Privacy Policy

Privacy Policy

This Privacy Policy describes our policies and procedures on the collection, use, and disclosure of your information when you use the Service and informs you about your privacy rights and how the law protects you. If you do not agree with our policies and practices, you may choose not to use our Service. For more information about C, please visit the “Privacy Policy” section on our official website. This policy may change from time to time. If a specific product we offer has a separate privacy policy or a special provision in the corresponding user service agreement, that product’s privacy policy will take precedence; for content not covered by that product’s privacy policy and user service agreement, this policy will apply. We use your personal data to provide and improve the Service. By accessing or using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.

Introduction

We highly value the privacy and personal information protection of our users. When you use our products and/or services, we may collect and use your information. Through the “Chapeo Cash Financial Privacy Policy” (hereinafter referred to as “this Policy”), we aim to explain the types of personal information we need to collect in relation to our business activities, as well as the means and protective measures we provide for you to access, update, and delete this information. Additionally, we outline the rules we follow when sharing, transferring, or publicly disclosing your personal information. This Policy is closely related to the Chapeo Cash financial services you use and the various business functions included in those services (collectively referred to as “our products and/or services”). We hope you will read this Policy carefully and ensure you fully understand the content described herein (especially the content in bold) before using our products and/or services. This will allow you to make appropriate choices based on the guidance provided in this Policy. For clarity, we use concise expressions for relevant terms mentioned in this Policy to facilitate your better understanding.

It is important to note that this Policy applies only to the products and/or services defined in this Policy.

Table of Contents

  1. How We Collect Your Personal Information
  2. How We Use Your Personal Information
  3. How We Use Cookies and Similar Technologies
  4. How We Store, Share, Transfer, and Disclose Your Personal Information
  5. How We Protect Your Personal Information
  6. Your Rights
  7. How We Handle Personal Information of Minors
  8. How This Policy is Updated
  9. How to Contact Us
  10. Definitions of Key Terms in This Policy

1. How We Collect Your Personal Information

We adhere to the principles of legitimacy, lawfulness, and necessity when collecting and using your personal information for the purposes described in this policy. We collect and use the personal information you provide actively or that is generated from your use of our products and/or services. Additionally, we may obtain your personal information from third parties. If we intend to use your personal information for purposes not specified in this policy or use the information collected for a specific purpose for another purpose, we will inform you in a reasonable manner and obtain your consent again before using it.

1.1 Personal Data

While using our services, we may ask you to provide certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:

1.2 Usage Data

We collect your personal information through the following channels:

  1. Information You Provide Directly: We may collect and store information you provide when using Chapeo Cash financial services. This includes information you provide when filling out forms on our website, applying for products and/or services, participating in feedback, resolving disputes, or contacting us regarding Chapeo Cash financial services. Additionally, we collect information generated during your use of our services, including details about your transactions and activities.
  2. Information We Collect Automatically: While you use the Chapeo Cash website, app, and related services, we collect information sent to us by your computer, mobile phone, and other access devices.

1.3 Information from Third-Party Social Media Services

If you grant us access to your third-party social media accounts, we may collect personal data associated with your third-party social media accounts, such as your name, email address, and activities, with your consent. You may also choose to share additional information with the company through your third-party social media accounts. By providing this information and personal data during registration or other instances, you authorize the company to use, share, and store this information in accordance with this Privacy Policy.

1.4 Mobile Data While Using the Application

To enjoy our financial services and support our anti-fraud systems, we may collect and synchronize the following information with your prior permission while using our application:

The permissions we request are aligned with the service features we provide. If our business functions change, the requested device permissions will also be adjusted accordingly. We will notify you separately the first time we request device permissions and explain the purpose of the permission request. By enabling these permissions, you authorize us to collect and use your personal information to achieve the stated functions. If you disable permissions, you withdraw this authorization, and we will stop collecting your personal information and be unable to provide the corresponding functions. Disabling permissions does not affect the processing of personal information based on your prior authorization.

