Privacy Policy

Kashway Permissions Disclosure

At Kashway, we are committed to transparency and protecting your privacy in compliance with the Data Protection Act, 2019 of Kenya and other applicable laws. To ensure a smooth loan approval process and evaluate your eligibility, we require access to specific permissions on your device. All data collected is securely transmitted, stored, and used solely for providing our services. We will not share your data with third parties without your explicit consent.

SMS Permissions

We require access to your SMS messages to accurately assess your loan eligibility. Includes review of all SMS information, such as sender and recipient names, SMS content, and time of sending and receiving. A filtering process ensures only SMS containing relevant financial data are analyzed and transmitted. Non-financial messages are not uploaded or processed.

How We Access and Use Your SMS Data:

1. Initial Access: After you confirm and authorize SMS access, our app will review your SMS messages, but no data will be uploaded at this stage. This initial review is solely for credit assessment.

2. Ongoing Access: When you click the "Apply" button to request pre-approval, the app will collect up to 6 months of SMS data, with a maximum of 3,000 messages. We focus specifically on messages related to financial transactions.

3. Selective Upload: Only SMS messages containing financial keywords will be uploaded for analysis. Previously uploaded messages are not re-uploaded to avoid duplication.

4. Local Storage: If you do not initiate a loan application, your SMS data remains on your device and is not transferred to our servers.

All SMS data is transmitted using industry-standard encryption and stored securely on our servers (https://frontend.kashway.cc/cloud). We take your privacy seriously and will never share your SMS data without your consent.

Notifications

We request permission to send you push notifications regarding important account updates, payment reminders, and special offers. These notifications are optional, and the app will continue to function normally if you choose not to receive them.

Emergency Contacts

For identity verification and fraud prevention purposes, we request access to two emergency contacts. You can either manually enter these contacts or select them from your address book. Only the contacts you select will be accessed, and no additional information from your address book is collected without your permission. This data is securely transmitted over HTTPS and stored on our servers (https://frontend.kashway.cc/cloud).

Device Information

To verify your identity and prevent fraud, we collect information about your device when you click the "Apply" button. This includes your device model, OS version, IMEI, serial number, and other environment details such as display and brightness settings, CPU, and performance data. Additionally, we collect data on installed apps, focusing only on financial-related apps, to assess your financial behavior and detect any security risks. Non-financial apps are not considered, and if you do not apply for a loan, this data will not be uploaded.

All collected device information is stored securely and is protected against unauthorized access.

Network Information

We collect and use network-related data for risk management and fraud prevention:

1. Google Advertising ID (GAID): Used to analyze advertising data and improve your ad experience.

2. Wi-Fi Information: Accessed for risk assessment and detecting potential network anomalies.

3. Network State: Information such as IP address, connection status, and network type is used to prevent data loss during network interruptions and for risk analysis.

Data Storage and Security

All data collected is securely transferred and stored on our servers (https://frontend.kashway.cc/cloud) using state-of-the-art encryption and security protocols. Your data will not be shared with any third parties without your explicit consent. If you do not initiate a loan application, none of your data will be uploaded.

How We Use Your Data

The data we collect helps us:

- Verify your identity.

- Build credit scoring models.

- Determine loan offers.

- Manage credit reports and collections.

We collect personal information such as your phone number, M-Pesa details, name, device model, OS version, and address. Additionally, we may collect SMS and device activity logs. To improve our credit assessment process, we may supplement our data with information from credit bureaus and financial institutions. By using our services, you consent to this data collection, processing, and secure storage.

Data Sharing and Transfer

Kashway may share or transfer your data under the following conditions:

1. Kashway Group Companies, Subsidiaries, or Affiliates: For product development, service improvement, and performance analysis.

2. Unrelated Third Parties (Service Providers): To assist in providing credit-related services.

3. Government, Judicial, or Administrative Authorities: To comply with legal or judicial orders.

4. Outsourced Third Parties: To process data on behalf of Kashway under its instructions.

5. Risk Management and Security Providers: For fraud prevention and security purposes.

6. Commercial Affiliates: For advertising purposes.

By using the Kashway app, you acknowledge and agree to the data collection, usage, and sharing practices outlined in this disclosure. Your consent allows us to deliver efficient, transparent, and secure loan services tailored to your financial needs.

