Small 360 Inc.
200 Lower Kabete Road
Nairobi, Kenya 10101
Personal data refers to any information that is related to an identified or identifiable natural person. This does not include anonymous or pseudonymous data. We may collect, process, use, transfer and store the following types of personal data:
Identity data: This includes identifiers such as your name, title, username on Kibanda Topup, social media usernames or profiles on online platforms, KRA pin, National ID number, date of birth.
Contact data: This includes your phone number, email addresses, physical address and other types of digital contact information.
Transaction data: This includes information about payment to and by you for products and services on the Kibanda Topup.
Financial data: This includes data on your mobile payments, debit or credit card details, bank account details and other information necessary for completing transactions on the platform or determining creditworthiness.
Profile data: This includes your user name, password, transaction history, services and goods purchased from us, your preferences, interests as well as feedback provided through surveys as well as any information we need to understand your behaviour when using our products and services.
Technical and usage data: This includes data on how you use our mobile and web platforms including but not limited to frequency of access, features used and duration of use. We also collect data on the type of device you use, the type and version of browser, types and versions of browser plug-ins, operating systems, timezone, location, login data and your IP (Internet Protocol) address. Location data will include both the location from which you access our services and products as well as the location information you provide.
Marketing data: This includes information on your preferences for receiving communications from us or our third party partners.
This is not an exhaustive list and only serves as an example of the types of data we collect from you. In the course of using our services you may provide data on other persons. In doing so, you agree that you have obtained the necessary consent from these persons.
It is unlikely that we will collect your sensitive data(sexual orientation, biometric data, sex, marital status, ethnicity, race, health status, conscience, belief, genetic data, real property details, family details). However, in the event that we need to for specialized services or by law, your consent will be explicitly requested and the data will be subject to a high degree of protection as prescribed by data protection laws.
We will use your personal data in the following circumstances:
Third-party marketing: We will get your express consent before we share your personal data with any third party for marketing purposes either through agreement with you, your acceptance of our terms and conditions for use of our Services or otherwise by communicating with you.
We may disclose your personal data to:
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes for which it was collected, and for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. Your personal data may be retained for a longer period where you have consented to the retention, there has been a complaint, there is a prospect of litigation with respect to your use of our Services or for historical and statistical purposes.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
If you wish to exercise any of the rights set out above or make a complaint with respect to how we process your personal data, please contact us .We may request specific information from you to enable us to confirm your identity, grant you access to your personal data or exercise any of your other rights in relation to such data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We will endeavour to respond to your complaint or request within fourteen days of its receipt. You will not have to pay a fee to access your personal data, or to exercise any of your rights in relation to the data, or to make a complaint. However, we may apply a charge if your request is clearly unfounded, repetitive or excessive. We may also refuse to comply with your request where permitted or required to do so under the law.