Protecting your information is important to us
Introduction
In line with the Data Protection Act 2019, which came into force 11th November 2019, all data processors and handlers are required to conform with the Act, our statement herein is an introduction of how we collect, handle, process and store any form of data that we come into contact with.
It is therefore, important that you read this Data Protection Statement and, if you are a principal Sacco member, we encourage you to share this statement with the beneficiaries of your membership and ensure that they have given you consent to act on their behalf.
This NDEGE CHAI SACCO SOC LTD Privacy Statement relates to the collection, usage, disclosure and storage of your Personal Data throughout the NDEGE CHAI SACCO SOC LTD’s processes and your data shall not be used for commercial purposes unless consent is obtained. By applying for Sacco membership or any other services, you will be deemed to have given consent to handling and processing of your personal data.
The personal data we process in relation to you and/or your company is provided by you/your representative, third parties, collected through the NDEGE CHAI SACCO SOC LTD website, publicly available sources or generated during your application for your membership and/or processing of your Sacco relationship with us, and through any media and our authorized Sacco agents and representatives.
When we collect and process your personal information, we ensure to keep it safe and to never sell it. We look after it properly and process it in accordance with our privacy principles set our below.
WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU?
Personal information you provide is processed fairly, lawfully and in a transparent manner. Personal data that we may process, as appropriate throughout the Sacco and membership process, but is not limited to:
- name and contact details (such as telephone number, e-mail address and postal address);
- date of birth;
- profession/occupation;
- gender;
- marital status;
- spouse and children;
- video, photographic images or audio recordings submitted or made as part of the Sacco business
- Bank accounts
We may also process sensitive or special personal data where relevant to the Sacco and membership processes, including where necessary to accommodate any disability needs.
When exercising our rights and obligations as Ndege Chai Sacco Soc Ltd under the Sacco contracts, it may be necessary to process sensitive data categories. Such sensitive may include but not limited to;
- membership record;
- previous membership experience available
- racial/ethnicity information;
- Country of origin
- Religion
HOW WE COLLECT YOUR PERSONAL DATA
The personal information we require about you (and, if applicable, other dependents under your Sacco membership) will be Ndege Chai Sacco Soc Ltd gathered and stored as set out in this Data Protection statement. Whilst there are several ways, we collect Personal Data we mainly obtain your information through the following means:
Approved Intermediaries
We may collect data directly or through our approved and authorized Sacco intermediaries and those appointed or acting on your behalf.
Service providers
We collect your data through various service providers that include but not limited to;
- Employer companies, locally and
- Our external advocates
- External auditors
- Auctioneers/debt collectors
- System vendors and insurers
- Medical practitioners and medical institutions
- Sacco creditors
- Regulators and government bodies
- Courier services
All these service providers have been approved or empaneled by NDEGE CHAI SACCO SOC LTD to provide the respective services.
Our marketing teams
If you are a Sacco intermediary/consultant or business partner, we may also collect your information from our day-to-day business activities with you, business referrals and your attendance at events, categories being collected and processed as per Data Protection Act 2019 laws of Kenya.
Our marketing team will collect documents from you and transmit the same to the company for processing of your Sacco membership where appropriate. This data will be used as per the intended purpose and in an event the data shall be used for commercial purpose, the same will be done in strict adherence of section 37 of the Data Protection Act 2019.
Your Personal Data may also be collected from third parties during membership processing such as references from previous bank/financial institution and government authorities/bodies.
PURPOSES FOR WHICH WE PROCESS YOUR PERSONAL DATA
If you are a member/customer, we mainly use your personal information so that we can provide a requisite service/product and manage your membership, including carrying out a credit risk survey, and to asses and serve your membership as part of a Sacco contract. However, there are several other reasons why we use your personal information as set out below:
- To consider whether to enter into a Sacco relationship with you;
- To comply with any Ndege Chai Sacco Soc Ltd rights or obligations to which we are subject
- To Processing of any info on membership in respect of an existing membership of
If you are an intermediary/consultant or business partner, we mainly use your personal information for day-to-day business activities with you and to provide you with information relevant to our services in accordance with our marketing strategy, including a periodic newsletter, invitations to events and communication of new products.
TO WHOM WE MAY DISCLOSE YOUR PERSONAL DATA
NDEGE CHAI SACCO SOC LTD operates a branch/Touch Points network hence any authorized persons working in our network may come into contact with your data. Your Personal Data may be disclosed to any of the following for any of the purposes outlined above:
- professional advisers, third party service providers, agents or independent contractors providing services to the NDEGE CHAI SACCO SOC LTD Sacco;
- any person in connection with litigation or other legal proceedings, to obtain legal advice or for establishing, exercising or defending legal rights;
- any person to whom disclosure is allowed or required by Law and/or Regulation;
- any court, tribunal, Regulatory Authority or Governmental Entity;
- any criminal records bureau, credit bureau or credit reference agency when conducting background checks;
- to third parties to provide references at your request or with your consent; and
- third parties to whom we may transfer our rights and/or obligations under any agreement, including but not limited to a potential merger or acquisition of all or part of the Group’s
In some circumstances, we may provide your personal data to a third party who will determine how and why it will be processed.
HOW LONG DO WE RETAIN YOUR PERSONAL DATA?
Personal Data is retained as long as necessary for the purpose for which it is collected and to meet legal, regulatory and operational requirements. Retention periods may differ for each Sacco membership taken. At the end of the retention period, non-identifiable data is kept for management information purposes. NDEGE CHAI SACCO SOC LTD has also put in place Data retention membership in line with Data Protection law.
