This statement provides information on how Wakenya Pamoja Sacco Ltd (hereinafter “the Sacco” approaches processing your personal data). Our focus and commitment to respecting your privacy and safeguarding your personal data remain stronger than ever.
1.1 Terms used in this Statement
Information that directly or indirectly identifies a person, institution or entity. Examples include your name, phone number,ID number and address, and information such as your income. Information relating to a sole trader, commercial partnership, or professional partnership is also considered personal data.
Data Processing refers to collection,storage, transfer of data and translating into useful information.
Whose Personal Data does the Sacco process?
The people whose personal data we process include:
- Sacco members
- Potential Sacco Members
- People who show an interest in the Sacco’s products and services or are connected in another way with a business or organization with which we have, want to have, or have had a business relationship, such as third-party participants
- Security providers and guarantors
- 1 Use of Your Personal Data
The Sacco may use Personal Data for the following purposes:
- To provide and maintain our Service, including to monitor the usage of our Service.
- To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
- For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
- To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
- To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
- To manage Your requests: To attend and manage Your requests to Us.
- For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
- For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
We may share Your personal information in the following situations:
- With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
- For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
- With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
- With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
- With Your consent: We may disclose your personal information for any other purpose with Your consent. However we can disclose your personal information without your consent under the following circumstances in good faith such that the action is necessary to:
- Comply with a legal obligation
- Protect and defend the rights or property of the Sacco
- Prevent or investigate possible wrongdoing in connection with the Service
- Protect the personal safety of Users of the Service or the public
- Protect against legal liability
- Security of Your Personal Data
2.2 How does the Sacco collect your Personal Data?
We receive your personal data when you provide it to the Sacco, examples include; when opening an account, getting into a contract with us(Loan), data you send to us in order that we can contact you and data arising from any group services that we provide.
We may also receive your data from other financial institutions, suppliers public sources like newspapers, public registers and websites or other parties we work with, or because you have given another party consent to share data with us in the context of combating fraud, money laundering or terrorism.
2.2 How long does the Sacco Retain your Data?
We do not keep your data for any longer than necessary to fulfill the purposes for which we collected the data. We have adopted a data retention policy. This policy specifies how long we keep data. In general, we will keep your data for seven years following the termination of the relevant agreement or the ending of your business relationship with the Sacco, unless there is a legal obligation to preserve the data longer e.g. if the regulator asks us to keep specific data for longer in the context of risk models. In some cases, we use shorter retention periods.
In specific situations, we may also keep data for longer than we are required by the retention period fixed by us. We will do this if, for example, the judicial authorities request camera images, in which case we will keep the images for longer than we usually do, or if you have submitted a complaint, in which case the underlying data must be kept for longer.
Once we no longer require the data for the purposes described before, we may keep the data for archiving purposes, in the event of legal proceedings, or for historic or scientific research purposes or statistical purposes.
2.3 Processing of special categories of Data at the Sacco
We process special categories of personal data where this is permitted by law and consent is acquired, this may include the use of Biometrics, criminal convictions, etc. If you give us consent to record special categories of personal data relating to you, or you have made this information public yourself, we will only process the information if this is necessary so that we can provide our services. If you have given us consent to record special categories of personal data, you may withdraw that consent at any time. To do this, please contact your Relationship Manager or through our official communication channels.
2.4 Does the Sacco use Automated Individual Decision-making including Profiling?
We will only decide based solely on automated processing including profiling which produces legal effects concerning you or significantly affects you, in case it is allowed by law and we have gained consent.
We do not envisage that any decisions will be taken about you that produce legal effects or significantly affects you.
2.5 Who at the Sacco has access to your Data?
Within Wakenya Pamoja Sacco your personal data can be accessed only by individuals who need to have access owing to their role and for official business purposes. All these people are bound by a duty of confidentiality.
2.6 Does the Sacco use your Personal Data for any other purpose?
If we want to use the information for any purpose other than the purpose for which it was obtained, we may do this if the two purposes are closely related.
If there is not a sufficiently strong correlation between the purpose for which we obtained the data and the new purpose, we will ask you to give your consent. If you have given us consent, you may withdraw that consent at any time. To do this, please contact us through email@example.com
2.7 Member Data Rights at the Sacco
a) Right to Access
You may ask through the branch to access all the information that we have and process in relation to you. The data protection office shall respond to such requests as stipulated by the law
b) Right to Data Portability
You have the right to request the Sacco to supply you with data that you previously provided to the Sacco in the context of a contract with us or with your consent, in a structured, machine-readable format, or that we transfer such data to another party. If you ask us to transfer data directly to another party, we can do this only if this is technically feasible.
c) Right to Rectification
If you believe your personal data has been processed incorrectly or incompletely, you may request that we change or supplement the data.
d) Right to restriction of processing
You may request that we restrict the personal data relating to you that we process. This means that we will process fewer personal data relating to you.
e) Right to object to Direct Marketing
You have the right to request the Sacco to stop sending marketing communication. You can place your request to the Contact center or branch.
2.9 Whom to contact to place a complaint or log in an inquiry regarding Personal Data
If you have any questions concerning the processing of personal data by us, please contact any of our branches. In the case of matters concerning the exercising of your rights and other questions about the processing of your personal data kindly contact us through firstname.lastname@example.org
Right to amend this privacy statement
We reserve the right to amend this privacy statement at any time. All amendments to this privacy statement will be posted on the website. Unless otherwise stated, the current version shall supersede and replace all previous versions of this privacy.