KOKO Networks Limited (collectively, “KOKO”) recognizes the importance of protecting the privacy of information provided by users of its services. KOKO does not share your personal information with unauthorized persons and adequate safeguards have been put in place to prevent unauthorized access and to ensure confidentiality of your personal information.
By downloading any KOKO applications, you consent to the following:
- I. By downloading any KOKO applications or using any KOKO applications you hereby give consent to the collection and processing of your personal information for legitimate business purposes;
- II. You hereby certify that all the information provided by you is true and correct to the best of your knowledge, and that any wilful misrepresentations or false information therein will be considered as an act to defraud KOKO, its partners and the law;
- III. You authorize KOKO to verify and investigate the above information as may be required, from the references provided and other reasonable sources;
- IV. You further agree that any KOKO applications and any other information obtained relative to KOKO’s applications shall be used by and communicated to KOKO and shall remain KOKO’s property even when you delete the applications from your electronic device or cease to be a customer of KOKO;
- V. You accept that KOKO shall have the right to monitor your account usage and activities and may disclose personal information to any bank or affiliate, government institution, their respective stakeholders and partners or as may be required by law;
- VI. KOKO employees who handle personal information are under obligation to treat it confidentially and will not disclose it to unauthorized third parties. KOKO employees are also responsible for the internal security of the information. Employees who violate KOKO’s privacy policies are subject to a range of disciplinary actions and legal sanctions.
SECTION 1: SCOPE OF POLICY AND TERMS
This policy applies to your use of:
- I. KOKO’s mobile applications hosted on the Google Play Store, Apple Play Store, KOKO’s websites, KOKOpoints, KOKO Sales sign up options, that you have downloaded onto your mobile phone or handheld device (“Device”) or have had access to and KOKO’s applications on any KOKO hardware (collectively “Applications”);
- II. Any of the services accessible through the Applications;
- III. Any information or services acquired through any of KOKO’s websites or any other modes of communication to customers or users and or from KOKO.
SECTION 2: INFORMATION WE COLLECT
We may collect, use and share Customer or User Information in accordance with the terms in this Policy.
Customer or User Information may be collected from you directly, from a person acting on our behalf or from other sources including any KOKO Applications, websites, KOKO, media platforms and from publicly available information. This information may be generated or combined with other information available to us or any member of KOKO.
We may collect the following information about you, which may include non-public personal Information:
2.1 Information you submit to KOKO consists of the following:
- I. Information provided by completing the Customer Sign-Up process using the myKOKO app downloaded from the Google Play Store or the KOKO app at any KOKOpoint or any other products or services invented by KOKO over time;
- II. Information provided by corresponding directly with KOKO, for example, by e-mail, through any of our websites, recorded messages through our media platforms, customer care services or by calling us using a toll-free number, SMS number, Twitter, Facebook or chat with Customer Care;
- III. Information provided by downloading, using and subscribing to any of our services, entering a competition, promotion or survey, reporting a problem using the App, our Services, or any of Our Sites and or Websites;
- IV. Information you submit may include your name, phone number, or location;
- V. Voluntarily providing to KOKO additional information about your interests, brand and product preferences, and answers to survey-based questions.
2.2 Information we collect about you and your device
Each time you visit one of our Websites or use one of our Apps the information we may collect includes, but is not limited to, the following:
- I. Technical information, including the type of mobile device you use, unique device identifiers (for example, your Device’s IMEI or serial number), information about the SIM card used by the Device, mobile network information, your device operating system, the type of browser you use, your device’s location and time zone setting (Device Information);
- II. Details of your use of any of our Apps or your visits to any of our websites including, but not limited to traffic data, location data, weblogs and other communication data.
2.3 Location information
We may also use GPS technology or other location services to determine your current location.
2.4 Information we receive from other sources
We reserve the right to work with a limited number of third parties (including credit reference agencies, mobile network providers and customer care service providers), and may receive information about you from them.
2.5 Unique application numbers
When you install or uninstall a service containing a unique application number or when such a service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.
We may occasionally send you push notifications through our mobile applications to provide you marketing messages and other service or transaction-related notifications that we feel may be of importance to you. You may at any time opt-out from receiving these types of communications by turning them off at the device level through your settings or through the mobile application settings.
We and our third-party service providers, including our marketing partners and analytics providers may use mobile tracking technologies and/or website cookies to distinguish you from other users of the App, App site or service site. This helps us to provide you with a good experience when you use the App or browse any of the websites and also allows us to improve the App and our websites.
As is true of most websites, we gather certain information automatically and store it in log files. This information may include your internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. From time to time, we may combine this automatically collected data to other information we collect about you for reasons such as analysis, security, content generation or marketing. We may use the analytic tools and software in order to develop and analyse the use of the services. Analytics companies may access anonymous individual data to help us understand how the services are used. We may link the information we store within the analytics software to any personal information you submit within the mobile applications.
By uninstalling the app from your device, you can withdraw your consent from accessing your customer information in the future. We may keep and share stored customer or user information after the point of uninstall for as long as necessary for the fulfilment of the purposes for which Customer or User Information was obtained or for the establishment, exercise or defence of legal claims, or for legitimate business purposes, or as permitted by law.