2. How We Use Your Personal Information

We use your information in the following ways to comply with national laws, regulations, and regulatory requirements, to provide services to you, enhance service quality, and safeguard your account and fund security:

  1. Achieve Purposes as Stated in “What Information We Collect” of This Policy:

    • We use your information to achieve the purposes outlined in the section where we describe what information we collect from you.
  2. Security and Stability of Services:

    • We use your information for identity verification, security prevention, fraud monitoring, prevention or prohibition of illegal activities, risk reduction, and for archival and backup purposes to ensure service stability and security.
  3. Service Notifications:

    • We send service notifications to keep you informed about the status of your use of our services.
  4. Reporting to Relevant Authorities:

    • We may report to relevant departments in accordance with legal requirements or regulatory requirements.
  5. Customer Surveys:

    • We invite you to participate in customer surveys related to our services.
  6. Improvement and Optimization of Chapeo Cash Financial Online Services:

    • We use your information to improve, refine, and optimize our Chapeo Cash financial online services.
  7. Handling Applications or Feedback for Chapeo Cash Products and/or Services:

    • We process your applications or feedback regarding Chapeo Cash products and/or services.
  8. De-identified Information Usage:

    • After de-identifying your information through technical means, the de-identified information cannot be used to identify individuals. We may use such de-identified information without revealing your personal information. We may analyze the user database and utilize it for commercial purposes without disclosing your personal information.
  9. Statistical Analysis and Sharing:

    • We perform statistical analysis on the usage of our products and/or services and may share these statistics publicly or with third parties to demonstrate overall usage trends of our products and/or services. These statistics do not contain any personally identifiable information about you.

Additional Measures:

These measures are implemented to ensure that your personal information is used responsibly and transparently, in line with your expectations and legal requirements.

3. How We Use Cookies and Similar Technologies

3.1 Use of Cookies

  1. Purpose of Cookies:

    • To enhance your browsing experience, we sometimes store small data files called cookies on your computer or mobile device. Cookies are plain text files stored by a web server on a computer or mobile device, which can only be retrieved or read by the server that created them. Each cookie is unique to your web browser or mobile application. Cookies typically contain identifiers, site names, and some numbers and characters. They allow websites to remember user visits (using session cookies) or multiple visits (using persistent cookies). With cookies, websites can save settings such as language, font size, and other browsing preferences, eliminating the need for users to reconfigure preferences on each visit. If a website does not use cookies, it may treat each visit as a new visitor, requiring users to log in repeatedly, for instance, when navigating between pages.
  2. Services Provided Through Cookies and Similar Technologies:

    • Remembering Your Account: For example, when you visit a site that requires login, we encrypt and store your login name in a cookie file on your computer. This encrypted storage is irreversible, meaning even if others use your computer, they cannot identify your login name. This eliminates the need for you to manually enter your account information each time you use our services.
    • Analyzing Service Usage: We use cookies, web beacons, and similar technologies to understand how you use our services, including which pages or services are most popular.
    • Optimizing Advertising: Based on aggregated statistical information about your visits to related websites, we may display products or advertisements that may interest you. These statistics do not include any personally identifiable information and are used to assess the effectiveness of advertisements. Cookies, web beacons, and similar technologies help us deliver ads relevant to your interests rather than generic ads.
    • Anonymous Data Collection: We may also use web beacon technologies to collect anonymous visit data. Like statistics, this data does not include personally identifiable information.
  3. Limitations of Cookie Usage:

    • We do not use cookies for purposes other than those described in this policy. You can manage or delete cookies based on your preferences using browser or operating system software that includes cookie clearing capabilities. Most web browsers automatically accept cookies, but you can usually modify your browser settings to reject cookies or delete them as needed. However, this may require you to manually adjust settings each time you visit our website and could impact the security and convenience of the services you use, though it will not affect your ability to use our other services normally.

3.2 Use of Web Beacons, Pixel Tags, and Similar Technologies

In addition to cookies, we employ other similar technologies such as web beacons and pixel tags on our website:

These technologies enable us to improve our services and provide a more personalized experience while respecting your privacy preferences.