Last updated on October 17, 2024. For users whose APP version before March 23, 2024, the security data interface is https://kkloanapi.kashway.cc/loan/. For a safer application experience, please update to the latest version.

Our policy concerning the collection, maintenance, use, transfer, disclosure, and protection of your personal information is outlined in the subsequent document. In an effort to ascertain our policies and procedures regarding the management of your personal information, we kindly request that you comprehensively examine this document. By downloading the Kashway application, you are indicating that you have read, understood, and agree to the terms of this privacy policy, which are detailed below. Furthermore, you authorize the collection, use, storage, processing, and sharing of your personal data in accordance with the terms of this privacy statement. This Privacy Policy, in conjunction with our Terms of Use and any other agreements, applies to your use of the Kashway Service and the System.

This privacy policy covers the subsequent subjects:

We compile personal information

We acquire specific personal information from you. You may have explicitly provided this information or it may have been obtained from sources other than yourself. The Data Protection Act of 2019 permits certain methods and purposes for information collection; however, it does not impose any restrictions.

Directly obtained information from you or your mobile device

In order to register and establish your Account, you must provide us with a variety of Personal Information, such as your name, ID number, date of birth, gender, educational background, religion, photo, physical address, email address, work details, marital status, emergency contacts, phone number, SIM card details, financial and credit information (including Mobile Money, if applicable), and an Account ID and/or password, when using the Application.

It is imperative to furnish germane information in order for the application to operate efficiently. For example, in order to make payments using the electronic money function of the Application, you must provide payment-related information, such as the type of payment card, mobile wallet account details, issuer name, account holder name, account number, and payment amount.

Information obtained through the application or website visits

We may accumulate specific technical data about your actions when you access our website or use the application. Your IP address, the websites you have visited in the past or present, the duration of your sessions, your device ID or media access control address, and specifications regarding the brand, model, and operating system of your device are among the examples of this information.

Furthermore, cookies have the capacity to frequently accumulate specific data when you access our website or employ the application. Cookies are small files that are stored on your computer or mobile device in order to enhance the user interface and monitor user activity. Despite the fact that the majority of devices and browsers accept cookies, the app or website may not function as intended if the settings are modified to refuse specific categories of cookies or to delete stored cookies at any moment.

When the application is used on a mobile device, real-time geolocation data is monitored and collected. Enabling GPS on your mobile device may result in improved app performance. Despite our diligent efforts to prevent it, inadvertent geolocation data collection may occur while the program is operating in the background. Although it is feasible to temporarily disable geolocation monitoring on your smartphone, it is crucial to bear in mind that this may obstruct the functionality of specific applications.

Technical information and unique identifiers (e.g., IMEI number, MAC address, phone number) of your mobile device, as well as mobile network information, operating system, mobile browser type, and time zone preference, must be provided by you (the User). Furthermore, in order to utilize the Application, you are required to submit a list of emergency contacts, records of calls and text messages, and images, videos, or other digital content.

Data obtained from external sources

In order to fulfill our service obligations, we may be granted access to your personal data by third parties (including mobile network providers, collection agencies, agents, suppliers, contractors, and partners). We collect this information exclusively to ensure that our Privacy Policy and the Data Protection Act, 2019 are upheld, as well as to fulfill our obligations to these respective parties.

Information concerning external parties that you provide

Please note that you are authorized to provide us with Personal Information about third parties, including spouses, family members, acquaintances, and emergency contacts, as detailed in the "Acknowledgment and Consent" section below. However, it is imperative that you obtain their consent.

