Definitions For the purposes of this Privacy Policy:
a) "Account" means a unique Account created for You to access our Service or
parts of our Service.
b) “Client” means a person who has engaged Spin Mobile Limited to provide the
Services on behalf of the Client’s Customers.
c) "Consumer", means the ultimate person whose data is the subject of the
Services.
d) "Cookies" are small files that are placed on Your computer, mobile Device or any
other Device by a website, containing the details of Your browsing history on
that website among its many uses.
e) "Data Controller" person which alone or jointly with others determines the
purposes and means of the processing of Personal Data.
f) “Data Processor” means entity processing data on behalf of Data Controller.
g) “Data Protection Laws” means all applicable laws, regulations, guidelines, and
standards, that pertain to the collection, processing, storage, transfer, and
protection of Personal Data.
h) "Device" means any Device that can access the Services such as a computer, a
cell phone or a digital tablet.
i) "Personal Data" is any information that relates to an identified or identifiable
individual.
j) "Service" has meaning ascribed to hereinto above.
k) "You" means the individual accessing or using the Service, or the company, or
other legal entity on behalf of which such individual is accessing or using the
Service, as applicable.
This Privacy Policy applies to “Personal Data,” of a Consumer that is Data that is
associated with an identified or identifiable natural person and is protected as
personal data or personal information under applicable data protection law.

By using the Services, you signify your acceptance of this Privacy Policy. If you do not
agree or are not comfortable with any policy described in this Privacy Policy, your
only remedy is to discontinue use of the Services.
We may as Data Processors be contracted by a client, acting as Data Controller, to
provide the Services to their Consumers in which case this Policy will apply with
necessary modifications. In such case the Client is responsible: –
 to ensure that specific consent from the Consumer as data subject is obtained
for collection, processing sharing and transfer out of the country the Personal
Data in accordance with the Kenya Data Protection Act 2019 (“DPA”).
 disclosing the rights of Consumers with respect to their Personal Data and other
information regarding the collection and use of that Personal Data, in
accordance with the DPA, and other laws requiring such disclosures.

If you still have any questions or concerns, please contact us at info@spinmobile.co

a) Contact Information (e.g., name, address, phone number, email address)
b) Demographic Information (e.g., age, gender, location)
b) Transaction History (e.g., purchase history, order details)
c) Marital status
d) Sex
e) Property details
f) job titles
g) billing addresses
h) debit/credit card numbers
i) demographic information (e.g., age, gender, location)
j) transaction history (e.g., purchase history, order details) marital status
your property valuation reports

a) Sensitive Information

When necessary, with your consent or as otherwise permitted by applicable law, we
process the following categories of sensitive information:
1. Credit history and credit scores
2. Personal Tax Identification Numbers, National Identity Card Number or other
government identifiers.
3. Race/tribe
4. Health
5. Political
6. Religion
7. Trade Union
8. details
9. Details on children (minors)

All personal information that you provide to us must be true, complete, and
accurate, and you must notify us of any changes to such personal information.

When necessary, with your consent or as otherwise permitted by applicable law, we
process the following categories of sensitive information:
1. Credit history and credit scores
2. Personal Tax Identification Numbers, National Identity Card Number or other
government identifiers.
3. Race/tribe
4. Health
5. Political
6. Religion
7. Trade Union
8. Property details
9. Details on children (minors)

All personal information that you provide to us must be true, complete, and
accurate, and you must notify us of any changes to such personal information.

b) Information collected through Cookies
We may collect certain information when you visit, use, or navigate the Services. This
information does not reveal your specific identity (like your name or contact
information) but may include Device and usage information, such as your IP address,
browser and Device characteristics, operating system, language preferences,
referring URLs, Device name, country, location, information about how and when
you use our Services, and other technical information. This information is primarily
needed to maintain the security and operation of our Services, and for our internal
analytics and reporting purposes.
Like many businesses, we also collect information through Cookies and similar
technologies. You can find out more about this in our Cookie Notice:
[www.spinmobile.co/cookies].
The information we collect includes:

