Privacy Policy

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

a) Information you give us about you (Submitted information):

This information may be collected through any of the following mechanisms:

• 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);
• Provided by registering to use the App Site, downloading or registering the App, subscribing to any of our Services, searching for an app or Service, sharing data via the App 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 phone number, SIM card details, age, username, password, 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, phone users contact list, and image information.

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:

• Technical information, including the type of mobile device you use, unique device identifiers, information about the SIM card used by the Device, mobile network information, your Device operating system, the type of browser you use, or your Device location and time zone setting (Device Information);
• Data from your use of any other third-party application on the Device or the Service Sites;
• 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 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 of Your Data

We collect Your Personal Data and other data on the lawful basis provided under the Data Protection Laws including the following:

• With Your consent;
• For the performance of our legal commitments to You;
• In compliance with legal requirements or in furtherance of public interest; and/or
• 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:

• The right to be informed of the use to which Your Personal Data is used as set out in this Statement;
• The right to access Your Personal Data in our custody;
• The right to object to processing of all or part Your Personal Data;
• The right to correct, or require correction of false or misleading Personal Data;
• The right to update Your Personal Data in our custody;
• The right to require that we delete Your Personal Data in our custody.

If You wish to exercise any of Your rights, You may contact us through info@pendo.co.ke and we shall use all reasonable endeavours to facilitate such changes or action as may be required.

5 How We Use Your Data

We use Your Personal Data and other data for the following purposes:

• To respond to and process Your request for the Services and to facilitate the transactions relevant to such request;
• To facilitate and improve customer service and to effectively respond to user customer service requests and support needs;
• To improve the Site offerings and efficacy based on the information and feedback received from users;
• To send periodic emails and communications to You including information and updates on Your pending transactions. You may opt-in to our mailing list and unsubscribe at any time;
• 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 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.

7 Circumstances Under Which We May Disclose Your Data

If required by law or mandated by a court order, we may disclose Your Personal and other data as authorised. In addition:

• To our subsidiaries, affiliates, agents or partners strictly in furtherance of provision of services to You, under obligations of confidentiality;
• Pursuant to fraud-prevention or investigation into suspected fraud;
• For purposes of verification of identity information in compliance with legal requirements;
• 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 for as long as is necessary to fulfil the purpose for which it was collected or as otherwise required by law.

9 Direct Marketing

We may wish to send You marketing messages and shall request Your consent. You may at any time opt out of receiving marketing messages from us.

10 Web Browser and Advertising Cookies

We may use web browser cookies to enhance Your experience. You may set Your web browser to refuse cookies; however, some parts of the website may not function optimally.

11 Third-Party Websites

Our website may link to third-party sites. We do not control their content and are not responsible for their practices. Browsing on any other website is subject to that website’s own terms and policies.

12 Protection of Children

We do not knowingly collect information from children under the age of 18 years, and no part of our website or app is structured to attract anyone under 18.

13 Changes to the Statement

We may change or update this Statement at any time and shall post a notification on the main page of the Site and app.

14 Acceptance of the Statement

By using our website, You signify Your acceptance of this Statement. Your continued use following changes shall be deemed acceptance of those changes.

15 User Non-Compliance

If You fail to comply with the terms of this Statement, We may terminate Your access to and use of our website and services.

16 Conflict with Terms and Conditions

This Statement shall be read in tandem with PendoMedia’s Terms and Conditions. Should there be a conflict regarding data handling, the terms of this Statement shall prevail.

17 How to Contact Us

If You have any questions about this Statement, please contact us at: