DATA PRIVACY POLICY

Last Updated: November 28th 2024

Introduction

Purpose of this privacy policy

Paya Ventures Ltd. (“Paya,” “we,” “our,” or “us”) is committed to protecting your privacy and ensuring your data security. This Privacy Policy outlines how we collect, use, and share your personal information and explains your rights concerning this information. By using our services, you consent to this Privacy Policy.

As a customer, you accept this privacy policy when you sign up for, access, or use our products, services, content, features, technologies, or functions offered on our website and all related sites, applications, and services.

This privacy policy aims to give you information on how Paya collects and processes your personal data through your use of Paya on this website or its app, including any data you may provide through this website when you sign up as a user. This website is not intended for children, and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Scope of Policy and Terms

This Privacy Policy applies to your use of:

• Paya Mobile Application Software (“App”) available on our website or hosted on the Google Play Store (“App Site”).
• Paya’s website (www.paya.co.ke).
• Paya Services, accessible through the App or our Service Sites.

Definitions

• "Customer" or "User" Any individual using Paya’s products or services.
• "Personal Data" Any information directly or indirectly identifying a person, including name, contact details, or financial records.
• "Sensitive Personal Information" Data that may include government-issued IDs, financial data, or biometrics.
• "Subprocessors" Third-party vendors contracted by Paya to process data as required for service delivery.
• "Laws" Includes applicable Kenyan and international legal frameworks.

Disclosure Statement

By using Paya’s services, you acknowledge and consent to the collection and sharing of your SMS logs, including transactional messages, with our trusted third-party processors. This data is used solely for purposes such as credit scoring, fraud prevention, and improving our services. Paya ensures that all third-party processors are rigorously vetted and bound by stringent confidentiality and data protection agreements to safeguard your information.

If you do not wish to share your SMS data, you may opt out by discontinuing the use of Paya’s services. Please note that opting out may affect our ability to provide certain functionalities, such as credit eligibility assessment. For questions or concerns, contact us at support@paya.co.ke

• Information We Collect

  We collect and process various types of information, to provide and improve our services:which may include:

  • Information You Provide

    When interacting with Paya, you may provide:

    • Personal Details: Name, ID number, address, email, phone number, and photo.
    • Financial Data: Bank details, loan application details, and income information.
    • Communication Data: Messages, queries, and other correspondence with us.

  • Device and Technical Information

    • Mobile device type, IMEI, serial number, SIM card details, and browser type.
    • Call logs, SMS logs, GPS location, and social media contact lists (if explicitly authorized).

  • Automatically Collected Information

    • Interaction data from your use of our App or website (e.g., login times, pages visited, and actions taken).
    • Information obtained via cookies or similar technologies for analytics and functionality.

  • Information from Third Parties

    • Data from credit bureaus, financial institutions, and publicly available sources.

  • Cookies

    Cookies help us offer you the best experience when using our site. In this policy, we use the term "cookies" to refer to cookies and similar technologies.

    Cookies are small data files that we or our partners may place on your computer or other devices when you visit our website. They allow us to remember your actions or preferences over time.

    We use cookies to collect data that helps us to:

    • Track site usage and browsing behavior;
    • Allow you to log in to your account and navigate through the website;
    • Monitor the effectiveness of our promotions and advertising;
    • Mitigate risks, enhance security, and help prevent fraud.

    We use both session and persistent cookies. Session cookies are deleted when you close your browser, while persistent cookies remain on your device until they expire or are deleted by you. Persistent cookies allow us to remember information about you when you visit our website again.

    To help us monitor the effectiveness of our promotions and advertising, we may provide site usage data obtained through the use of cookies to select third-party service providers. Any data shared with these third parties will be non-personally identifiable.

    By signing up for an account with Paya or continuing to use our website, you consent to our use of cookies as described in this policy. You may decline our cookies if your browser or browser add-on permits, but doing so may affect your ability to use Paya's services. For more information on how to delete or reject cookies, you can consult the "help" section in your browser or visit www.allaboutcookies.org, where you can find further information about cookies.

• Why We Collect Information

  We collect and process your information for the following purposes:

  • Loan Assessment and Approval: To assess creditworthiness and provide financing solutions.
  • Regulatory Compliance: To meet legal obligations, including anti-money laundering (AML) and “know-your-customer” (KYC) requirements.
  • Fraud Prevention: To detect and prevent fraudulent activities.
  • Marketing and Communication: To send promotional offers and updates (subject to your consent).

• How We Use and Share Your Information

  • Use of Personal data and Information collected

    We will only use your personal data based on your consent or when required by law. Most commonly, we use your data for the following purposes:.

    • Provide tailored loan services and credit models.
    • Improve customer service and technical support.
    • Ensure compliance with applicable laws and regulatory requirements.

  • Sharing of Information

    Your data may be shared with:

    • Credit Bureaus: To report loan performance and support credit scoring.
    • Third-Party Service Providers: For payment processing, marketing, and customer support.
    • Regulatory Authorities: As required by law or court orders.
    • Subprocessors: Vetted and compliant partners necessary for providing BNPL services.

    We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

• Change of Purpose

  We will only use your personal data for the purposes for which it was collected, unless we reasonably consider that it needs to be used for another purpose that is compatible with the original one. If you would like an explanation about how the new purpose is compatible with the original purpose, please contact us.

  If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis that allows us to do so.

  Despite these measures, no system is completely secure. You are encouraged to protect your credentials.

• Data Security

  We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized 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.

  However, please note that although we take reasonable steps to protect your information, no website, Internet transmission, computer system, or wireless connection is completely secure. We have therefore 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.

  In Addition to the foregoing, Paya takes appropriate measures to safeguard your personal information, including:

  • Encryption: All sensitive data is encrypted in transit and at rest.
  • Access Control: Restricted access to your data for authorized personnel only.
  • Regular Audits: Periodic security assessments to identify vulnerabilities.

  Despite these measures, no system is completely secure. You are encouraged to protect your credentials.

• Your Rights

  As a Paya customer, you have the following rights:

  • Access and Rectification:Request access to or correction of your data.
  • Data Deletion: Request deletion of your data, subject to regulatory retention requirements.
  • Marketing Opt-Out: Opt-out of marketing communications via your App settings or by contacting support@paya.co.ke.

• Retention of Data

  We retain your information for as long as necessary to:

  • Fulfill the purposes outlined in this Privacy Policy.
  • Comply with legal and regulatory requirements.

  If your account becomes inactive, we will archive your data in accordance with industry standards.

• Updates to This Policy

  We may revise this Privacy Policy from time to time. Updates will be posted on our App and website, and you may be required to review and accept them to continue using our services.

  For inquiries or concerns about this policy, contact:

  • Email: support@paya.co.ke
  • Website: www.paya.co.ke