Version 1.4 — 9th Oct 2018
Who are we?
We are Kash AI Limited (“we”, “our”, “us”) and operate under the name of Kash.
We’re committed to protecting and respecting your privacy. If you have any questions about your personal information please chat with us through the Kash app, or by emailing us at [firstname.lastname@example.org], or by writing to us at Kash, 29 Mambilla Street, Off Aso Drive, FCT, Abuja, Nigeria.
We’re registered with the Corporate Affairs Commission under number NG108784.
The information we hold about you 👀
Information submitted through our app or website
For example, when you sign up to the app and provide details such as your name, ID, selfie and address, or details we collect about how you use the app and website
There may be times when you give us ‘sensitive’ information, which includes things like your racial origin, political opinions, religious beliefs, trade union membership details or biometric data. We’ll only use this information in strict accordance with the law.
Details about your transactions with us
including any cards and accounts you use.
Information on how you use your phone
For example the mobile network you use, your IP address or operating system and the settings on your phone.
Information you give us permission to access on your phone
Things you give us explicit permission to see, like your address book, photos, geolocation and data from your camera.
Information from social networks or online accounts
Information from any accounts that you share with us.
How we use your information 🔍
To provide our services. We use it to:
- Help us maintain the account.
- Track, analyse and improve the services we give you and other customers.
To meet our legal obligations. We use it to:
- Search your record at immigration and fraud prevention agencies.
- Prevent illegal activities like money laundering, tax evasion and fraud.
- Make responsible lending decisions, like offering you an arranged overdraft. We make our decisions automatically using technology. We’ll tell you in the app once we’ve made this decision. You can opt out or ask for a manual review by email and via the app.
To exercise what’s known as our legitimate interests. This is when we use data for a reason which is in your and/or our interest, and which doesn't involve overriding your privacy rights. We use it to:
- Market products and services generally in app.
- Search your record at credit reference agencies when you sign up (this is a 'soft search' and shouldn't impact your credit score).
With your permission. We use it to:
- Check your credit history if you apply for a credit product like an arranged overdraft (this is a 'hard search').
- Market and communicate our products and services and those of affiliated partners where we think these will be of interest to you by email. You can always unsubscribe from receiving these if you want to, by email and via the app.
Who we share it with 🤝
We may share your personal information with:
- Anyone who works for us when they need it to do their job.
Any organisation which supports any of our services you use, when they need it to offer those services. That includes:
- Card producers and networks.
- Credit reference agencies (for information on how they use data please read the Credit Reference Agency Information Notice).
- Analytical, Know Your Customer (KYC) and cyber security service providers.
- Customer ‘interface’ providers (like the ones who manage our in-app chat service).
- Companies that do advertising for us (but we won’t share identifiable personal data with third parties for their own direct marketing unless you give us permission, and you can opt out any time).
- Certain authorities that detect and prevent terrorism (including authorities outside Nigeria if one of your payments is processed through a worldwide payment system).
- Anyone who you give us explicit permission to share it with.
We’ll also share it to comply with the law; to enforce our Terms and Conditions or other agreements; or to protect the rights, property or safety of us, our customers or others.
How long we keep it 📁
We keep your data as long as you’re using Kash, and for 6 years after that to comply with the law. In some circumstances, like cases of anti-money laundering or fraud, we may keep data longer if we need to and/or the law says we have to.
Your rights ✅
You have a right to:
- Access the personal data we hold about you, or to get a copy of it.
- Make us correct inaccurate data.
- Ask us to delete, 'block' or suppress your data, though for legal reasons we might not always be able to do it.
- Object to us using your data for direct marketing and in certain circumstances ‘legitimate interests’, research and statistical reasons.
- Withdraw any consent you’ve previously given us.
To do so, please contact us through the app or by emailing [email@example.com].
Where we store your data 🔒
We might transfer and store the data we collect from you somewhere outside Nigeria. People who work for us or our suppliers outside Nigeria might also process your data. We may share data with organisations and countries that:
- The African Union say have adequate data protection.
- We’ve agreed standard data protection clauses with.
How to make a complaint 😔
If you have a complaint, please contact us through the app or by emailing [firstname.lastname@example.org] and we’ll do our best to fix the problem. If you’re still not happy, you can refer your complaint to the Consumer Protection Council. For more details you can visit their website at www.fccpc.gov.ng.
Changes to this policy 📝
We’ll post any changes we make to our privacy notice on this page and, if they’re significant changes we’ll let you know by email.