b) Information collected through Cookies
We may collect certain information when you visit, use, or navigate the Services. This
information does not reveal your specific identity (like your name or contact
information) but may include Device and usage information, such as your IP address,
browser and Device characteristics, operating system, language preferences,
referring URLs, Device name, country, location, information about how and when
you use our Services, and other technical information. This information is primarily
needed to maintain the security and operation of our Services, and for our internal
analytics and reporting purposes.
Like many businesses, we also collect information through Cookies and similar
technologies. You can find out more about this in our Cookie Notice:
[www.spinmobile.co/cookies].
The information we collect includes:

i. Log and Usage Data.
Log and usage data is service-related, diagnostic, usage, and performance
information our servers automatically collect when you access or use our Services
and which we record in log files. Depending on how you interact with us, this log
data may include your IP address, Device information, browser type, and settings
and information about your activity in the Services (such as the date/time stamps
associated with your usage and other actions you take such as which features you
use), Device event information (such as system activity, error reports, and hardware
settings).

ii. Device Data.

We collect Device data such as information about your computer, phone, tablet, or
other Device you use to access the Services. Depending on the Device used, this
Device data may include information such as your IP address (or proxy server),
Device and application identification numbers, location, browser type, hardware
model, Internet service provider and/or mobile carrier, operating system, and
system configuration information.

iii. Location Data.
We collect location data such as information about your Device’s location, which can
be either precise or imprecise. How much information we collect depends on the
type and settings of the Device you use to access the Services. For example, we may
use GPS and other technologies to collect geolocation data that tells us your current
location (based on your IP address). You can opt out of allowing us to collect this
information either by refusing access to the information or by disabling your
Location setting on your Device. However, if you choose to opt out, you may not be
able to use certain aspects of the Services.
c) Information collected from other sources
In order to enhance our ability to provide the Services, relevant marketing and
offers, and update our records, we may obtain information about you from other
sources, such as credit bureaus, affiliates, or other companies, public databases,
joint marketing partners, affiliate programs, data providers, and from other third
parties. This information includes mailing addresses, job titles, email addresses,
phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses,
social media profiles, social media URLs, spending habits and custom profiles.
3. Use of Your Personal Data
We use your Personal Data to provide the Services to you pursuant to the applicable
terms and conditions and in accordance with Data Protection Laws. We collect,
process, store your personal information for a variety of reasons, depending on how
you interact with our Services, including:
a) to facilitate Account creation and authentication and otherwise manage user
accounts. We may process your information so you can create and log in to your
Account, as well as keep your Account in working order;
b) automated analysis of mobile money and bank statements;
c) easy integration to Application Programming Interfaces (APIs);
d) presenting/formatting data in required format for decision making;
e) provide a 360-degree view of data subject’s financial status and providing
insights based on data from the Statements;
f) integration of the Service with the other services provided us and our affiliates.

We may need to share your personal information in the following situations:
a) To enable us provide the Services.
b) In connection with, or during negotiations of, any merger, sale of company
assets, financing, or acquisition of all or a portion of our business to another
company.
c) With our affiliates, in which case we will require those affiliates to honor this
privacy notice. Affiliates include our parent company and any subsidiaries, joint
venture partners, or other companies that we control or that are under common
control with us.
d) With our business partners to offer you certain products, services, or
promotions.
e) With contracted service providers so that they can provide us with services, such
as IT, system administration and hosting, and customer support.
f) Disclosure is required by or under any written law or by the order of the court.
In respect of paragraphs (b), (c), (d) and (e) above we shall notify you and you will
have the option to agree or decline such sharing.
We will, to the extent required by Data Protection Laws” and the applicable
contract, obtain assurances before disclosing Personal Data to a subcontractor or
third-party agent that the recipient will: (a) use the Personal Data only to assist us in
providing, maintaining or improving the Service, (b) provide at least the same level of
protection for Personal Data as is required of us, and (c) notify us if the recipient is
no longer able to provide the required protections. Upon notice, we will act
promptly to endeavor to stop and remediate any unauthorized processing of
Personal Data by the recipient. We will remain

We may use Cookies and similar tracking technologies to access or store
information. Specific information about how we use such technologies and how you
can refuse certain Cookies is set out in our Cookie Notice:
[ www.spinmobile.co/cookies ].

