Effective Date: 3rd February 2024

1. SCOPE OF THIS PRIVACY NOTICE

1.1 Mombo App is a mobile application used by Mombo Savings and credit cooperative society to serve its members. Mombo Sacco is a Commissioner of cooperative development licensed savings and credit cooperative society and the data controller responsible for processing your data when you download and use the Mombo mobile application (“Mombo App”) hosted on the Google Play Store, Apple App Store or when you access our Services through other Channels.

1.2 Mombo Sacco may also act as a data processor for a data controller with whom you have a contractual relationship. In such instances, Mombo Sacco will act in accordance with the instructions given by the data controller.
1.3 If you have any questions about this Privacy Notice, please contact us via email at support@mombo.africa
1.4 Please read this Privacy Notice and our Privacy Policy carefully to understand our practices regarding your personal data in accordance with the Data Protection Act, 2019. By expressing your acceptance of the terms of this Privacy Notice and our Privacy Policy (through the Mombo App, or other Channels ), you accept and understand that your personal data will be processed in accordance with this Privacy Notice and our Privacy Policy.
1.5 Mombo App’s Services are not intended for children, and we do not knowingly collect data relating to children.

2. DEFINITIONS

2.1 “Channels” means any system or medium (including the Mombo App, Unstructured Supplementary Service Data (USSD) and web whether internet based, mobile device based or not), which may be established by Mombo Sacco from time to time to enable you to access and utilise one or more of the Services.
2.2 “Children” means individuals below the age of eighteen (18) years.
2.3 “Consent” means an express, unequivocal, free, specific, and informed indication of your wishes by a statement or by a clear affirmative action.
2.4 “Customer” or “User” means any individual to which Mombo Sacco provides its Services.
2.5 “Personal data” means any information relating to an identified or identifiable individual, which shall include Sensitive personal data.
2.6 “Sensitive personal data” means personal data about an individual’s race, health status, ethnic social origin, conscience, belief, genetic data, biometric data, property details, marital status, family details including names of the individual’s child(ren), parent(s), spouse(s), or the individual’s sex or the sexual orientation.
2.7 “Services” refers to the financial products and features provided by Mombo Sacco to Customers through the Mombo App, through its partner channels, or through other Channels.
2.8 “We”, “Our” and “Us” refer to Mombo Sacco.

3. THE DATA WE COLLECT ABOUT YOU

3.1 Mombo Sacco will collect personal data from you as you use our Services. This includes the following:

• • Identity Data: includes your full name, title, date of birth, age, gender, identity document,KRA pin certificate number and photo or image.
  • Profile Data: includes your level of education, employment status and income information, images, marital status, and other details you submit in response to surveys administered by Mombo Sacco or Mombo Sacco’s agents.
  • Contact Data: includes your present address, permanent address, email address, and mobile numbers.
  • Financial Data: includes your bank account statement, contract of employment, payslips,M-Pesa statement, title deed, logbooks, mobile account number, remittance account number, and payment card details.
  • Transaction Data: includes payments and transfers to and from you, and your Mombo App or Channel transaction history.
  • Device Data: includes the type of mobile device you use, device specifications (such as screen size, resolution, memory, or CPU capacity), unique device identifiers (IMEI number, IP address, Google Play Services ADID, MAC address), mobile network carrier, and mobile operating system.
  • Content Data: includes information stored on your device, such as contact lists, call and SMS logs, and list of installed applications.
  • Network Data: includes information about Mombo Sacco users in your network, such as volume, repayment behaviour, and demographics.
  • Usage Data: includes your username, password or PIN, OTP, and details of your use of the Mombo App or Channels.
  • Communications Data: includes records of messages received from you, your account, or your device, including customer service tickets filed through the App, Channels or via email, call logs and call recordings, and records of other interactions between you or your representatives and Mombo Sacco or its agents.
  • Marketing Data: includes your preferences in receiving promotional messages from us and our authorised third parties, as well as data provided by you in relation to special offers and promotional activities conducted by Mombo Sacco.
  • Location Data: includes your current location determined by geolocation technology.
  • Third Party Data: includes information about you that we obtain from partners, credit reference agencies or bureaus, external collection agencies, identity verification and sanctions screening service providers, mobile network providers, and marketing partners.

3.2 We also may collect other information about you, your device, and your use of the App or Channels in ways that we describe to you at the time of collection.
3.3 We process your personal data from the following sources:

• 3.3.1 Information you give us. This is information you submit to us or allow us to access by expressing your acceptance in the Mombo App, through USSD transaction, or by other recorded means, including by filling in forms or by corresponding with us or interacting with our website or social media accounts.
• 3.3.2 Information we collect from your device. This is information you allow us to access by installing the Mombo App or accessing our Channels on your Device and enabling certain device permissions.
• 3.3.3 Third Party Data and publicly available sources. We may receive personal data about you from various third parties, partners and public sources such as:
  1. 3.3.3.1 Financial, Profile and Transaction Data from providers of technical, payment, delivery, and general financial services such as mobile network providers, money service businesses, USSD service providers, and external collection agencies.
  2. 3.3.3.2 Contact, Financial, Profile and Transaction Data from identity verification and sanctions screening service providers and credit reference agencies.
  3. 3.3.3.3 Communications Data from your interactions with our external collection agencies.
  4. 3.3.3.4 Identity, Profile, and Contact Data from partners and publicly available sources.

3.4 If you fail to provide or withhold any or all of the personal data that Mombo Sacco requests, we may be unable to provide you with our Services.

4. PURPOSES AND LAWFUL BASIS FOR WHICH WE WILL USE YOUR PERSONAL DATA

4.1 We will only process your personal data when we have a lawful basis to do so. In most instances, we will process your personal data under one of the following circumstances:

• 4.1.1 Where you have given your consent for the processing of your personal data.
• 4.1.2 Where we need to perform a contract with you, or where we need to take steps at your request before entering into a contract with you.
• 4.1.3 Where we need to comply with a legal obligation.
• 4.1.4 Where it is necessary for our legitimate interests (or those of a third party), and where your interests and fundamental rights do not override those interests.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA