Kopasmart Privacy Policy

Kopasmart Privacy Policy

Effective Date: 2nd August 2024

Kopasmart, a product of Kingdom Bank Limited, together with its associated entity duly incorporated in Kenya, respects your privacy and is committed to protecting your personal data. This privacy policy explains how we collect, use, and share your personal information, and your rights regarding the data we hold.

Introduction

KopaSmart Lending offers short-term loans to eligible customers. These terms and conditions govern your use of the KopaSmart Lending service.

Scope of the Data Processing Terms and Conditions

These Data Processing Terms and Conditions, together with our Terms of Use and Loan Account Agreement, apply to your use of:

  • 1. Kopasmart mobile application software (App) available on our site or hosted on the Google Play Store (App Site), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).
  • 2. Any of the services accessible through the App (Services) or those available on the App Site or other sites of ours or other third-party sites (Service Sites).

This Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Loan Terms

Loan terms include the loan amount, interest rate, and repayment period. These terms will be provided to you before you accept any loan offer.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By downloading the App, you confirm that you have read, understood, and accepted the terms of this Policy set out hereunder. You also consent to the collection, use, storage, processing, and disclosure of your personal information by us and other Third-Party Providers in the manner set out in this Policy. You also authorize us to obtain your information from Third Party Providers in accordance with the terms of this Policy.

You can withdraw your consent to our collection, processing, or use of your personal information at any time by making a request at dataprotection@kingdombankltd.co.ke or via a contact link on the App.

Information We May Collect From You:

Information You Give Us (Submitted Information)

This information may include your name, address, email address, phone number, the Device's phone number, SIM card details, age, username, password, financial and credit information (including your mobile money account details, bank account details, and bank verification number, where applicable), personal description, and photograph.

This information may be collected through:

  • Filling in forms in the App or on the App Site.
  • Corresponding with us (e.g., by email or chat).
  • Registering to use the App Site, downloading or registering the App, subscribing to any of our Services (such as applying for a loan), searching for an app or Service, sharing data via the App's social media functions, entering a competition, promotion or survey, and reporting a problem with the App, our Services, our App Site, or any of our Service Sites.

Information We Collect About You and Your Device

Each time you visit one of our Sites or use one of our Apps, we may automatically collect the following information:

  • Technical Information: Including your Device's phone number, SIM card details, the type of mobile device you use, information about the SIM card used by the Device, mobile network information, your Device’s operating system, the type of browser you use, or your Device’s location and time zone setting (Device Information).
  • Content Information: Including information stored on your Device, such as SMS logs.
  • Log Information: Including details of your use of any of our Apps or your visits to any of our Service Sites, including traffic data, location data, weblogs, and other communication data.

Unique Application Numbers

We or our marketing partners or analytics providers may use mobile tracking technologies and/or website cookies to distinguish you from other users of the App, App Site, or Service Sites. This helps us provide you with a pleasant experience when you use the App and allows us to improve our services.:

Tracking and Cookies:

  • Payment Company Providers, Banks, Identity Verification Companies, Credit Reference Agencies, Debt Collection Companies, Value Added Services Providers, Government Departments and Agencies, Marketing Lists, Employers, and Mobile Network Operators (“Third Party Providers”)..

Uses Made of the Information

The information we collect from you or from Third Party Providers is used and processed for:

  • Contractual Purposes: Providing services to you, determining service eligibility, and communicating with you regarding services.
  • Lawful Obligations: Identification, validation, verification, payment processing, compliance with regulatory duties, risk analysis, and troubleshooting, collection of loans and any amount outstanding from you, compliance with any risk, regulatory duty or lawful obligation including responding to regulators or supervisors, carrying out anti-money laundering investigations, record-keeping obligations.
  • Legitimate Interests: Fraud detection, improving services, offering rewards, collaborating with Third Parties, marketing, and advertising.

Consent

We may process your information where you expressly give consent for a specific purpose or where we have legal obligations to do so. If you do not provide the requested information, we may not be able to offer you our loan services.

Disclosure of Your Information

We may disclose or share your information with:

  • Members of our Group (subsidiaries, affiliates, holding company).
  • Agents, vendors, advisors, and third-party service providers.
  • Regulators, supervisors, or anti-money laundering and fraud prevention authorities.
  • Financial institutions, identity verification companies, and mobile network operators.
  • In the event of a proposed merger, acquisition, or transfer of our business or assets.
  • Third parties providing referrals, targeted marketing, or lead generation services.

Save in compliance with an order of the Court, Arbitral Panel, Tribunal, Regulatory Directive, or Order or any other legal or regulatory obligation, we do not disclose information about identifiable individuals to other parties.

Where We Store Your Personal Data

Due to the nature of our operations and business, we store and process your information in Kenya. All information you provide to us is stored in Kenya and on our secure servers. We maintain a high level of data security and protection and we will continue to ensure high security and technical measures and safeguards that guarantee the safety of your information.

Data Security

We implement appropriate security measures to protect your personal data from unauthorized access, alteration, or destruction. This includes physical, managerial, and technical measures, employee training, threat intelligence monitoring, and firewalls. Our information security policies and procedures are designed in strict accordance with international standards and are reviewed and updated regularly. We implement and maintain appropriate safeguards to protect information, considering in particular the risks to you, presented by unauthorized or unlawful processing or accidental loss, destruction of, or damage to their personal data. We require the same level of security to be maintained by our Third-Party Providers.

Your Rights

As a data subject, you have the following rights under the Data Protection Act:

  • Access your personal data.
  • Object to our processing of your personal data.
  • Request the correction or deletion of any data we may have about you.
  • Receive your personal data in a structured, commonly used, and machine-readable format.
  • Request that we transmit your data to another data controller or processor.
  • Request reasons if your application for a service has been denied.

You can exercise any of these rights by sending a written request to dataprotection@kingdombankltd.co.ke.

Data Protection Principles

When we process your personal data, we adhere to the following principles:

  • Lawfulness, Fairness, and Transparency: Process data legally, fairly, and transparently.
  • Purpose Limitation: Collect data for specified, explicit, and legitimate purposes.
  • Data Minimization: Ensure data is adequate, relevant, and limited to what is necessary.
  • Accuracy: Keep data accurate and up to date.
  • Storage Limitation: Retain data only as long as necessary.
  • Integrity and Confidentiality: Process data securely to prevent unauthorized access, loss, or damage.

Retaining Your Information

We retain and use your data only as long as necessary to implement, administer, and manage your requests and contracts, or as required to comply with legal or regulatory obligations. We may retain your data for a minimum of seven years even after receiving a request for deletion to comply with regulatory obligations.

Transfer of Personal Data Outside Kenya

We do not transfer your personal data outside Kenya.

Changes to Terms and Conditions

Any changes we make to these Terms and Conditions in the future will be posted on this page and, where appropriate, notified to you when you next start the App or log onto one of the Service Sites. The new terms may be displayed on-screen, and you may be required to read and accept them to continue using the App or the Services.

Contact Us

For any inquiries or to exercise your rights, contact us at:

Data Protection Officer
Kingdom Bank Limited
Kingdom Bank Towers
Argwings Kodhek Road, Kilimani
P.O. Box 22741 – 00400 Nairobi, Kenya
Email: dataprotection@kingdombankltd.co.ke