Legal

Website Privacy Statement

1. Introduction

Welcome to Koba Money Transfer Services Ltd ("Koba", "we", "us", or "our"). We are committed to protecting your personal data and ensuring that your privacy is respected across all our operations. This Privacy Statement describes how we collect, use, store, share and protect your personal data when you visit our website, use our services, or interact with us.

This statement is aligned with Koba’s Data Protection Policy to ensure adequate data protection as prescribed by relevant legal frameworks, including in countries that do not yet have mature data protection laws. It applies to all personal data held by Koba relating to identifiable natural persons across our network, branch offices, implementing partners, and suppliers.

2. Definitions & Types of Personal Data We Collect

Personal data means any information relating to an identified or identifiable natural person. Depending on your interactions with us, we may collect and maintain the following sets of personal data:

Identity & Personal Information: Full names, date and place of birth, identity card and passport details and fingerprints where required for legal verification.
Contact Information: Postal or living addresses, email addresses, and telephone numbers.
Relationship Details: Identification of relatives (where applicable for compliance or beneficiary purposes).
Business & Technical Information: Business references, geo-referencing, connection data, and information stored in your electronic connection terminal device.
Stakeholder Data: Data pertaining to our personnel (staff, interns, volunteers), direct and indirect beneficiaries (including interviewees), donors, sympathizers, contractors, suppliers, consultants, and implementing partners.

3. Core Principles of Data Processing

We handle all personal data in strict adherence to the following fundamental principles:

Fairness and Lawfulness: Data is collected and processed legally, fairly and with the voluntary consent of the data subject where applicable. The data collected is adequate, relevant and not excessive for the intended purpose.
Purpose Limitation: Personal data is only processed for specified, explicit, and legitimate purposes defined prior to collection. Subsequent changes to the purpose are heavily restricted and require strict justification.
Transparency: We keep you clearly and comprehensively informed about how your data is handled, the purposes of processing, and the categories of third parties to whom the data might be transmitted.
Confidentiality and Security: All personal data is subject to absolute secrecy. It is secured with appropriate organizational and technical measures to prevent unauthorized access, illegal processing, accidental loss, modification, or destruction.
Factual Accuracy: We take suitable steps to ensure that the personal data on file is correct, complete, and kept up to date. Inaccurate or incomplete data will be corrected, supplemented, or deleted.
Deletion & Retention: Data is retained in an identifiable form for a period no longer than is necessary for the purposes for which it was obtained, unless legally mandated or justified for historical preservation.

4. Lawful Bases for Processing

We only process your personal data when we have a valid legal basis to do so, which includes:

Consent: When you have given explicit and voluntary consent for specific processing operations.
Legitimate Interest: When processing is necessary to enforce the legitimate legal, audit or financial interests of Koba, provided that your individual rights do not outweigh these interests.
Legal Obligation: To ensure compliance with national and international statutory obligations to which Koba is subject.
Vital Interests: To protect the life or safety of the data subject or another natural person.
Public Mission: For the performance of a public service mission entrusted to Koba.

5. Telecommunications, Website & Internet Usage

When you access our electronic communication services, website, or intranet, Koba implements technical safeguards to defend our IT infrastructure against external attacks and harmful content.

Any subscriber or user of our electronic communication services will be informed clearly and comprehensively regarding the actions intended to provide access to or record data on their connection terminal device (such as cookies or tracking configurations). We provide you with the necessary means to object to such actions.

Security Notice: There is no general monitoring of communication or internet use. However, data evaluations of a specific individual may be conducted by authorized investigating departments in concrete, justified cases of suspected policy violations, ensuring strict proportionality and compliance with national laws.

6. Transmission and Third-Party Disclosures

The transmission of personal data inside or outside Koba is strictly managed:

Equivalent Standards: Recipients of data outside Koba are contractually required to maintain a data protection level equivalent to our internal standards and use the data solely for defined purposes.
Legal & Law Enforcement Mandates: In specific circumstances authorized by national legislation, Koba may disclose personal data to law enforcement agencies without the data subject’s consent.
Executive Validation: Any such disclosure to law enforcement must be validated in writing by Koba’s Executive Director ahead of the disclosure, ensuring the request is legitimate, motivated, necessary, and safe for the organization.

7. Your Rights as a Data Subject

As a data subject, you have comprehensive rights regarding the personal data we hold about you. You are entitled to:

Right to Information & Access: Request information regarding what personal data is stored, how it was collected, and its intended purpose.
Right to Rectification: Demand that incorrect or incomplete data be immediately corrected or supplemented.
Right to Erasure (Deletion): Request the deletion of your data if the processing lacks a legal basis, if the legal basis has ceased to apply, or if the purpose of processing has lapsed (subject to existing statutory retention periods).
Right to Object: Object to the processing of your data if your personal situation warrants that your interests take precedence over those of the data controller, except where required by explicit legal provisions.

8. Contact and Subject Access Requests

To exercise any of your rights, or if you have any questions regarding this Privacy Statement, you may submit a formal request. All subject access and modification requests will be rigorously verified to confirm your identity before any information is modified or released.

Data Protection Officer

Koba Money Transfer Services Limited

Email: info@kobamoney.com

Address: 9^th Floor, Mitsumi Business Park, Westlands, Nairobi