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Mdhamini Terms of Service & Conditions

Mdhamini DATA PRIVACY STATEMENT

Version 2.0 Dated 10th November 2024

Policy Statement

Mdhamini PLC, (this includes all its subsidiaries and regional companies in Kenya, Uganda, Malawi and South Sudan) is committed to protecting the fundamental human right to privacy. Mdhamini respects the personal information and data we collect from you through the different mediums.

This Privacy Statement, applies to personal data that Mdhamini PLC including all its subsidiary companies (“Mdhamini”, “we” “our” “us”, “Mdhamini”) collects and handles for the purposes of maintaining and providing Mdhamini related information to the vis. For the purposes of this Privacy Statement, “Personal data” means any information relating to an identified or identifiable natural person.

Who we are.

Mdhamini of P.O Box 00100 is both a controller and a processor in respect of personal data it processes in connection with the services provided under the relevant engagement with its customers.

What Personal Data Do We Collect About You?

As a Data Controller and a Data Processor, Mdhamini collects personal data directly from the Data Subject or indirectly through intermediaries, service providers and other third parties. We may collect the following personal information.

Where We Collect Personal Information

We use Personal Information to carry out our business activities.  The purposes for which we use your Personal Information will differ based on our relationship (i.e. Members, Employees, Business Partners, Prospective Members, etc.) including the type of communications between us and the services we provide.

We collect Personal Data from various sources, including (depending on the country you are in):

  • Individuals and their family members, online or by telephone, or in written correspondence
  • Individuals’ employers.
  • In the event of a claim, third parties including the other party to the claim (claimant/ defendant), witnesses, experts (including medical experts), loss adjustors, lawyers and claims investigators etc.
  • Credit reference agencies (to the extent Mdhamini is taking any credit risk)
  • Government agencies, such as motor vehicle registration authorities and tax authorities

We obtain your personal data from sources such as;

  • Application forms, Claims Forms, Proposal Forms and other forms that you fill.
  • Software applications (apps) made available by us to you
  • Our Website (mdhamini.codekali.com)
  • Meetings, Telephone conversations and other forms of communication
  • Social Media applications and/or tools

Use of Your Personal Data

Mdhamini may use your personal data for the following purposes.

  • Know your Customer (KYC) and Customer Due Diligence (CDD)
  • Communicating with customers, business partners and employees.
  • Assessing and making determination on provision of financial products or services, employing persons as employees and such other business decisions.
  • Enhancing and improving product and service offering including maintaining information security.
  • To respond to feedback, queries and complaints that you submit through our feedback form.
  • Facilitating business operations including information technology systems.
  • To personalize and improve our services, including to provide or recommend, features, content, and advertisements. Where this is the case, we will take appropriate measures to protect your personal information in accordance with this Privacy Statement.

Legal Justification for Our Use of Personal Data

The primary purpose for collecting and processing your personal data is to perform contractual and statutory tasks related to management of the financial products/solutions you have with us. We will also process your data in connection with other tasks as required by law and statutory regulations. In addition to these, personal data may be used in product and service development.

We commit to always identify and document without prejudice the lawful basis of processing your personal data for each specific purpose and put necessary security measures to ensure safeguarding of your personal data and the lawful purpose consented to always applies.

How We Store and Protect Your Data

We have put in place appropriate physical, legal, technical and organization safeguards to protect the personal data we collect in connection with our services. Such measures include but are not limited to requiring confidentiality from employees and other persons authorize to handle personal data and implementing information technology security measures such as system rights, audit trails and firewalls.

You should be aware that the Internet is not a secure form of communication and sending and receiving information over the Internet carries with it risks including the risk of access and interference by unauthorized third parties. We do not accept responsibility or liability for the confidentiality, security or integrity of your Personal Data in connection with its transmission over the Internet.

Disclosure of Personal Data.

Mdhamini undertakes to keep your personal data confidential and where it is necessary to satisfy the purpose for which it was collected or as may be required by law Mdhamini will share your data with third parties.

In connection with the purposes described above we sometimes need to share your Personal Information with third parties. Please note that in addition to the disclosures we have identified in the table below, we may disclose Personal Data for the purposes we explain in this Privacy Statement to service providers, contractors, agents and Mdhamini companies that perform activities on our behalf.

 

Mdhamini shall not disclose your personal information to any third parties such as service providers other than with your prior consent, for a legitimate reason or for the performance of a contract.

Consent

You understand that by using our site services and our products you agree to be bound by this statement of privacy. If you agree to this statement on behalf of an entity, you represent and warrant that you have the authority to bind that entity to our privacy statement, by using our products and/or accessing our site, if you do not accept it in entirety you must inform us immediately indicating what part of our privacy statement you are not agreeable to.

The affected individual’s consent to this processing of personal information is a necessary condition for Mdhamini to be able to provide the services the client requests. Where you are providing us with information about a person other than yourself, you agree to notify them of our use of their Personal Data and to obtain such consent for us.

Transfer of Your Personal Data

Mdhamini may transfer your personal information for the purpose of effecting/implementing, administering, and securing any product or service that you have applied for or for other purpose set out in this privacy statement.  We may transfer or disclose the personal data we collect to regulatory, or supervisory authority, third party contractors, subcontractors, and/or their subsidiaries and affiliates who provides support to Mdhamini in providing its services. The third-party providers may use their own third-party subcontractors that have access to personal data (sub-processors). It is our policy to use only third-party providers that are bound to maintain appropriate levels of security and confidentiality, to process personal information only as instructed by Mdhamini, and to flow those same obligations down to their sub-processors.

Cross-border Transmission of Your Personal Data

Your data is primarily stored in our data centers located within the country where you are located. From time to time we may need to transfer your personal information outside the country where you are located. This includes countries that do not have laws that provide specific protection to your personal data.

Where we send your information outside the country, we will make sure that there is proof of adequate data protection safeguards in the recipient country or consent from you on transfer of your personal information. Prior to transferring personal data outside the country where you are located, we shall ascertain that the transfer is based on the provided legal and regulatory standards. Circumstances in which we may transfer your personal data outside are highlighted in the table below;

Retention of Personal Data

Personal Data is retained as long as necessary for the purpose for which it is collected and to meet legal, regulatory and operational requirements. Retention periods may differ for each financial product purchased. At the end of the retention period, anonymized data is kept for management information purposes. Mdhamini has also put in place Data retention policy in line with Data Protection law.

Your Data Protection Rights

We will collect, process and store your personal data in accordance with your rights under the Data Protection Act and attendant Regulations. Under certain circumstances, you have the following rights in relation to your personal data:

In exercising your right as provided above, we may request specific information from you to help us confirm your identity. This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Enforcing Your Rights

If you wish to enforce any of your rights as highlighted above as provided under the Data Protection Act and attendant Regulations, then please contact us on our details in clause 16 below. You may use the various statutory forms made available by us and we will respond to your request without undue delay and within the statutory timelines.

Complaints

If you feel we have not complied with your right to privacy and other provided rights regarding your personal data, you have a right to complain to us through the provided tool available on our website or you may pay us a visit and fill the complaint form and we shall endeavor to resolve such a complain. You however have the right to contact the Office of the Data Commissioner or such other data supervisory authority in the jurisdiction we operate in.

Cookies

Cookies are small text files which are stored on your computer when you visit certain web pages. Mdhamini may use cookies and similar technologies on our websites and apps, and in our emails. When you return to the website or app, or visit websites and apps that use the same cookies, they recognize these cookies and your device.

We use cookies to do many different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving your online experience. We also use cookies in some of our emails to help us understand how you interact with our emails, and to help us improve our future email communications. The cookies policy on our websites and apps give you more information on cookies, how and where we use them, and how you can control them.

Changes to This Data Privacy Statement

Mdhamini reserves the right to change the provisions of this Privacy Statement at any time. Where the changes will have a fundamental impact on the nature of the processing of your data or your rights, we shall notify you in advance. We will let you know via email and/or a prominent notice on our Service, prior

to the change becoming effective and update the “effective date” at the top of this Privacy Statement.

Your use of the Website and applications following the posting of such revised Statement shall constitute your acceptance of any such changes. We encourage you to review our Privacy Statement whenever you visit the Website and application(s) to guarantee your understanding of how your information may be collected, processed and used.

Contact Information

If you have any queries relating to your personal data and/or this Privacy Statement, contact us through dataprotection@Mdhamini.co.ke

Our address for purposes of data processing is;

Data Protection Officer

Mdhamini Plc

Mdhamini Plaza, Mara Road, Upper Hill

P.O. Box 59485 – 00200 Nairobi, Kenya

Tel 020 282 3000, 0703 099 120

dataprotection@Mdhamini.co.ke | mdhamini.codekali.com

Terms and Conditions

Mdhamini Cookie Policy

What is a cookie?

A cookie is a small piece of data that a website asks your browser to store on your computer or mobile device. The cookie allows the website to "remember" your actions or preferences over time.

