Privacy Policy

TemboPlus is a trademark of TemboPlus Fintech Company Ltd. (TemboPlus). TemboPlus Fintech Company Limited is a Tanzania limited liability company. As the data collector, TemboPlus ("we" “us” “our”) are committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us and how you can exercise your privacy rights. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting https://www.temboplus.com/ (“our Site”) and by using our apps you are accepting and consenting to the practices described in this policy.Please note that by clicking the “Connect with Google or Apple” button you are agreeing that Google or Apple may share personal data held by them with us. The collection and processing of your personal data is in accordance with the National Information Technology Development Agency Act 2007, the Kenya Data Protection Act, 2019 (the “Acts”) and the provisions and prescriptions of Section 5; Part 1 and Part 2 of National Information Systems and Network Security Standards and Guidelines.

1. Key Terms:

In this privacy policy, these terms have the following meanings:"Affiliate" means an entity that directly or indirectly Controls, is Controlled by or is under common Control with an entity."Control" means an ownership, voting or similar interest representing fifty percent (50%) or more of the total interests then outstanding of the entity in question. The term "Controlled" shall be construed accordingly.“Cookies” A cookie is a small data file that is transferred to your computer or mobile device. It enables us to remember your account log-in information, IP addresses, number of times you visit, browser type and version, device details, date and time of visits."TemboPlus’s Site(s)" has the meaning given to it in our Terms of Use"User" means any person or entity that is registered with us to use the Service.“Mobile App(s)” means any one or all of the TemboPlus applications available for Users to use on their mobile devices."Personal Information" means any information that identifies or can be used to identify an individual directly or indirectly. Examples of Personal Information include, but are not limited to, first and last name, date of birth, email address, gender, occupation, or other demographic information, identity card, financial information.“Services” has the meaning given to it in our Terms of Use.

2. Information we may collect from you

The information that we collect depends on the context of your interaction with TemboPlus, your account settings, the products and features you use, your location and any applicable laws. We may collect and process the following data about you:

Information you give us: You may give us information about you by filling in forms on our site (https://www.temboplus.com/ ) and our apps, by using our apps and by allowing us to access your information on social media sites (including but not limited to Facebook, Twitter and LinkedIn) or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site, search for a feature, your activity levels on boards or other social media functions on the applicable social media sites, the applications you use on social media sites, and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, login information for social networking sites, financial and credit card information, personal description, current and former places of employment, education, names of colleagues, contacts and friends, photographs, and lists of family members.

Information we collect about you: With regard to each of your visits to our site we may automatically collect the following information:technical information: including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform. If you are using your mobile phone to access our site, we may also collect information about the cellular network of you mobile device, your mobile device’s operating system or platform and the type pf mobile device you are using.Log and usage data: including information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, performance of our services, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

Information we receive from others: We may obtain information about you if you use any of the other websites we operate, the other services we provide and/or the social media sites which you login to via our site. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, social media sites, advertising networks, analytics providers, search information providers, credit bureaus, and financial services and credit providers) and may receive information about you from them.

3. Cookies

Our website uses cookies to distinguish you from other users of our website. We may use the data to provide you with a good experience when you browse our website and also allows us enhance the experience on our site. By visiting our website, and accepting our use of these cookies, you consent to the placement of cookies and beacons in your browser and HTML-based emails in accordance with this Privacy Policy. Use of the Information We use information collected (alone or in combination with other data we source) about you in the following ways: Information you give us: We will use this information:to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us to communicate information about other goods and services we offer that are similar to those that you have already purchased or enquired about.subject to the marketing preferences you have selected on our website, to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a product or service which you were previously interested in. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this to notify you about changes to our service to provide support and improve the service to ensure that content from our site is presented in the most effective manner for you and for your device.To enforce compliance with our Terms of Use.To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Disclosure and sharing of your information We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries and our Affiliates. We may share your information with selected third parties including:Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.Advertisers and advertising networks that we may partner with who require the data to select and serve targeted adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in Lagos State). We may make use of the personal data we have collected from you to enable us to evaluate and improve our Services.Analytics and search engine providers that assist us in the improvement and optimization of our site. We may disclose your personal information to third parties: a) In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets. b) If OFIL or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements or to protect the rights, property, or safety of OFIL, our customers, or others. This includes exchanging information with law enforcement and other companies and organizations for the purposes of fraud protection and credit risk reduction.A potential buyer (and its agents and advisors) in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition. In that event, any acquirer will be subject to our obligations under this privacy policy, including your rights to access and choice. We will notify you of the change either by sending you an email or posting a notice on our Site.any other person, with your consent.

6. International data transfers

Information that we collect may be stored, processed in, and transferred between any of the countries in which we operate, in order to enable us to use the information in accordance with this policy. We take reasonable steps to ensure any such information transferred to other countries shall be in compliance with applicable data protection laws and regulations. Customer consent By ticking the “I agree to the Terms and Conditions”, which you hereby adopt as your electronic signature, you consent and agree that:We can provide materials and other information about your legal rights and duties to you electronically.We are authorized to share, receive and use data/information collected from your transaction, in the terms of this Privacy Policy, with other affiliated third parties including but not limited to switching companies, mobile network operators, electricity companies, aggregators, credit bureaus, other financial institutions, e-commerce platforms.

8. Where we store your personal data

The data that we collect from you is stored on our secure servers using AWS. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorizes access.

Data retention Unless a longer retention period is required or permitted by law, we will only securely hold your data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy.Even if we delete your data, it may persist on backup or archival media for legal, tax or regulatory purposes and we will ensure this is stored securely.

Your rights You have the right to ask us not to process your personal data for marketing purposes and to withdraw your consent at any time. Please note that the withdrawal of your consent will not affect the lawful processing of data which we have obtained based on your previous consent. We will usually inform you (before collecting your data) if we intend to use your data for the aforementioned purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us via email at hey@temboplus.com. Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

11. Dispute resolution:

TemboPlus maintains a data breach procedure in order to deal with incidents concerning Personal Information or practices leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Information stored or processed.The following key measures and guidelines will be followed in the case of other disputes:TemboPlus shall respond to and maintain a complaint register of all complaints lodged through our service contacts in a CRM. The user will be contacted to verify issues through a series of manual user testsFor any complaint relating to fraud or system breaches, TemboPlus will respond to the complaints after due inquiry / investigation.The senior management will review complaints register along with responses and the unresolved complaints at the end of each day and ensure that complaint resolution guidelines are complied with.

12. Remedies

Each of the parties will be entitled to enforce its rights in the event of a breach of the terms of this privacy policy, to recover damages caused by any breach of the provisions herein and to exercise all other rights existing under law. Any claim or dispute arising in relation to this privacy policy shall be subject to the jurisdiction of the courts of the Republic of Kenya. We shall not be liable for any breach where a claim in respect of such breach is not brought within one month of the date that such breach arose.

13. Limitation of liability

Notwithstanding any other provision in this privacy policy, neither TemboPlus, its affiliates, officers, directors, employees, attorneys or agents shall have any liability with respect to, and you hereby waive, release and agree not to sue any of them upon, any claim for any special, indirect, incidental, consequential damages suffered or incurred by you in connection with, arising out of, or in any way related to, a breach of this privacy policy.

14. Access to information

The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee in providing you with details of the information we hold about you.We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you understand any changes to this policy.

15. Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to TemboPlus via email at hey@temboplus.com. EFFECTIVE DATE: 11th November, 2021.