PendoMedia Limited (“PendoMedia”) is committed to protecting Your personal data and therefore our collection and processing of Your data shall be subject to the Data Protection Act, 2019 and Regulations made thereunder as well as other applicable laws (together called “Data Protection Laws”). This statement explains the Personal Data we collect from You as well as how we collect, process, use and handle Your Personal Data and Your rights in relation to Your Personal Data. 1. Definition (a) The terms “You” and “Your” refer to and are used in relation to any person who visits and/or registers to use our website and services. (b) The terms “we”, “us” “our” refer to and are used in relation to PendoMedia. (c) The term “Statement” shall refer to this Data Privacy Statement. 2. The Personal Data and Non-Personal Data We Collect Information you give us about you (Submitted information): This information may be collected through any of the following mechanisms: i. provided by filling in forms in the App or on the App Site (together our Sites); provided by corresponding with us (for example, by e-mail or chat); ii. provided by registering to use the App Site, downloading or registering the App, subscribing to any of our Services (such as applying for a loan), searching for an app or Service, sharing data via the App's social media functions, entering a competition, promotion or survey, and reporting a problem with the App, our Services, our App Site or any of Our Service Sites. This information may include your name, address, e-mail address and phone number, the Device's phone number, SIM card details, age, username, password and other registration information, financial and credit information (including your mobile money account details, bank account details, and bank verification number, where applicable), personal description and photograph. b) Information we collect about you and your device. Each time you visit one of our Sites or use one of our Apps we may automatically collect the following information: i. technical information, including the type of mobile device you use, unique device identifiers (for example, your Device's IMEI or serial number), information about the SIM card used by the Device, mobile network information, your Device’s operating system, the type of browser you use, or your Device’s location and time zone setting (Device Information); information stored on your Device, including contact lists, call logs, SMS logs, Facebook friends, contact lists from other social media accounts, photos, videos or other digital content (Content Information); ii. data from your use of any other third-party application on the Device or the Service Sites; iii. and details of your use of any of our Apps or your visits to any of Our Service Sites; including, but not limited to, traffic data, location data, weblogs and other communication data (Log Information). c) Location information. We may also use GPS technology OR other location services to determine your current location. d) Unique application numbers. When you install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us. However, you are free to refuse to supply Personal Data and other Data provided You understand that failure to do so may limit Your access to certain services and activities within our website and mobile app. 3. Legal Basis for Collection Your Data We collect Your Personal Data and other data on the lawful basis provided under the Data Protection Laws including the following: (a) With Your consent; (b) For the performance of our legal commitments to You; (c) In compliance with legal requirements or in furtherance of public interest; and/or (d) In furtherance of our legitimate business interest 4. Your Rights in Relation to Your Personal Data You shall have all rights provided under law in relation to Your Personal Data supplied to us including: (a) The right to be informed of the use to which Your Personal Data is used as set out in this Statement; (b) The right to access Your Personal Data in our custody; (c) The right to object to processing of all or part Your Personal Data; (d) The right to correct, or require correction of false or misleading Personal Data in relation to You; (e) The right to update Your Personal Data in our custody; (f) The right to require that we delete Your Personal Data in our custody as long as Your understand that this may limit Your access to certain Services and activities within the Site If You wish to exercise any of Your rights as set out above, You may contact us through and we shall use all reasonable endeavours to facilitate such changes or action as may be required by the exercise of Your rights within a reasonable timeline under the relevant circumstances. 