4. How We Retain, Share, Transfer, and Disclose Your Personal Information

4.1 Retention of Your Personal Data

We will retain your personal data only for the period necessary to fulfill the purposes outlined in this Privacy Policy. This includes compliance with legal obligations, resolving disputes, and enforcing our legal agreements and policies. Additionally, we may retain usage data for internal analysis purposes. The retention period for usage data is typically shorter unless extended for security enhancement, service improvement, or legal obligations.

4.2 Sharing Your Personal Information

We may share your personal information in the following circumstances:

4.3 Transfer of Your Personal Data

We do not transfer your personal information to any company, organization, or individual except in the following cases:

  1. With your explicit consent, we may transfer your personal information to other parties.
  2. When required by applicable laws, regulations, legal procedures, mandatory administrative or judicial requests.
  3. In cases involving mergers, acquisitions, or bankruptcy liquidations where the transfer of personal information is involved, we will require the new entity holding your personal information to continue to be bound by this policy. Otherwise, we will ask that entity to re-obtain your consent.

4.4 Public Disclosure of Your Personal Data

We only disclose your personal information in the following circumstances:

  1. With your explicit consent, in accordance with the disclosure method specified by you.
  2. When required by law, legal procedures, litigation, or government regulatory authorities. In compliance with applicable laws and regulations, when we receive such requests for disclosure, we require appropriate legal documents such as subpoenas or investigation letters. We believe that requests for information should be as transparent as possible within the limits permitted by law. We conduct a thorough review of all requests to ensure they have a legal basis and are limited to data that law enforcement agencies have the lawful right to obtain for specific investigative purposes.

4.5 Exceptions Requiring Prior Authorization for Sharing, Transfer, and Disclosure of Personal Information

In accordance with relevant laws, regulations, and national standards, we may share, transfer, or disclose your personal information without prior authorization in the following circumstances:

  1. Related to fulfilling obligations required by laws and regulations.
  2. Directly related to national security or defense security.
  3. Directly related to public safety, public health, or major public interests.
  4. Directly related to criminal investigation, prosecution, trial, and execution of judgments.
  5. Necessary protecting the vital interests of you or other individuals when obtaining your consent is difficult.
  6. Information that you voluntarily disclose to the public.
  7. Personal information collected from legally disclosed information sources, such as lawful news reports or government information disclosures.

5. How We Protect Your Personal Information

5.1 Data Security Measures

We prioritize the security of your personal information and employ all reasonable and feasible measures to protect it:

5.2 Other Security Measures to Protect Personal Information

To manage and standardize the storage and use of personal information, we implement the following measures:

5.3 Security Incident Response

In the event of a personal information security incident:

5.4 Storage and Retention of Your Personal Information

  1. Retention Period: We retain your personal information only for the period necessary to fulfill the purposes outlined in this policy and within the time limits required by laws, regulations, and regulatory requirements. We promise to keep your personal information for consumer rights protection until one month after your account is cancelled, unless otherwise stipulated by laws and regulations. After the retention period expires, we will delete or anonymize your personal information.
  2. Termination of Use: Upon termination of our services to you, we will cease collecting and using your information, except as required by laws, regulations, or regulatory authorities. If we terminate our services or operations, we will notify you at least thirty days in advance and delete or anonymize your personal information after terminating the services or operations.

6. Your Rights

Chapeo Cash places great importance on your concerns regarding personal information and, in accordance with relevant laws, regulations, and standards in Kenya, strives to ensure your exercise of the following rights:

6.1 Access to Your Personal Information

  1. Access Request: You have the right to access your personal information at any time, except where exceptions are prescribed by laws and regulations. If you wish to exercise your right to access data, you can do so through the following methods:
  1. Alternative Access: If you are unable to access this personal information through the provided links, you can contact us at any time using the contact information specified in this policy. We will respond to your access request and complete verification and processing within 15 working days.
  2. Additional Personal Information: For other personal information generated during your use of our products or services, we will provide it to you as long as it does not require excessive input from us. If you wish to exercise your data access rights, you can contact us using the contact information specified in this policy.

