Privacy Policy 

This privacy policy describes how Mali-Yetu protects the personal data it
processes, why and how we collect and use your personal data and how you can
exercise your rights in relation to the processing of your personal data. This
privacy policy should be read together with the Terms and Conditions of Use
for other products and services. Where there is a conflict, this privacy statement
will prevail.
This privacy also explains how this is an E-wallet, how we offer services on
transfer of funds and also the loan journey.
This statement applies to all customers, suppliers, agents, merchants, dealers
and all visitors frequenting any of Mali-Yetu services.
Reference to:

Definitions

“You”, “Your” means: customer
“Personal data” or “personal information” means: Information about you or
information that identifies you as a unique individual, such as your name/s and
surname combined with your physical address, contact details and/or
passport/identity number.
“Processing” collectively means handling, collecting, using, altering, merging,
linking, organizing, disseminating, storing, protecting, retrieving, disclosing,
erasing, archiving, destroying, or disposing of your personal information.
“Sensitive personal information” includes data revealing your race, health
status, ethnic social origin, conscience, belief, genetic data, biometric data,
property details, marital status, family details including details of your children,
parents, spouse or spouses, sex or sexual orientation.
Any supplier who has been contracted by Mali-Yetu and executed a Supplier
contract.
“Mali-Yetu”, “we” or “us”, “our” and “ours” means Mali-Yetu Limited
The word “includes” means that what follows is not necessarily exhaustive and
therefore the examples given are not the only things or situations included in the
meaning or explanation of that text.

Collection of personal data
Mali-Yetu will only collect personal data about you in so far as is necessary to
achieve the purposes set out in this privacy statement. We collect your personal
information with your knowledge and consent with exception to cases where
prior consent cannot be obtained for real reasons and the processing of the data
is permitted by law.

Personal information collected
• Identification Information:
Name
Date of Birth
National Identity Card/Passport details
• Images:
Facial images
selfies for authentication purposes and in compliance with legal and regulatory
requirements.
• Contact Details:
Phone number or email address

If provided, Mali-Yetu will use this information to contact you. We may also
obtain your contact list information to facilitate your transactions.

Camera and Images data- We use this data for Know Your Customer (KYC)
information for user verification and validation as required by the law.

• Biometric Data:
Fingerprints and facial images for authentication purposes and in compliance
with legal and regulatory requirements.

• Location Information:
To enable us to provide location-based services and aid us in fraudulent activity
detection.

• Device Information:
Information about the device you use to access the app, including:
Device type
Operating system
IP address
The duration for which your session lasted
Unique device identifiers

Mali-Yetu will collect your personal information when you do any of the
following:
• Make an application, buy or use any of our product and/or service or from
third parties on our electronic and digital platforms.
• Use any of our product and/or service on a mobile or other device
• Ask Mali-Yetu for more information about a product or service or contact
Mali-Yetu with a query or a complaint;
• When you visit, access Mali-Yetu premises;
• Attend an event sponsored by Mali-Yetu.
• Make an application to Mali-Yetu or interact with us as a supplier, agent
or dealer;
• Visit, access or use any of our online platforms/ websites;
• Subscribe to any of our online services, Short Message Service (SMS),
email or social media platforms;
• Respond to or participate in a survey, marketing promotion, prize
competition or special offer;
• We may also collect your information from other organizations including
fraud prevention agencies and government agencies
When we require personal information from you in order to fulfill a statutory or
contractual requirement, or where such information is necessary to enter into a
contract or is otherwise an obligation, we will inform you and indicate the
consequences of failing to do so.
These examples are non-exhaustive, which is reflective of the varied nature of
the personal information we may collect.

When do we collect information?
We collect information from you when you register on our site, fill out a form
or enter information on our site.

How do we use your information?
We may use the information we collect from you when you register, make a
purchase, sign up for our newsletter, respond to a survey or marketing
communication, surf the website r use certain other site features in the following
ways;

Use of personal data
• Responding to any of your queries or concerns;
• Verifying your identity information through publicly available and/or
restricted government databases in order to comply with applicable
regulatory requirements;
• Carrying out credit checks and credit scoring;
• To comply with any legal, governmental or regulatory requirement or for
use by our lawyers in connection with any legal proceedings;
• In business practices including quality control, training and ensuring
effective systems operations;
• To protect our network including to manage the volume of calls, texts and
other use of our network;
• To understand how you use our network, products and services for
purposes of developing or improving products and services;
• Preventing and detecting fraud or other crimes and for debt recovery;
• Provide aggregated data (which do not contain any information which
may identify you as an individual) to third parties for research and
scientific purpose;