Employing the personal information we acquire

In addition to any other permissible uses under the Data Protection Act, 2019 and equivalent statutes, the Personal Information we collect may be utilized for the following purposes:

a. recognizing you, administering the conditions of your credit, and establishing your account.

b. Confirming the necessary items before establishing an account.

c. Managing the disbursement of loans and the payment of service fees.

d. Credit model development and assessment.

e. Compliance with legal obligations, including anti-money laundering and know-your-customer regulations.

f. Contacting you to provide the application with usage guidelines.

g. Notifying you of any updates to the application or modifications to the services.

h. Responding to and addressing inquiries and comments.

i. The development, evaluation, refinement, and customization of the application.

j. Engaging in genuine phone conversations or sending you SMS messages.

k. The analysis of demographic data, trends, user behavior, and service usage.

l. Directly communicating with clients about promotions, discounts, or offers.

Disclosure of the personal information we collect

In addition to the permitted uses specified by the Data Protection Act, 2019 and related laws, we may disclose your personal data to Affiliates and other entities for the following purposes:

Conducting investigations and responding to regulatory inquiries are examples of legal obligations.

a. Legal proceedings that are relevant to our company or you.

b.During the negotiation of corporate restructuring, asset sales, and mergers.

c. Establishing partnerships with external organizations that provide services such as product development, research, and marketing.

d. Providing combined, anonymized statistics.

e.When disclosure is necessary to prevent injury, report unlawful activity, investigate any violations of the conditions of use, or comply with relevant applicable law.

f. We make a genuine effort to anonymize Personal Information that is not necessary for the purpose of linking it to you.

International trade in personal information

Your personal information may be transmitted, stored, utilized, and processed outside of your current location or country of origin when you employ our services. We ensure that these transfers are subject to the same level of protection as required by the legal framework of your country in accordance with our Privacy Policy.

Safeguarding personal information

The retention of personal data is limited to the duration specified by the Data Protection Act, 2019 and other relevant statutes, or to the extent necessary to achieve the purposes for which it was collected. We discontinue the retention of your information when it is no longer required to fulfill legal or business obligations or for the original purpose, thereby eliminating any capability of personally identifying you.

Acquiring personal information

You may request that we rectify your personal information that is under our control by contacting us using the information provided below. We reserve the right to impose an administrative fee in accordance with the Kenya Information and Communications legislation, but not exclusively in accordance with this legislation. Rejection may occur for trivial reasons or when the law permits it.

The location where we store your personal information

The personal data that has been collected may be handled, transferred, or retained by third-party service providers who provide a level of security that is comparable to that of this privacy statement. This may involve the processing or storage of data outside of your country of origin under the supervision of our staff or external vendors.

Safeguarding your personal information

It is essential to safeguard your personal information. We implement the necessary safety measures to prevent loss or damage and to thwart unauthorized access, gathering, use, disclosure, and processing. However, the security of internet transmission cannot be guaranteed. You are responsible for the protection of your account and mobile device, as well as the preservation of confidentiality.

Your rights

Kashway is committed to addressing your privacy concerns. We endeavor to guarantee that you can exercise the following rights in relation to your personal information in accordance with Kenyan laws, regulations, and standards:

Access to your personal information

With the exception of laws and regulations, you have the right to access your personal information at any time. You have the ability to access the following in order to exercise your data access rights:

The following information pertains to your application

The details of your transaction:

For those who are unable to access this personal information through the aforementioned links, please refer to the "User Support and Contact Information" section of this policy for information on how to reach us. We will respond to your access request and complete the verification and processing within 15 business days.

As long as it does not necessitate an inordinate amount of effort, we will provide any additional personal information that is generated during your use of our products or services. To exercise your data access rights, please reach out to us via the methods outlined in the "User Support and Contact Information" section of this Policy.

Right to know about data sales

According to our policy, we do not sell your personal information. We will notify you before any changes to our policy and provide you with the option to opt out of data sales.  

Right to deny sales of data

You have the right to opt out of the sale of your personal data. To exercise this right, you can contact us through the following:  

Email address:service@kashway.cc 

Correction/Deletion of Personal Information  

You have the right to request the correction of inaccurate personal information. You can submit a correction request through the methods provided in the "Access Your Personal Information" section or contact us via the methods listed in the "User Support and Contact Information" section of this policy. We will process your request within 15 working days.