6.2 Correction of Your Personal Information

When you discover errors in the personal information we process about you, you have the right to request corrections. You can submit a correction request through the methods listed under “Access to Your Personal Information.” If you are unable to correct this personal information through the provided links, you can contact us at any time using the contact information specified in this policy. We will respond to your correction request and complete verification and processing within 15 working days.

6.3 Deletion of Your Personal Information

You can request the deletion of personal information under the following circumstances by contacting customer service:

  1. Violations of Laws and Regulations: If our processing of personal information violates laws and regulations.
  2. Unauthorized Collection or Use: If we collect or use your personal information without your consent.
  3. Breach of Agreement: If our processing of personal information violates our agreement with you.

Upon receiving your deletion request, we will handle it according to your request and relevant legal requirements. If we decide to respond to your deletion request, we will also notify entities from whom we obtained your personal information to promptly delete it, unless otherwise required by laws and regulations or authorized by you.

Backup Systems:

After you delete information from our services, we may not immediately delete corresponding information from backup systems but will delete it when updating backups.

Account Cancellation:

You can withdraw all authorizations for us to continue collecting your personal information by canceling your account. You can complete account cancellation through the mobile app: My -> Security Settings -> Account Cancellation. You can also contact us using the contact information specified in this policy, and after verifying your account cancellation details and contract performance, we will process your account cancellation request.

Response to Your Requests:

To ensure security, you may need to provide a written request or other proof of your identity. We may ask you to verify your identity before processing your request. We will respond to your request and complete verification and processing within 15 working days.

Costs:

For your reasonable requests, we generally do not charge fees. However, for multiple repeated requests exceeding reasonable limits, we may charge costs depending on the situation. Requests that are groundlessly repeated, require excessive technical means (e.g., necessitating the development of new systems or fundamentally changing current practices), pose risks to the legitimate rights and interests of others, or are impractical (e.g., involving information stored on backup tapes) may be refused.

Exceptions:

We may not be able to respond to your requests in the following circumstances:

7. How We Handle Minors’ Personal Information

Our services are not intended for anyone under the age of 18. We do not intentionally collect personal identity information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us. If we discover that we have collected personal data from anyone under the age of 18 without parental consent, we will take steps to delete this information from our servers.

If we rely on consent as the legal basis for processing your information, and your country requires parental consent, we may require your parents’ consent to collect and use this information.

8. How This Policy Is Updated

  1. Changes to Privacy Policy: Our privacy policy may change. Without your explicit consent, we will not reduce your rights under this policy. We will publish any changes made to this policy on the Chapeo Cash Financial official website.
  2. Notification of Major Changes: For significant changes, we will also notify you promptly through one of the following methods:
  1. Significant Changes Defined: Major changes referred to in this policy include but are not limited to:
  1. Keeping Updated: To ensure you receive timely notifications, please inform us promptly when your contact information changes. If you continue to use our services after this policy update takes effect, it means you have fully read, understood, and accepted the updated policy and are willing to be bound by it. We encourage you to review this policy each time you use our services. You can view this policy in the Chapeo Cash APP under “Home Page -> My -> Chapeo Cash Privacy Policy.”

9. How to Contact Us

  1. Contact Information: We have established a dedicated department and a personal information protection commissioner. If you have any questions, comments, or suggestions regarding this policy or your personal information, please contact us through the following methods:

Our customer service department, along with the personal information protection department, will respond to you promptly.

  1. Response Time: Generally, we will respond and complete verification and processing within 15 working days. If you are dissatisfied with our response, especially if our processing of personal information has harmed your legitimate rights and interests, you can seek solutions through the following external channels: file a lawsuit with a competent court or complain/report to the relevant regulatory authorities.

10. Definitions of Key Terms in This Policy

For the purposes of this privacy policy: