Your privacy is important to us. It is Clixpesa's policy to respect your privacy regarding any information we may collect from you across our website, https://clixpesa.com, and mobile applications that we operate. This privacy notice outlines the details of how we handle, use, and safeguard your data when you engage with our services, including our website, mobile applications, and other online platforms (collectively referred to as "Our Services"). This Privacy Notice is applicable to users in Kenya and any other jurisdictions our users reside.

If you live in Kenya or any other country, we are the data controller responsible for your personal data when you access or use any of our services.

This Privacy Policy applies to all Clixpesa services unless specified otherwise.

Information We Collect

We must receive or collect some personal data to operate, provide, improve, understand, customize, support, and market our services. This also includes when you install, access, or use our services. The types of information we receive and collect depend on how you use our Services.

• You provide us with your basic information including name, contact details, and payment information such as credit or debit card details (if applicable) when you register to use our website and mobile application.
• We may also collect personal information relating to your IP address, information from cookies, and information about your computer or device (e.g. device and browser type), information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on, the geographical location from which you accessed our website (based on your IP address).
• We also receive information about you from other users and third parties. For example, when other users or third parties you interact with use our Services, they may provide your account number, name, and other information (like information from their mobile address book or in the case of businesses, additional information about you such as unique identifiers), just as you may provide theirs. We require each of these users and third parties to have lawful rights to collect, use, and share your information before providing any information to us.

How We Use Your Information

We use the information we collect to operate, provide, improve, understand, customize, support, and market our services. This includes using the information to:

• We use the information we have to operate and provide our services, including providing customer support, and improving, fixing, and customizing our services. We understand how people use our services and analyze and use the information we have to evaluate and improve our services, research, develop, and test new services and features, and conduct troubleshooting activities. We also use your information to respond to you when you contact us.
• We verify accounts and activity and promote safety and security on and off our services, such as by investigating suspicious activity or violations of our terms, and to ensure our services are being used legally.
• We use the information we have to communicate with you about our services and features and let you know about our terms and policies and other important updates.
• Communicate with you about your account and our services. We may send you notifications about your account, transactions, or our services. We may also send you marketing communications and promotional offers.
• You share your information as you use and communicate through our Services, and we share your information to help us operate, provide, improve, understand, customize, support, and market our Services. In this regard, we share your personal data with the following:
  • Our business partners, suppliers, and subcontractors for the performance of any contract we enter into with you.
  • With third parties to help us operate, provide, improve, understand, customize, support, and market our Services.
  • With the general public when you submit content to a public forum, such as blog comments, social media posts, or other features of our Services that are viewable by the general public.
  • With third parties when you engage in promotions offered through our Services.
  • With third parties when you use third-party services that are integrated with our Services, such as when you use third-party payment processing services.
  • With other third parties for our business purposes or as permitted or required by law.
  • Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. [We do not disclose personal information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users)
• We work with third-party service providers to help us operate, provide, improve, understand, customize, support, and market our services. For example, we work with companies to distribute our apps, provide our infrastructure, delivery, and other systems, supply location, map, and places information, process payments, help us understand how people use our services, market our services, help you connect with businesses using our services, conduct surveys and research for us, and help with customer service. These companies may provide us information about you in certain circumstances; for example, app stores may provide us reports to help us diagnose and fix service issues. We allow you to use our Services in connection with third-party services. If you use our Services with such third-party services, we may receive information about you from them. For example, if you choose to access our Services through a mobile carrier’s or device provider’s promotion of our services. Please note that when you use third-party services, their own terms and Privacy Policies will govern those services.
• Enforce our Terms of Service and other usage policies and comply with legal requirements.

Our Legal Bases For Processing Your Information

Under the Kenyan Data Protection Act, 2019, entities must have a legal basis to process data. You have rights available to you depending on which legal basis we use, and we’ve explained these below. You should know that no matter what legal basis applies, you always have the right to request access to, rectification of, and erasure of your data under the Kenya Data Protection Act, 2019. We process your personal data on the following bases provided under the Kenya Data Protection Act, 2019:

We process your personal data on the following bases provided under the Kenya Data Protection Act, 2019:

• Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
• Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
• Performance of a Contract: For all people who have legal capacity to enter into an enforceable contract, we process data as necessary to perform our contractual obligations to you. We describe the contractual services for which this data processing is necessary in our services/features section of the website/app and in the additional informational resources accessible from our website and applications.
• Legal Obligations: We have a duty to provide information to law enforcement authorities and to other authorities who may make legal requests for information from time to time in order to prevent, investigate or prosecute criminal activities. We will at all times ensure that the legal procedures are followed by the requesting authorities before personal data is submitted. The legal basis for processing personal data to comply with legal obligations we are subject to include:
  • To share information with law enforcement and to respond to legal requests;
  • Toprevent and address fraud, unauthorized use of our services, violations of our terms and policies, or other harmful or illegal activity; to protect ourselves (including our rights, property or products), our users or others, including as part of investigations or regulatory inquiries;
  • To share information with our partners to promote safety and security;
  • To secure systems and fight spam, threats, abuse, or infringement activities and promote safety and security.
• Protection of Vital Interests: We may process your data when it is necessary to protect an interest which is essential for your life or that of another person.
• Public Interest: For undertaking research and to promote safety and security. When we process your data as necessary for a task carried out in the public interest, you have the right to object to, and seek restriction of, our processing. In evaluating an objection, we’ll evaluate several factors, including: reasonable user expectations; the benefits and risks to you and third parties; and other available means to achieve the same purpose that may be less invasive and do not require disproportionate effort. Your objection will be upheld, and we will cease processing your information, unless the processing is based on compelling legitimate grounds or is needed for legal reasons.

How Manage Your Information

You can access and manage your information through our Services. For example, you can access your profile and account information, adjust your privacy settings, and manage your preferences. You can also manage information about you by editing your profile or account information, adjusting your privacy settings, or by choosing to close your account. You can also request access to your information, and request that we correct, delete, or restrict the processing of your information. You can also object to certain processing and request that we provide your information to you or a third party. You can exercise these rights by contacting us. We will respond to your request within a reasonable timeframe.

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.

We will retain your personal data for as long as we need it to provide you with our services. We may also retain and use your information in order to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our agreements.

Law and Protection

We may collect, use, preserve, and share your information if we have a good-faith belief that it is reasonably necessary to: (a) respond pursuant to applicable law or regulations, to legal process, or to government requests; (b) enforce our Terms and any other applicable terms and policies, including for investigations of potential violations; (c) detect, prevent, or otherwise address fraud, security, or technical issues; or (d) protect the rights, property, or safety of our users, Clixpesa, or the public as required or permitted by law.

Assignment, Change of Control and Transfer

All of our rights and obligations under our Privacy Policy are freely assignable by us to any of our affiliates, in connection with a merger, acquisition, restructuring, or sale of assets, or by operation of law or otherwise, and we may transfer your information to any of our affiliates, successor entities, or new owner.

Changes to this Privacy Policy

We may revise this Privacy Policy from time to time. The most current version of the policy will govern our processing of your personal data and will always be athttps://clixpesa.com/privacy-policy. If we make a change to this policy that, in our sole discretion, is material, we will notify you via an email to the email address associated with your account. By continuing to access or use our services after those changes become effective, you agree to be bound by the revised Privacy Policy.

Contact Us

If you have any questions about this Privacy Policy,
please contact us at dpo@clixpesa.com, or write to us at:

Clixpesa Solutions Limited
Isaac Salat Road, Embassy Building
P.O Box 1130 – 20200,
Kericho, Kenya