NDEGE CHAI SACCO SOC LTD Sacco may also retain your contact information for the purposes of inviting you to renew any of your Sacco membership savings plan from time to time and may use your contact to send you notifications notifying you of our various products, progress and membership updates.
HOW WE PROTECT YOUR PERSONAL DATA
The security of your Personal Data is important to us and NDEGE CHAI SACCO SOC LTD implements technical and organizational measures to safeguard your personal data.
As a responsible organization, NDEGE CHAI SACCO SOC LTD manages its members’ data and authorized personnel may access your Personal Data. Your Personal Data may therefore be transferred to Sacco representatives, agents, regulators, external advocates & auditors, advisors or third-party service providers, and other third parties authorized to act on our behalf in a country that may not offer equivalent data protection or privacy laws to that of the country where you are located. When using external service providers, we require that they adhere to security standards mandated by NDEGE CHAI SACCO SOC LTD and regardless of where personal data is transferred, we take all steps reasonably necessary to ensure that it is kept securely.
You should be aware that the Internet is not a secure form of communication and sending and receiving information over the Internet carries with it risks including the risk of access and interference by unauthorized third parties. We do not accept responsibility or liability for the confidentiality, security or integrity of your Personal Data in connection with its transmission over the Internet.
MINORS
NDEGE CHAI SACCO SOC LTD do not issue Sacco membership to a minor. However, any personal data belonging to a minor where a membership of Sacco has been taken out by a parent or guardian on behalf of the minor, shall be processed/handled in accordance with section 33 of the Data Protection Act 2019
YOUR RIGHT TO OBJECT TO OR RESTRICT THE PROCESSING OF YOUR PERSONAL DATA
In some circumstances you may have the right to object to how NDEGE CHAI SACCO SOC LTD processing your Personal Data or restrict its processing but this does not mean you can decide or choose how we process your Personal Data.
Where is stated that we process your personal information on the basis of a legitimate interest, you are entitled to object to the processing in question on grounds relating to your particular situation, we will then stop processing the information unless we can demonstrate compelling legitimate grounds.
UPDATING YOUR MEMBERSHIP DATA
NDEGE CHAI SACCO SOC LTD Sacco will update your data from time to time as advised by you, you are obligated to ensure that NDEGE CHAI SACCO SOC LTD Sacco is always holding accurate and updated personal data.
UPDATES TO NDEGE CHAI SACCO SOC LTD SACCO PRIVACY STATEMENT
The NDEGE CHAI SACCO SOC LTD Privacy Statement may be updated from time to time and it is your responsibility to visit our websites and other communication platforms regularly for the most recent version.
ACCESSING, CORRECTING AND ERASURE OF YOUR PERSONAL DATA
You have the right to ask for your personal data to be deleted, for example when there is no longer a valid reason to possess it, to be given details about the personal information concerning you that we hold and why and how we use it.
If you wish to contact us for the personal data subject to data processing, you may do so by mail to NDEGE CHAI SACCO SOC LTD, email; DPO@ndegechaisacco.com. If you wish to correct or request deletion of your Personal Data or have questions regarding this statement please email: DPO@ndegechaisacco.com.
You have a right to demand the erasure of your personal data, for example where the personal information we collected is no longer necessary for the original purpose or, where you withdraw your consent and where the legal ground for processing was consented. However, this need to be balanced against other factors, for example, according to the type of personal information we hold about you why we have collected it, there may be some legal and regulatory obligations which mean we cannot comply with your request.
We take reasonable steps to ensure that the personal information we hold about you is accurate and complete. However, if you do not believe this to be the case, contact us and ask us to update or amend it.
Right to Data Portability
In certain circumstances, you have a right to ask that we transfer any personal information that you have provided to us to another third party of your choice. Once transferred, the other party will be responsible for looking after your personal information.
RIGHT TO OBJECT DIRECT MARKETING
You can ask us to stop sending you marketing message at any time. You have the right not to be subjected to decisions based solely on automated processing, including profiling, which produce legal effects concerning you or similarly significantly affect you.
CONSENT
You understand that by using our site services and our products you agree to be bound by this statement of privacy. If you agree to this statement on behalf of an entity, you represent and warrant that you have the authority to bind that entity to our privacy statement, by using our products and/or accessing our site, if you do not accept it in entirety you must inform us immediately indicating what part of our privacy statement you are not agreeable to.
By providing your personal information or personal information of someone included in your membership to NDEGE CHAI SACCO SOC LTD Sacco, you acknowledge that we may use it only in the ways set out in this Data Protection statement.
Right to withdraw consent
For certain uses of your personal information, we may ask for your consent. Where we do this, you have the right to withdraw your consent to further use of your personal information. Withdrawal of consent would not invalidate any processing we carried out prior to your withdrawal of consent. Please note in some cases we may not be able to process your Sacco membership requests if you withdraw your consent.
We do not generally rely on consent for processing personal information in relation to Sacco contracts; we generally rely on other legal grounds, such as the basis that processing is necessary for the performance of a contract to which you are party.
Right to complain
If you have concerns in relation to the way NDEGE CHAI SACCO SOC LTD processes your personal data, you can either contact us by writing or email under aforementioned contacts.
Obtaining a copy of the privacy Membership.
From time to time, we may need to make changes to this Data Protection Statement, for example as a result of government regulations, new technologies or other developments in data protection
laws or privacy generally. We encourage you to review periodically to see the most update Data Protection Statement. A copy of this statement is obtained by contacting us via email
DPO@ndegechaisacco.com and also annexed to all our Sacco membership documents.