Transfer of personal data
Any transfer of personal data collected by our app will only occur for the stated
purposes outlined in our privacy policy and in accordance with applicable data
protection laws. Personal data will only be transferred to individuals or
organizations that have adequate data protection controls in place, ensuring your
information is safeguarded and treated with the utmost confidentiality. We
maintain strict contractual agreements and conduct due diligence to ensure that
any recipients of personal data adhere to the same level of data protection
standards as required by applicable laws

Retention of personal data
Mali-Yetu will retain your personal data only for as long as is necessary to
achieve the purpose for which they were collected. We may retain your personal
data and/or information for a period of up to seven (7) years or as may be
required by law and maintains specific records management and retention
policies and procedures, so that personal data are deleted after a reasonable time
according to the following retention criteria:
Where we have an ongoing relationship with you.
To comply with a legal obligation to which it is subject.
Where retention is advisable to safeguard or improve the Mali-Yetu legal
position.

Marketing
Mali-Yetu will only contact you for marketing purposes where you have
provided us with your consent to do so. Consent will be sought before any such
marketing applications commence.

How do we protect your information?
We use vulnerability scanning and/or scanning to PCI standards. We use regular
Malware Scanning.
Your personal information is contained behind secured networks and is only
accessible by a limited number of people who have special access rights to such
systems and are required to keep the information confidential. In addition, all
sensitive information you supply is encrypted via Secure Socket Layer (SSL)
technology.
We implement a variety of security measures when a user enters, submits or
accesses their information to maintain the safety of your personal information.
For your convenience, we may store your personal and crucial information kept
for more than 60 days in order to automate the process.
We aim to collect only what we need, keep it up-to-date and remove it when we
no longer need it.
We take reasonable steps to ensure that the personal information we process is
limited to what we require in connection with the purposes set out in this Policy;
it is accurate and, where necessary, kept up to date; and it is erased or rectified
without delay if it is inaccurate. From time to time we may ask you to confirm
the accuracy of your personal information.
For some of our online services, you can review or update certain account
information by logging in and accessing the “Client Center” or a similar user
profile section. If you cannot change the incorrect information online, or you
prefer to request changes offline, please contact your Mali-Yetu age using the
contact information listed on your account statements, records, or other account
materials.

Do we use ‘cookies?
We may store some information (using “cookies”) on your computer when you
visit our websites. This enables us to recognize you during subsequent visits.
We use cookies for storing and honoring your preferences and settings, enabling
you to sign in, providing interest-based advertising, combating fraud, analyzing
how our products perform, and fulfilling other legitimate purposes.
We may also use this data in aggregate form to develop customized services –
tailored to your individual interests and needs. Should you choose to do so, it is
possible (depending on the browser you are using), to be prompted before
accepting any cookies, or to prevent your browser from accepting any cookies
at all. This will however cause certain features of the web site not to be
accessible.

Third-party disclosure
We do not sell, trade or otherwise transfer to outside parties your Personally
Identifiable Information.

Third-party links
Occasionally, at our discretion, we may include or offer third-party services on
our website. These third-party sites have separate and independent privacy
policies. We therefore have no responsibility or liability for the content and
activities of these linked sites. Nonetheless, we seek to protect the integrity of
our site and welcome any feedback about these sites.

How does our site handle Do Not Track signals?
We honor Do Not Track signals and Do Not Track, plant cookies, or use
advertising when a Do Not Track (DNT) browser mechanism is in place.
Does our site allow third-party behavioral tracking?

It’s also important to note that we allow third-party behavioral tracking

COPPA (Children Online Privacy Protection Act)
When it comes to the collection of personal information from persons under the
age of 18 years old, the Children’s Online Privacy Protection Act (COPPA) puts
parents in control. The Federal Trade Commission, United States’ consumer
protection agency, enforces the COPPA Rule, which spells out what operators
of websites and online services must do to protect children’s privacy and safety
online.
We do not onboard minors (any person under 18 years of age) except where you
additionally register on their behalf as their parent and/ or legal guardian. If you
allow a child to use our services, you should be aware that their personal
information could be collected as described in this statement.

