Privacy policy

This Privacy Policy governs the collection, use and disclosure of your personal data, including sensitive personal data by Fincomp Solutions Kenya Limited (“Fincomp Solutions”, “we”, “Us” or “our”) and any of its members, successors, assigns and/or authorized representatives. Personal data is information relating to an identifiable or identified individual (natural person). We are the Data Controller in relation to the personal data collected from you and we solely determine the purpose and means of processing your personal data. By using our website (fincompsolutions.com) and/or our services, you confirm that you have read and understood this Privacy Policy and expressly consent to our use and disclosure of your personal data and any sensitive personal data in accordance with this policy. We respect the privacy of your personal data and will treat it confidentially and securely.

Your Personal Data

Personal data comprises all the personal details we collect and/or hold about you, directly or indirectly including your personal identification data, your transactions data, financial information, interactions and dealings with us, including information received from third parties, the public domain or collected through use of our website.

By signing up to any of our services, you authorise Fincomp Solutions to collect, process and store your personal data including:

Information you provide to us including your national identification number, your name, your mobile phone number, your email address, gender, date of birth, personal property details;
Technical information automatically collected from you and/or any of your electronic devices. Technical information includes: the type of device you use, unique device identifiers i.e., IP or serial number, the operating system, timezone setting; and location information to determine your current location;
Information received from third parties including government agencies, credit reference agencies and mobile network providers.

If you do not provide us with the personal data required to meet our legal and regulatory obligations or to enter into an agreement with you, we may not be able to provide you with our products or services.

Purposes for which we may process your Personal Data

Fincomp Solutions recognizes your right to privacy as a data subject. We ensure that your personal data is processed in a lawful, fair and transparent manner and only for the legitimate purpose for which it was collected.

Any of your personal data collected and/or stored by Us through means specified in this policy may be used for any of the following purposes:

Contracting and completing necessary legal agreements including effecting transactions and completing instructions or requests;
Regulatory compliance including all purposes required under written law;
Conducting background checks and assessing your fitness for our products and services;
Updating Our records about you;
Statistical purposes;
Establishment, continuation and management of the relationship;
Improving our product and service offering including the way we serve you; and
Contacting and informing you of our other products and services which may be of interest to you.

Fincomp Solutions may have a legal or regulatory purpose in processing your personal data. These purposes include:

The prevention, detection, investigation and prosecution of crime in any jurisdiction (including, without limitation, money laundering, terrorism, fraud and other financial crime);
Identity verification, government sanctions screening and due diligence checks;
Compliance with local or foreign law, regulations, directives, judgments or court orders, government sanctions or embargoes, reporting requirements under financial transactions legislation, and demands of any authority, regulator, tribunal, enforcement agency, or exchange body.
We may also process your personal data to effect agreements between Us and any authority, regulator, or enforcement agency; to comply with policies and good practice standards where it is in our legitimate interest to do so.

We may also process your personal data where it is in our legitimate interests to seek professional advice, including, in connection with any legal proceedings (including any prospective legal proceedings), for obtaining legal advice or for establishing, exercising or defending legal rights.

Persons to whom we may disclose Personal Data

Other than to those individuals and entities listed below your personal data will not be shared or disclosed by Fincomp Solutions to any external person or body, unless We have your express consent, or is under either a legal obligation or any other duty to do so.

For the purposes detailed above, your information may be disclosed:

To any member of Fincomp Solutions or Bonlem Empire anywhere in the world, including any officer, employee, agent or director and/or their advisors;
To any local or international law enforcement or competent regulatory or governmental authority for any legal purpose;
To any of Our service providers, dealers, agents or any other company that may be or become Fincomp Solutions’ subsidiary or holding company for reasonable commercial purposes relating to our products and services;
To Our lawyers, auditors or other professional advisors or to any court of competent jurisdiction or arbitration tribunal in connection with any legal or audit proceedings;
To Our business alliance partners who may provide their product or service to you including but not limited to financial partners, agrovets, agronomists, farm input providers;
For legitimate business purposes connected to your use of our services, such as marketing and research related activities;
In business practices including but not limited to quality control, training and ensuring effective systems operation;
Any authorised person or any security provider;
Anyone we consider necessary to facilitate your Requests for Services; and
Anyone we consider necessary to provide you with services in connection with the service agreement signed between us.

The above disclosures may require the transfer of your information to parties located in countries outside Kenya. We will ensure that parties to whom your details are transferred treat your information securely and confidentially. We also pledge our commitment to fully meet any internationally recognised standards of personal data protection and to comply with applicable data protection and privacy laws including Kenya’s Data Protection Act and Regulations.

Security

The security of your personal data is our key priority. We have technical and organisational security measures in place to safeguard your personal data. When using external service providers, we require that they adhere to security standards mandated by us. We may do this through contractual provisions, including any required by a privacy regulator, and oversight of the service provider. Regardless of where personal data is transferred, we take all steps reasonably necessary to ensure that your data is kept securely.

Retention

Information held about you is retained as long as the purpose for which the information was collected continues or as required under regulatory requirements. The information is then destroyed unless its retention is required to satisfy legal, regulatory or accounting requirements or to protect Our interests. In most cases the information will be retained for seven years from the end of your relationship with us.

Marketing and Push Notifications

We may use your personal data:

To conduct market research and surveys with the aim of improving our products and services;
For marketing purposes, and promotional events.

We may also occasionally use push notifications through Our website or registered email address to send you marketing messages and other Service or transaction-related notifications that may be of importance to you. We process your personal data for these purposes because it is in the interest of our business to do so with the intention of improving our products and services and generating business.

By signing up to any of Our services, you expressly provide your consent to receive marketing and promotional content from Us. However, you have the right, at any time, to opt-out from receiving these types of communications by turning them off at the device level through your settings. You may also contact us through the contact details available under the contact us section on Our website (fincompsolutions.com).

Your Rights

As a data subject, you have the following rights:

Access
You have the right to access any of your personal data under Our custody any time. You may request for a copy of your personal data held by us where necessary.
Correction of personal data
If you suspect that your personal data as held by Us is false or misleading, it is your right to request that we correct such false or misleading data.
Erasure of personal data
Where Fincomp Solutions no longer has a legitimate business or lawful purpose to store your data or in the event the data we hold in relation to you is false or misleading, you have the right to request for deletion of your personal data.
Object to the processing of personal data
It is within your rights to object the processing of all or part of your personal data held by Us. However, please note that you must consent to the processing of your personal data to access our products and services.
Restriction
You have a right to require that personal data collected and stored by Us is processed for explicit, specified and legitimate purposes and that your personal data is not processed in a manner incompatible with those purposes.
Be informed
You have the right to be informed of the use to which your personal data is put.

All requests, inquiries, questions and/or concerns in relation of your rights as data subject should be addressed to Fincomp Solutions via the contact details available on Our website (fincompsolutions.com).

Terms and Conditions

There are specific Terms and Conditions for the Services offered by Fincomp Solutions and these are signed between Us and each of Our Clients. The legal agreements signed between us shall govern the collection, use and disclosure of your personal data.

Complaints

In the event you are unhappy with the way we collect, handle or process your personal data, you may send your complaints
via compliance@fincompsolutions.com. We will promptly and fairly address all your complaints and concerns and provide feedback to you within reasonable timelines.

Changes to this Privacy Policy

This Privacy Policy may be updated from time to time without advance notice to you. The most updated version will be uploaded onto Our website to replace the existing version. Any amendments to the Privacy Policy will take effect immediately.