Most Internet browsers support cookies; however, users can set their browsers to decline certain types of cookies or specific cookies. Further, users can delete cookies at any time.

Why do we use cookies?

We use cookies to learn how you interact with our content and to improve your experience when visiting our website(s). For example, some cookies remember your language or preferences so that you do not have to repeatedly make these choices when you visit one of our websites. We also use cookies to help us with geolocation tracking in order to present you with the closest Mdhamini station and office locations. Additionally, cookies allow us to serve you specific content, such as videos on our website(s). We may employ the learnings of your behavior on our website(s) to serve you with targeted advertisements on third-party website(s) in an effort to “re-market” our products and services to you.

What types of cookies do we use?

First-Party and Third-Party Cookies

We use both first-party and third-party cookies on our website.

First-party cookies are cookies issued from the mdhamini.codekali.com/ domain that are generally used to identify language and location preferences or render basic site functionality.

Third-party cookies belong to and are managed by other parties, such as Mdhamini business partners or service providers. These cookies may be required to render certain forms, such as the submission of a job application, or to allow for some advertising outside of the Mdhamini website.

Session Cookies

Session cookies are temporary cookies that are used to remember you during the course of your visit to the website, and they expire when you close the web browser.

Persistent Cookies

Persistent cookies are used to remember your preferences within the website and remain on your desktop or mobile device even after you close your browser or restart your computer. We use these cookies to analyse user behavior to establish visit patterns so that we can improve our website functionality for you and others who visit our website(s). These cookies also allow us to serve you with targeted advertising and measure the effectiveness of our site functionality and advertising.

How are cookies used for advertising purposes?

Cookies and ad technology such as web beacons, pixels, and anonymous ad network tags help us serve relevant ads to you more effectively. They also help us collect aggregated audit data, research, and performance reporting for advertisers. Pixels enable us to understand and improve the delivery of ads to you, and know when certain ads have been shown to you. Since your web browser may request advertisements and web beacons directly from ad network servers, these networks can view, edit, or set their own cookies, just as if you had requested a web page from their site.

Although we do not use cookies to create a profile of your browsing behavior on third-party sites, we do use aggregate data from third parties to show you relevant, interest-based advertising. We do not provide any personal information that we collect to advertisers. You can opt out of off-site and third-party-informed advertising by adjusting your cookie settings. Opting out will not remove advertising from the pages you visit, but, instead, opting out will result in the ads you see not being matched to your interests. This implies that the ad(s) you see will not be matched to your interests by those specific cookies.

How are third party cookies used?

For some of the functions within our websites we use third party suppliers, for example, when you visit a page with videos embedded from or links to YouTube. These videos or links (and any other content from third party suppliers) may contain third party cookies, and we encourage you to consult the privacy policies of these third party vendors on their websites for information regarding their use of cookies.

Mdhamini Privacy Policy

This Privacy Policy explains what personal data is collected when you use the mdhamini.codekali.com/ any mdhamini.codekali.com/ mobile application (“Mdhamini”) and the services provided through it (together the “Service”), how such personal data will be used, shared.

BY USING THE SERVICE, YOU PROMISE US THAT (I) YOU HAVE READ, UNDERSTAND AND AGREE TO THIS PRIVACY POLICY, AND (II) YOU ARE OVER 16 YEARS OF AGE (OR HAVE HAD YOUR PARENT OR GUARDIAN READ AND AGREE TO THIS PRIVACY POLICY FOR YOU). If you do not agree, or are unable to make this promise, you must not use the Service. In such case, you must contact the support team via email to request deletion of your account and data.

“Process”, in respect of personal data, includes to collect, store, and disclose to others.

TABLE OF CONTENTS

1. PERSONAL DATA CONTROLLER

2. CATEGORIES OF PERSONAL DATA WE COLLECT

3. FOR WHAT PURPOSES WE PROCESS PERSONAL DATA

4. AUTHORISED REQUIREMENT FOR PROCESSING YOUR PERSONAL DATA

5. WHO WE SHARE YOUR PERSONAL DATA WITH

6. HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS

7. AGE LIMITATION

8. CHANGES TO THIS PRIVACY POLICY

9. DATA RETENTION

10. CONTACT US

1. PERSONAL DATA CONTROLLER

Mdhamini Online Marketplace Kenya Limited, a company registered in the Republic of Kenya will be the controller of your personal data.

2. CATEGORIES OF PERSONAL DATA WE COLLECT

We collect data you give us voluntarily (for example, an email address). We also collect data automatically (for example, your IP address).

2.1. Data you give us

You may be asked to provide us information about yourself when you register for and/or use the Service. This information includes: first name, last name, phone number, email, gender, date of birth (together “Required Information”), address details, working hours etc., as well as access to your photos, albums and their metadata.

To use our Service and register an account, you will need to provide Required Information. You will be able to use the Service even if you do not give this data to us, but some Service’s functionality may be limited to you (for example, if you do no register an account, you will not be able to chat with other users, post ads, see contact details of other users).

Sometimes you may also need to provide to us additional information in the communication with our Support Team in order to fulfill your request (for example, if your account was previously blocked, we may ask you to confirm your identity by providing an ID document).

While posting announcement, you can decide to provide additional personal information on yourself. For example, you can decide to make available your CV or any photos of you or bearing your personal information. You acknowledge that by providing your personal data in announcement you are making such data publicly available. In addition, you acknowledge and agree that we will make public some personal data from your profile to provide the Service, - it will enable us to facilitate communication and transactions between the users. In particular, you acknowledge and agree that your email will be shown as a part of your advertisement in the Seeking Work CVs section to some users with the posted advertisement in the Jobs section.

You should carefully consider risks associated with the fact that you make certain information – in particular, you phone number, address, photos, passport and financial details or exact location – publicly available.

If you want to apply for a car loan, we shall provide us with your employment Type (Salary Earner or Business Owner), Monthly Income/Salary and Bank Verification Number(BVN). We will use this information for the calculation of amounts for the first and subsequent monthly installments.

2.2. Data provided to us by third parties

When you decide to log in using Facebook, we get personal data from your Facebook account. This includes your profile image, name, and Facebook ID. Unless you opt-out on the Facebook Login screen, we will also collect other data, such as email address, gender, date of birth, friends list, and location as listed in your Facebook profile.

For more information, please refer to the Facebook Permissions Reference (describes the categories of information, which Facebook may share with third parties and the set of requirements) and to the Facebook Data policy. In addition, Facebook lets you control the choices you made when connecting your Facebook profile to the App on their Apps and Websites page.

When you log in with Google, we get your name, email address, profile language settings, profile picture, gender, and date of birth. To know more about how Google processes your data, visit its Privacy Policy. To remove access granted to us, visit Google Permissions.

When you decide to log in using Apple, we get Apple ID, name and email from your account. You can use Hide My Email function during signing in with Apple, and it will create and share a unique, random email address that will forward our messages to your personal email.

Apple lets you revoke access provided to the App on your Apple ID Manage Page by following the next steps.

When you decide to log in or verify your phone number using Truecaller, we get personal data from your Truecaller user profile upon your consent. This includes your phone number, name, addresses (country code; city; street; zipcode), profile image, job title, company name, gender, and other information from your profile. For more information, please refer to the Truecaller Privacy Policy.

If you were invited to create an account in the Service, the person that invited you can provide personal information about you, such as your phone number, email address, social media account or other contact information.

We may collect your name, official government ID number and photo image to confirm your identity. For this we will share this information with a 3rd party service provider, Smile Identity Inc., in order to validate it with the governmental sources. Smile Identity Inc. may use your ID number to collect the following additional data on you from the governmental sources: full name, date of birth, image, address, phone number, gender, government ID expiry date or other additional information associated with your ID number that the issuing authority may provide. Smile ID may process or store your data outside of the borders of your country.

During such verification, Smile ID collects information that estimates the location of parts and areas of your face (“Face Data”). We do not collect or store your Face Data. Smile ID uses Face Data only to verify you are using the ID or other identification document that is yours. Neither we nor Smile ID uses Face Data for any other purposes. Face Data used for verification is retained by Smile ID for a maximum duration of ninety (90) days upon completion of the verification. Face Data is stored on Smile ID servers, hosted by Amazon Web Services.

2.3. Data we collect automatically:
2.3.1. Data about how you found us

We collect data about your referring URL (that is, the place on the Web where you were when you tapped on our ad).

2.3.2. Device and Location data.

We collect data from your device. Examples of such data include: language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, and Facebook ID.

2.3.3. Usage data

We record how you interact with our Service. For example, we log the features, and content you interact with, how often you use the Service, how long you are on the Service, what sections you use, how many ads you watch.

2.3.4. Advertising IDs

We collect your Apple Identifier for Advertising (“IDFA”) or Google Advertising ID (“AAID”) (depending on the operating system of your device). You can typically reset these numbers through the settings of your device’s operating system (but we do not control this).