Fair Information Practices
The Fair Information Practices Principles form the backbone of privacy law in
the United States and the concepts they include have played a significant role in
the development of data protection laws around the globe. Understanding the
Fair Information Practice Principles and how they should be implemented is
critical to comply with the various privacy laws that protect personal
information.
In order to be in line with Fair Information Practices we will take the following
responsive action, should a data breach occur:
We will notify you via email within 7 business days
We also agree to the Individual Redress Principle which requires that
individuals have the right to legally pursue enforceable rights against data
collectors and processors who fail to adhere to the law. This principle requires
not only that individuals have enforceable rights against data users, but also that
individuals have recourse to courts or government agencies to investigate and/or
prosecute non-compliance by data processors.

International Data Transfers
From time to time we may need to transfer your personal information outside
the Republic of Kenya.
Where we send your information outside Kenya, we will make sure that your
information is properly protected in accordance with the applicable Data
Protection Laws.

CAN SPAM Act
The CAN-SPAM Act is a law that sets the rules for commercial email,
establishes requirements for commercial messages, gives recipients the right to
have emails stopped from being sent to them, and spells out tough penalties for
violations.
We collect your email address in order to send information, respond to inquiries
or other requests or questions.
To be in accordance with CANSPAM, we agree to the following: – Not use false or misleading subjects or email addresses. – Identify the message as an advertisement in some reasonable way. – Include the physical address of our business or site headquarters. – Monitor third-party email marketing services for compliance, if one is used.
– Honor opt-out/unsubscribe requests quickly. – Allow users to unsubscribe by using the link at the bottom of each email.
If at any time you would like to unsubscribe from receiving future emails, you
can email us by following the instructions at the bottom of each email and we
will promptly remove you from ALL correspondence.

Your rights
You have the right in the circumstances and under the conditions, and subject to
the exceptions, set out in applicable law to:
• Be informed that we are collecting personal data about you.
• Request access to your personal information that we have on record. This
right entitles you to know whether Mali-Yetu holds personal data of you
and, if so, obtain information on and a copy of those personal data.
• Request Mali-Yetu to rectify any of your personal data that is incorrect or
incomplete.
• Object to and withdraw your consent to processing of your personal data.
This right entitles you to request that Mali-Yetu no longer processes your
personal data. The withdrawal of your consent shall not affect the
lawfulness of processing based on prior consent before its withdrawal.
We may also continue to process your personal information if we have a
legitimate or legal reason to do so.
• Request the erasure of your personal data. This right entitles you to
request the erasure of your personal data, including where such personal
data would no longer be necessary to achieve the purposes.
• Request the restriction of the processing of your personal data: This right
entitles you to request that Mali-Yetu only processes your personal data
in limited circumstances, including with your consent.
• Request portability of your personal data. This right entitles you to
receive a copy (in a structured, commonly used, and machine-readable
format) of personal data that you have provided to Mali-Yetu, or request
Mali-Yetu to transmit such personal data to another data controller in an
electronic format.

Non-Compliance with this Statement
We shall have the right to terminate any agreement with you for failure to
comply with the provisions of this statement and reject any application for
information contrary to this statement.

Amendments to this Statement
Mali-Yetu reserves the right to amend or modify this privacy statement from
time to time and your continued use of our products and services constitutes
your agreement to be bound by the terms of any such amendment or variation.

E-Wallet and transfer of funds services
Mali-Yetu is a digital lending platform where you after downloading and
installing the mobile app get to create an account. Within the app you can be
able to send, receive, pay or even request money from another customer with
the app. You also have the option of transferring money from and to a bank
account.

Loan Journey
The primary way of getting a loan from the app is through your warehouse
receipt number. After you have deposited your goods to the warehouse, you’re
provided with a unique warehouse receipt that’s been approved by the
Warehouse Receipt Security Council (WRSC). With this receipt, you are able to
log in the app and under the Loans number you can select a bank/financial
institution to follow from and fill in the requires details. You should see your
warehouse receipt details which primarily include the value of your commodity
and your loan limit. From there you can choose on the amount you would like to
get with the fixed rates of the specific bank/financial institution you chose.
Repayment of the loan happens after your commodities are sold or offloaded
from the warehouse. All the charges are paid and any remaining amount is
credited to your Mali-Yetu account.

Contacting Us
If there are any questions regarding this privacy policy, you may contact us
using the information below;


info@africawarehouse.com
support@africawarehouse.com

+254 117 014 437 / +254 739 440 355