5. How We Use Your Data We use Your Personal Data and other data for the following purposes: (a) To respond to and process Your request for the Services and to facilitate the transactions relevant to such request. We may share Your Personal Data and/or other data with third parties but only strictly as may necessary to facilitate a request for Services; (b) To facilitate and improve customer service and to effectively respond to user customer service requests and support needs; (c) To improve the Site offerings and efficacy based on the information and feedback received from users of our website and services; (d) To send periodic emails to communications to You including information and updates on Your pending transactions through the website. In addition, You may opt-in to our mailing list in which case You will receive emails that may include (but not be limited to) company news, updates, related product or service information. You may opt to unsubscribe from the mailing list and not receive such additional information and we shall provide clear instructions on how to unsubscribe from the mailing list at the bottom of each email in relation to the additional information. (e) To administer content, promotion, survey or other Site feature 6. How We Protect and Store Your Data We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of Your Personal Data and other data stored on the Site. We shall comply with all legal provisions in relation to the storage of Your Personal Data including (but not limited to) the requirement that Personal Data be stored in Kenya. We shall not transfer Your Personal Data outside Kenya except as strictly provided in the Act. If or when we the services of a third party in relation to data storage, we shall require that such third parties to comply with the provisions of the Act in relation to handling and storage of Your Personal Data. 7. Circumstances Under Which We May Disclose Your Data If required by law or mandated by a court order or order of regulatory and other statutory authorities, we may disclose Your Personal and other data as authorised. In addition, we may disclose Your Personal Data and other data in the following circumstances: (a) To our subsidiaries, affiliates, agents or partners strictly in furtherance of provision of services to You. Such shall be under the obligations of confidentiality; (b) Pursuant to fraud-prevention or investigation into suspected fraud; (c) (to publicly available and/or government registries and databases) For purposes of verification of identity information in compliance with legal requirements. (d) To debt-collection agencies and otherwise in pursuit of recovery of debts owing by You to us. 8. Retention of Data We shall only retain Your Personal Data that we collect for as long as is necessary to fulfil the purpose for which it was collected (including for continuing purposes such as future transactions) or as otherwise required by law. Notwithstanding that the retention period determined above may have lapsed, we may continue to retain Your Personal Data if it is relevant to a pending complaint or query lodged by You or a third party or to actual or potential legal process. 9. Direct Marketing We may wish to send You marketing messages and shall request Your consent to receive such messages. However, You may at any time opt out of receiving marketing messages from us by using the opt-out option we provide on our website. Please note that when You exercise the “opt-out” option in relation to marketing messages, it shall not apply to any other communications from us to You. 10. Web Browser and Advertising Cookies We may use web browser cookies to enhance Your experience of our website. Your web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them You. Your may opt to set Your web browser to refuse cookies, or to alert You when cookies are being sent. However, if You do so, some parts of the website may not function optimally. If You allow advertising cookies, You may have advertising delivered to You by advertising partners through our website. This Statement does not cover the use of cookies by any advertisers. 11. Third-Party Websites You may find advertising or other content on our website that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our website, is subject to that website own terms and policies and we shall not be liable for any disclosures or dealing thereon. 12. Protection of Children Protecting the privacy of the very young is especially important to us. For that reason, We do not knowingly collect, process or maintain information on our website or app belonging to children under the age of 13 years, and no part of our website or app is structured to attract anyone under the age of 13 years. 13. Changes to the Statement We may change or update this Statement at any time and shall post a notification of such change or update on the main page of the Site and app. We encourage You to frequently check this page for any changes to this Statement as it is Your responsibility to access and review this Statement periodically and become aware of changes thereto. 14. Acceptance of the Statement By using our website, You signify Your acceptance of this Statement and the terms thereof. If You do not agree with the terms herein, please do not use our website. Your continued use of our website following the posting of changes to this Statement shall be deemed Your acceptance of those changes. 15. User Non-Compliance In the event that You fail to comply with the terms of this Statement, We shall have the right to terminate Your access to and use of our website and services. 16. Conflict with Terms and Conditions It is intended that this Statement shall (where applicable) be read and interpreted in tandem with PendoMedia’s Terms and Conditions for Access/or Use of the Platform and Services. Should there be a conflict between the said Terms and Conditions and this Statement with regard to collection, processing and handling of User data, the term of this Statement shall prevail. 17. How to Contact Us If You have any questions about this Statement, the practices of and Your dealings with our website and services, please contact us at: PendoMedia Limited P.O. Box 5342-00100 Nairobi, Kenya