Your Personal Data may be transferred to, stored, and processed by us in our
facilities and by those third parties with whom we may share your personal
information in and other countries in accordance with the Data Protection Laws.
We will take all necessary measures to protect your Personal Data in accordance
with this privacy notice and Data Protection Laws.

We will only keep your personal information for as long as it is necessary for the
purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose
in this notice will require us keeping your personal information for longer than the
period of time in which users have an Account with us.
When we have no ongoing legitimate business need to process your personal
information, we will either delete or anonymize such information, or, if this is not
possible (for example, because your personal information has been stored in backup
archives), then we will securely store your personal information and isolate it from
any further processing until deletion is possible.

We have implemented appropriate and reasonable technical and organizational
security measures designed to protect the security of any personal information we
process. However, despite our safeguards and efforts to secure your information, no
electronic transmission over the Internet or information storage technology can be
guaranteed to be 100% secure, so we cannot promise or guarantee that hackers,
cybercriminals, or other unauthorized third parties will not be able to defeat our
security and improperly collect, access, steal, or modify your information. Although
we will do our best to protect your personal information, transmission of personal
information to and from our Services is at your own risk. You should only access the
Services within a secure environment.

a) Withdrawing your consent
If we are relying on your consent to process your personal information, you have the
right to withdraw your consent at any time. You can withdraw your consent at any
time by contacting us by using the contact details provided in the section 15 below.
However, please note that this will not affect the lawfulness of the processing before
its withdrawal nor, when applicable law allows, will it affect the processing of your
personal information conducted in reliance on lawful processing grounds other than
consent.
b) Opting out of marketing and promotional communications
You can unsubscribe from our marketing and promotional communications at any
time by clicking on the unsubscribe link in the emails that we send, or by contacting
us using the details provided in the section 11 below. You will then be removed from
the marketing lists. However, we may still communicate with you — for example, to
send you service-related messages that are necessary for the administration and use
of your Account, to respond to service requests, or for other non-marketing
purposes.
c) Account Information
If you would at any time like to review or change the information in your Account or
terminate your Account, you can log in to your Account settings and update your
user Account.
Upon your request to terminate your Account, we will deactivate or delete your
Account and information from our active databases. However, we may retain some
information in our files to prevent fraud, troubleshoot problems, assist with any
investigations, enforce our legal terms and/or comply with applicable legal
requirements.

You understand that we have legitimate and protected interest in the development
of our system used for crunching and automated analytics of the data we receive
from you. This interest extends to the manner in which we have reproduced,
arranged and presented your data at the conclusion of the crunching process. The
resultant data is then anonymized and becomes proprietary to us, granting the
exclusive right to it for historical, scientific and statistical purposes. This usage may
extend to both state and non-state actors in policy development and enterprise, all
aimed at the betterment of society.

12. Your Privacy Rights

13. Updates to this Policy
We may update this privacy notice from time to time. The updated version will be
indicated by an updated ’Revised' date and the updated version will be effective as
soon as it is accessible. If we make material changes to this privacy notice, we may
notify you either by prominently posting a notice of such changes or by directly
sending you a notification. We encourage you to review this privacy notice
frequently to be informed of how we are protecting your information.
14. Disputes
We prioritize openness, transparency, and accountability. If you ever have concerns
about our policies, terms, or the delivery of our services, we have a thorough
mechanism in place to address them once you bring them to our attention. We
actively encourage our Clients and Consumers to engage with us and continue doing
so.
Our commitment to providing you with the best possible experience led us to
intentionally establish a dispute resolution mechanism. This allows us to enhance
our Services, ensuring value for your money and time. We pledge not to let you
down and to adhere to the principles of natural justice, in accordance with
alternative dispute resolution methods outlined in the law.
We ask that you commit to utilizing alternative dispute resolution mechanisms
before initiating any formal dispute resolution processes. This approach enhances
the effectiveness of our Service delivery and helps protect sensitive information
handled by all parties from unnecessary exposure to third parties.
15. How Can You Contact Us About This Notice?
Spin Mobile Limited
2nd Floor, Block C, Cassia Court Complex, Kiambere Road, Upperhill Nairobi
Office Tel: +254 723 81 55 86
P.O. Box 56013 – 00200 |Kenya
Email: info@spinmobile.co