SECTION 3: WHY WE COLLECT THE ABOVE INFORMATION
We may collect information for a number of reasons, including, but not limited to, the following:
- I. To create customer or user accounts;
- II. To process your transactions;
- III. To verify your identity;
- IV. To analyse customer behaviour;
- V. To allow our partners to fulfil their obligations to you;
- VI. To allow us to fulfil our obligations to our partners;
- VII. To troubleshoot problems with the services through the myKOKO app, KOKO app, websites or any other products that KOKO manufacture or produce;
- VIII. To comply with applicable laws, regulations, and rules, such as those relating to “know-your-customer” and anti-money laundering requirements;
- IX. To detect and prevent fraud and other illegal uses of the services;
- X. To send you marketing notices, service updates and promotional offers;
- XII. To improve customer or user experience;
- XIII. To serve you with promotional offers, advertisements and other sponsored content from our advertising partners.
SECTION 4: HOW WE USE AND SHARE INFORMATION
These clauses explain how we will use and share your information.
4.1 By using our services, you agree that we and members of KOKO shall use Customer or user Information in accordance with such clauses.
4.1.1 We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.
4.1.2 Information collected by us shall only be used for the purposes defined in this policy.
4.1.3 We do not disclose information about identifiable individuals to other parties, including advertising partners, unless it is necessary for providing our services.
4.1.4 We may share limited personal information with select partners for research and development.
4.1.5 We may provide other parties with anonymous individual information about our customers or users for the purposes of compiling statistics relating to our user base or customer experience and may disclose such information to any third party for such purposes, provided that such information will always be anonymous and in accordance to this policy.
4.1.6 We provide our advertising partners with general reports on how their adverts are served through all our media platforms, and the customers who watch and/or hear them, but these reports do not include information to personally identify any of our customers. Personal information such as name, email address & mobile number will be shared with any of our advertising partners if and only if you agree to voluntarily share that information as part of any campaign.
4.2.1 By using our services, you agree that we may, as necessary and appropriate for the above purposes, transfer and disclose any customer or user information to the following recipients globally, who may also process, transfer and disclose such customer or user information for the above purposes:
- I. Including, but not limited to, any member of KOKO and any subcontractors, agents, service providers, or associates of KOKO (including but not limited to their employees, directors and officers);
- II. Any party in connection with any KOKO business transfer, disposal, merger or acquisition, wherever located, including in jurisdictions which do not have data protection laws that provide the same level of protection as the jurisdiction in which the services are supplied;
- III. Third-party service providers under contract with KOKO that help us with our business operations, such as transaction processing, fraud prevention, and marketing. We share your personal information with these companies only as necessary to provide you with our services; and,
- IV. Law enforcement, government officials or other third parties, but only:
- A. In connection with a formal request, subpoena, court order, or similar legal procedure; or
- B. When we believe in good faith that disclosure is necessary to comply with the law, prevent physical harm or financial loss, report suspected illegal activity, or to investigate violations of our User Agreements; or
- C. Or any other legally permissible purpose.
SECTION 5: WHERE WE STORE INFORMATION
5.1 The data that we collect from you may be transferred to and stored at a destination outside Kenya. It may also be processed by KOKO staff operating outside Kenya who work for us. These staff members may be engaged in the fulfilment of your requests.
5.3 Where we have given you (or where you have chosen) a password or PIN that enables you to access certain parts of our applications, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
5.4 Unfortunately, the transmission of information via the internet is not always completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our websites or servers.
5.5 Once we have received your information, we will use strict procedures and security features aimed at preventing unauthorized access.
SECTION 6. CUSTOMER OBLIGATIONS AND RIGHTS
You agree to inform us promptly, and in any event, within 30 days, through our customer care platforms, if there are any changes to Customer or user information, and to respond promptly to any request from us.
- I. You fail to provide promptly, Customer information that we reasonably request for, or;
- II. You withhold or withdraw any consents that we may need to process, transfer or disclose customer information for the above purposes (except for purposes connected with marketing or promoting products and services to you), or;
- III. We have, or a member of KOKO has, suspicions regarding Financial Crime or an associated risk;
- I. Be unable to provide new, or continue to provide all or part of our services to you and reserve the right to terminate our relationship with you;
- II. Take actions necessary for us or a member of KOKO to meet the compliance or legal Obligations; and/or
- III. Block, transfer or close your KOKO Customer Account(s) where permitted under Laws.
You agree that KOKO shall not be liable for any loss or damage arising from or incidental to our use, collection, processing and sharing of customer information, and any action we have taken in relation to this section.
Should we wish to use your information for marketing purposes, we will inform you prior to such use. You shall be entitled to prevent such usage by informing us, within 10 days of being informed of the proposed use, that you do not wish to disclose such information. You can also exercise the right at any time by contacting us at our Customer care numbers detailed at the end of this policy.
SECTION 8: QUESTIONS AND CHANGES
SMS shortcode (KE): 20531