You may request the deletion of your personal information under the following circumstances:  

1. The processing violates laws or regulations.  

2. The collection or use of personal information occurred without consent.  

3. The processing violates agreements made with you.

We will handle deletion requests in accordance with the law after receiving them. You may also revoke consent for the continued collection of your personal information by deactivating your account.

When responding to your request, we may require identity verification. We will reply and process reasonable requests within 15 working days, usually free of charge. However, we may charge for repetitive or excessive requests. We may not respond to unreasonable requests, such as those involving legal obligations, public safety, malicious misuse of rights, or trade secrets.

Modifications to this privacy declaration

This privacy statement may be amended at any time to accommodate changing legal or regulatory requirements or to reflect changes. In the event of any updates, the application/website will broadcast general alerts. The updates are approved provided that you continue to utilize the website.

Language

In the event of a discrepancy, the English version of this privacy policy will take precedence over any other language versions.

Acceptance and consent

You acknowledge that your personal data may be collected, used, disclosed, stored, conveyed, and processed in accordance with the terms of this privacy statement. It is your responsibility to obtain consent for the use of personal data belonging to third parties in the manner described below.

Marketing and promotional products

Marketing communications could be disseminated across a diverse array of platforms. You have the option to either revoke your consent by contacting us or by utilizing the features that are available to you. Loan receipts and other correspondence will endure.

Hyperlinks to external websites

Our application and website may include hyperlinks to external websites. We are not accountable for their data practices and lack authority over them. Verify their policies regarding the acquisition and utilization of information.

Data Protection and Privacy Notice

We prioritize your privacy and data security, ensuring transparency and reliability in our services. Our apps are free from spyware, malware, and adware, and do not track or collect personal information without consent. We only gather necessary data to improve services, always based on user consent and in line with our Privacy Policy. Users can manage, modify, delete data, or withdraw consent via in-app settings. We safeguard data with industry-standard encryption and access controls, conducting regular audits to maintain integrity. We adhere to privacy regulations and ensure compliance through routine audits.

Personal information of minors

Our Services are not available to users under the age of 18 and we do not knowingly collect any information from individuals under the age of 18. If you are a parent or guardian and learn that your child has provided us with personal data, please contact us immediately. Upon becoming aware that we have collected personal information from users under the age of 18 without parental consent, we will take prompt action to delete it from our servers.

How We Retain, Share, Transfer, and Disclose Your Personal Information

We retain your personal data as long as necessary to fulfill our Privacy Policy's purposes and comply with legal obligations. Data for internal analysis is kept for shorter periods unless needed for security or service improvement. Personal information may be shared with service providers, affiliates, business partners, and other users in public areas, or with your consent. We transfer data only with your consent or as legally required, ensuring any recipient adheres to this policy. Public disclosure occurs only if legally mandated or with your consent. In special legal circumstances, such as national security or public safety, your information may be shared without prior consent.

The limitations of accountability

Any indirect, incidental, consequential, extraordinary, exemplary, or punitive damages that may result from the use of the App or communication with third parties are not our concern. We are not liable for any delays or failings that are the consequence of circumstances that are beyond our reasonable control.

Policy update reminder

Our privacy policy may be changed, but it will not reduce your rights without your consent. We will post any changes on the official website of Kashway and notify you of major changes through the following methods:

Pop-up reminders when logging in to the client or using the service;

Major changes include but are not limited to:

- Major changes in business and service models;

- Major changes in ownership or organizational structure;

- Changes to the recipients with whom personal information is shared, transferred, or publicly disclosed;

- Significant changes to your rights and how they are exercised;

- Changes to the department responsible for personal information security or the contact information;

- High risks indicated in the security assessment report.

Please update your contact information in time to ensure that you receive the notification. Continued use of the service indicates your acceptance of the updated policy. We recommend that you check the privacy policy every time you use the service, which you can view in the Kashway privacy policy.

User Support and Contact Information

For inquiries or concerns, please do not hesitate to reach out to us via email at: service@kashway.cc