2.3.5. Transaction data

When you make payments through the Service, you need to provide financial account data, such as your credit card number, to our third-party service providers. We do not collect or store full credit card number data, though we may receive credit card-related data, data about the transaction, including: date, time and amount of the transaction, the type of payment method used.

2.3.6. Cookies

A cookie is a small text file that is stored on a user's computer for record-keeping purposes. Cookies can be either session cookies or persistent cookies. A session cookie expires when you close your browser and is used to make it easier for you to navigate our Service. A persistent cookie remains on your hard drive for an extended period of time. We also use tracking pixels that set cookies to assist with delivering online advertising.

Cookies are used, in particular, to automatically recognize you the next time you visit our Website. As a result, the information, which you have earlier entered in certain fields on the Website may automatically appear the next time when you use our Service. Cookie data will be stored on your device and most of the times only for a limited time period.

3. FOR WHAT PURPOSES WE PROCESS YOUR PERSONAL DATA

We process your personal data:

3.1. To provide our Service

This includes enabling you to use the Service in a seamless manner and preventing or addressing Service errors or technical issues.

3.2. To customize your experience

We process your personal data to adjust the content of the Service and make offers tailored to your personal preferences and interests.

3.3. To manage your account and provide you with customer support

We process your personal data to respond to your requests for technical support, Service information or to any other communication you initiate. This includes accessing your account to address technical support requests. For this purpose, we may send you, for example, notifications or emails about the performance of our Service, security, payment transactions, notices regarding our Terms of Use or this Privacy Policy.

3.4. To communicate with you regarding your use of our Service

We communicate with you, for example, by push notifications or in the chat. As a result, you may, for example, receive a notification whether on the Website or via email that you received a new message on Mdhamini. To opt out of receiving push notifications, you need to change the settings on your browser or mobile device. To opt out of certain type of emails, you need to follow unsubscribe link located in the footer of the email by contacting our support team at support@mdhamini.codekali.com/.

The services that we use for these purposes may collect data concerning the date and time when the message was viewed by our users, as well as when they interacted with it, such as by clicking on links included in the message.

3.5. To research and analyze your use of the Service

This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop Mdhamini and our new products. We also use such data for statistical analysis purposes, to test and improve our offers. This enables us to better understand what features and sections of Mdhamini our users like more, what categories of users use our Service. As a consequence, we often decide how to improve Mdhamini based on the results obtained from this processing. For example, if we discover that Jobs section is not as popular as others, we may focus on improving it.

3.6. To send you marketing communications

We process your personal data for our marketing campaigns. We may add your email address to our marketing list. As a result, you will receive information about our products, such as for example, special offers, and products of our partners. If you do not want to receive marketing emails from us, you can unsubscribe following instructions in the footer of the marketing emails, by contacting our support team at support@mdhamini.codekali.com/ .

We may also show you advertisements on the Website, and send you push notifications for marketing purposes. To opt out of receiving push notifications, you need to change the settings on your device or/and browser.

3.7. To personalize our ads

We and our partners use your personal data to tailor ads and possibly even show them to you at the relevant time. For example, if you have visited our Website, you might see ads of our products, for example, in your Facebook’s feed.

We may target advertising to you through a variety of ad networks and exchanges, using data from advertising technologies on and off of our Services like, unique cookie, or similar tracking technology, pixel, device identifiers, geolocation, operation system information, email.

How to opt out or influence personalized advertising

iOS: On your iPhone or iPad, go to “Settings,” then “Privacy” and tap “Advertising” to select “Limit Ad Track”. In addition, you can reset your advertising identifier (this also may help you to see less of personalized ads) in the same section.

Android: To opt-out of ads on an Android device, simply open the Google Settings app on your mobile phone, tap “Ads” and enable “Opt out of interest-based ads”. In addition, you can reset your advertising identifier in the same section (this also may help you to see less of personalized ads).

To learn even more about how to affect advertising choices on various devices, please look at the information available here.

In addition, you may get useful information and opt out of some interest-based advertising, by visiting the following links:

Browsers: It is also may be possible to stop your browser from accepting cookies altogether by changing your browser’s cookie settings. You can usually find these settings in the “options” or “preferences” menu of your browser. The following links may be helpful, or you can use the “Help” option in your browser.

Google allows its users to opt out of Google’s personalized ads and to prevent their data from being used by Google Analytics.

Facebook also allows its users to influence the types of ads they see on Facebook. To find how to control the ads you see on Facebook, please go here or adjust your ads settings on Facebook.

3.8. To enforce our Terms and Conditions of Use and to prevent and combat fraud

We use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud. As a result of such processing, we may share your information with others, including law enforcement agencies (in particular, if a dispute arises in connection with our Terms of Use).

3.9. To comply with legal obligations

We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.

3.10. To process your payments

We provide paid products and/or services within the Service. For this purpose, we use third-party services for payment processing (for example, payment processors). As a result of this processing, you will be able to make a payment and use the paid features of the Service.

4. UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA

We process your personal data, in particular, under the following legal bases:

4.1. your consent;

4.2. to perform our contract with you;

4.3. for our (or others') legitimate interests; Under this legal basis we, in particular:

  • communicate with you regarding your use of our Service

This includes, for example, sending you push notifications reminding you that you have unread messages. The legitimate interest we rely on for this purpose is our interest to encourage you to use our Service more often. We also take into account the potential benefits to you.

  • research and analyze your use of the Service

Our legitimate interest for this purpose is our interest in improving our Service so that we understand users’ preferences and are able to provide you with a better experience (for example, to make the use of our mobile application easier and more enjoyable, or to introduce and test new features).

  • send you marketing communications

The legitimate interest we rely on for this processing is our interest to promote our Service in a measured and appropriate way.

  • personalize our ads

The legitimate interest we rely on for this processing is our interest to promote our Service in a reasonably targeted way.

Our legitimate interests for this purpose are enforcing our legal rights, preventing and addressing fraud and unauthorised use of the Service, non-compliance with our Terms of Use.

4.4. to comply with legal obligations.

5. WITH WHOM WE SHARE YOUR PERSONAL DATA

We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Service. We may share some sets of personal data, in particular, for purposes and with parties indicated in Section 2 of this Privacy Policy. The types of third parties we share information with include, in particular:

5.1. Service providers

We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We may share your personal information with the following types of service providers:

  • cloud storage providers (Amazon, DigitalOcean, Hetzner)
  • payment processing service providers (M-Pesa)
  • delivery service providers (Bolt)
  • data analytics providers (Facebook, Google, Appsflyer)
  • marketing partners (in particular, social media networks, marketing agencies, and email delivery services; such as Facebook, Google, Elastic email)
  • local banks and credit organizations (TrustGro Finance, Bees Credit, ImaliPay, Bank of Africa Kenya, Phoenix Capital, Roots Credit Ltd etc.);
5.2. Law enforcement agencies and other public authorities

We may use and disclose personal data to enforce our Terms of Use, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.

5.3. Third parties as part of a merger or acquisition

As we develop our business, we may buy or sell assets or business offerings. Customers’ information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

6. HOW YOU CAN EXERCISE YOUR RIGHTS

To be in control of your personal data, you have the following rights:

Accessing / reviewing / updating / correcting your personal data. You may review, edit, or change the personal data that you had previously provided to Mdhamini in the settings section on the Website.

You may also request a copy of your personal data collected during your use of the Service at support@mdhamini.codekali.com/.

Deleting your personal data. You can request erasure of your personal data by sending us an email at support@mdhamini.codekali.com/ or you can delete your account via the link.

When you request deletion of your personal data, we will use reasonable efforts to honor your request. In some cases, we may be legally required to keep some of the data for a certain time; in such event, we will fulfill your request after we have complied with our obligations.

Objecting to or restricting the use of your personal data (including for direct marketing purposes). You can ask us to stop using all or some of your personal data or limit our use thereof by sending a request at support@mdhamini.codekali.com/.

7. AGE LIMITATION

We do not knowingly process personal data from persons under 16 years of age. If you learn that anyone younger than 16 has provided us with personal data, please contact us at support@mdhamini.codekali.com/.

8. CHANGES TO THIS PRIVACY POLICY

We may modify this Privacy Policy from time to time. If we decide to make material changes to this Privacy Policy, you will be notified through our Service or by other available means and will have an opportunity to review the revised Privacy Policy. By continuing to access or use the Service after those changes become effective, you agree to be bound by the revised Privacy Policy.

9. DATA RETENTION

We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy (including providing the Service to you), which includes (but is not limited to) the period during which you have a Mdhamini account. We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We will store your hashed email address, phone number, identification documents and information on the fact your account has been blocked after fulfilling your request on deleting your personal data.

10. CONTACT US

You may contact us at any time for details regarding this Privacy Policy and its previous versions. For any questions concerning your account or your personal data please contact us at support@mdhamini.codekali.com/.

Effective as of: 1st December 2024