiatives. This third-party software may use cookies or similar tracking technology to help manage and optimize your online experience with us. We shall however have opt out mechanisms for this which you can implement should you wish not to receive this kind of advertisement.

Website Analytics: We may also partner with selected third-party vendors to allow tracking technologies and remarketing services on the Application through the use of first party cookies and third-party cookies, to, among other things, analyze and track users’ use of the Application, determine the popularity of certain content, and better understand online activity. By accessing the Application, you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their privacy policy and contact them directly for responses to your questions. We do not transfer personal information to these third-party vendors.

You should be aware that getting a new computer, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings.

THIRD-PARTY WEBSITES

The Application may contain links to third-party websites and applications of interest, including advertisements and external services, that are not affiliated with us. Once you have used these links to leave the Application, any information you provide to these third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from the Application.

SECURITY OF YOUR INFORMATION

We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.

THIRD PARTY CONTRACT & SERVICE PROVIDERS DATA POLICY 

Data transfer to third parties 

We may share your personal data with our service providers, financial institutions, vendors, affiliates, subsidiaries, parent company, contractors, etc to assist us in providing, delivering, analysing, administering, improving, and personalizing content that is delivered to you as part of our services. These include third parties who assist us in performing, delivering, or enhancing certain products and services related to the delivery and operation of our services; or who provide technical and/or customer support on our behalf; or who provide application or software development and quality assurance; or who provide verification functions, who process transactions and payment requests, research on user demographics, interests, and behaviour, and other products or services. These third party service providers may also collect personal information about or from you in performing their services and/or functions on our website or Platforms. We may also pass certain requests from you or your organization to these third-party service providers. Regardless of the third-party involved, any disclosure shall only be for a lawful purpose.   

Data transfer for the purpose of legal/regulatory compliance 

We may from to time be required to share your personal data with a regulator, law enforcement body, government agency, court or other third party to (i) comply with the law; (ii) enforce the terms of a contract; and (iii) protect the rights, property, or safety of PYCS.  

Links to third-party websites or services 

This Policy only applies to Information collected by our site/Platforms or which we transfer in the course of our services to you. Our site and platforms may contain links to other websites or services that are not owned or controlled by us, including links to websites of financial or technical partners, financial institutions, vendors, advertisers, sponsors, partners, service providers, who at one point or the other facilitate transactions executed on our Platforms.  

We have no control over these third-party websites, and your use of third-party websites and features are subject to the privacy policies of those websites or platforms. We are not responsible or liable for the privacy or business practices of any third-party websites linked to our site or third-party social media feature or functionality displayed on our site, including, but not limited to Facebook, LinkedIn, Twitter, etc. Your use of third-party websites linked to our sites is at your own risk, therefore, we encourage you to read the privacy policies of any linked third-party websites or platform you access through or outside our sites or platforms. If you are dissatisfied with the privacy policy or data protection standard of such a third party, you are at liberty to exit such a site/platform.  PYCS will not be responsible for any damage, loss or liability caused to you on those third-party sites or platforms.   

Security of shared information 

We will not share your Information with any third party until we obtain an undertaking (implicit or explicit) that they will take appropriate steps to implement appropriate security measures by themselves, their employees, officers, affiliates, and sub-processors to protect your Information and prevent unauthorized disclosure or loss. We will also ensure that such third parties commit themselves to the statutory and contractual obligation of confidentiality, as may be stipulated in a non-disclosure agreement, privacy policy, confidentiality clauses, etc. We will also obtain an undertaking that such a third party will comply with the applicable data protections laws in force, and that it will under no circumstances use your Information for any unlawful purpose or purpose other than that for which the Information was disclosed.   

PYCS will from time to time monitor and review the conduct or activities of these third parties to ensure that they are compliant with the confidentiality obligations imposed on them.   

EXCEPTIONS 

Please note that this Privacy Policy does not apply to Information that is already in the public domain through no fault of ours.   

VIOLATION 

If you violate the letter or spirit of this Policy, or otherwise create risk or possible legal exposure for us or attempt to violate the privacy rights of PYCS and/or its other users, we reserve to restrict your access to our Platforms. We will notify you if we are constrained to take such a decision. 

OPTIONS REGARDING YOUR INFORMATION

Account Information

You may at any time review or change the information in your account or terminate your account by: 

• • • Logging into your account settings and updating your account
    • Contacting us using the contact information provided below

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

Emails and Communications

If you no longer wish to receive correspondence, emails, or other communications from us, you may opt-out by: 

• • • Noting your preferences at the time you register your account with the Application
    • Logging into your account settings and updating your preferences.
    • Contacting us using the contact information provided below

If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.

CONTACT US

If you have questions regarding your data privacy rights or would like to submit a related data privacy right request, kindly contact us via the information below:  If you have questions or comments about this Privacy Policy, please contact us at:

dpo@pycs.co.ke