OUR COMMITMENT TO PRIVACY
Throughout this policy, we use the term "personal information" to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been aggregated and/or anonymized so that it does not identify a specific user.
THE INFORMATION WE COLLECT
When you visit the website or use one of our mobile applications or other Services, we collect your IP address, and standard web log information, such as your browser type and the pages you accessed on our website. We also may collect Geolocation Information (defined below). If you do not agree to our collection of this information, you may not be able to use our Service. If you pay for a service or a product using the TinyPesa© URL and you get a security prompt from a Mobile wallet company or service, TinyPesa© collects details of the transaction such as phone number, transaction amount, time transaction took place, geo-location (If turned on we might, note that information based on the preferences you selected), Name (Optional) but part of the Mobile Money wallet details, TinyPesa business that collected the funds
If you open a TinyPesa© account, we collect the following information from you:
- Account Information - text-enabled cellular/wireless telephone number, machine or mobile device ID and other similar information.
- Identification Information - your name, street address, email address, date of birth, and Last 4 digits of Huduma number (or other governmental issued verification numbers).
- Device Information - information about you: (a) from your mobile device or computer such as your device type, machine or mobile device identification number, Geolocation Information, time zone, language setting, browser type, and IP address, and (b) from third parties for purposes of transaction processing, identity verification, fraud detection or prevention and other similar purposes. For fraud prevention purposes, we also may link your machine ID with the machines of others who use your same payment cards.
- Geolocation Information - information that identifies with reasonable specificity your location by using, for instance, longitude and latitude coordinates obtained through GPS, Wi-Fi, or cell site triangulation. We will collect this data for fraud and risk purposes. In addition, some of our Services may ask you for permission to share your current location within your device settings to enhance our Services. If you do not agree to our collection of Geolocation Information, our Services may not function properly when you try to use them. For information about your ability to restrict the collection and use of Geolocation Information to enhance our Services, please refer to the settings available in your device.
- Social Web Information - including but not limited to your Facebook Connect credentials and email account information. If you authorize Facebook Connect, the plug in allows us access to your email address, Facebook friends list, and public profile (including profile picture). We also allow you to import data from other social web services, including but not limited to Twitter, gmail, and email service providers. Social and e-mail contact information helps you connect to friends and contacts for invitation and payment transmission purposes (as well as helping us improve the Services and fight fraud). Additionally, another TinyPesa© user may mention you in a transaction to which you are not a party by “tagging” your username in a transaction note or comment. When you are mentioned in a transaction note or comment into which you have visibility (e.g., a public transaction, a “friends only” transaction by one of your TinyPesa© friends, or a comment on either such transaction), a link to your TinyPesa© profile will appear in the transaction note or comment and, if your push notifications are turned on, you will receive a push notification about the mentions. You may manage certain contact preferences and notifications in your account settings.
- Financial Information - bank account online login information, bank account and routing numbers, and Paybill and Till (Lipa na Mpesa) numbers, linked to your TinyPesa© account. TinyPesa© does not share financial information with third party social networking services such as those listed in the prior bullet.
We are committed to providing a safe, secure and all-around great service. Therefore, before permitting you to use the Services, we may require additional information from you we can use to verify your identity, address, or other information or to manage risk and compliance throughout our relationship. We may also obtain information about you from third parties such as identity verification, fraud prevention and similar services.
When you are using the Services, we collect information about your account transactions and we may collect Geolocation Information and/or information about your computer or other access device for fraud prevention and other similar purposes.
Finally, we may collect additional information from or about you in other ways not specifically described here. For example, we may collect information related to your contact with our customer support team or store results when you respond to a survey.
INFORMATION FROM CHILDREN
The Services are not directed to children under the age of 13. If we obtain actual knowledge that we have collected personal information from a child under the age of 13, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from a child under the age of 13.
Do Not Track: Do Not Track ("DNT") is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We respect your privacy unlike most big corporations and will respond to DNT signals.
HOW WE PROTECT & STORE PERSONAL INFORMATION
We store and process your personal information using third party servers located in data centers in the Republic of Kenya. This information is protected by physical, electronic and procedural safeguards in compliance with applicable Kenyan legal regulations. We also use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our office and files, and we authorize access to personal information only for those employees who require it to fulfill their job responsibilities.
We strive to ensure security on our systems. Despite our efforts, we cannot guarantee that personal information may not be accessed, disclosed, altered or destroyed by breach of our administrative, managerial and technical safeguards. Therefore, we urge you to take adequate precautions to protect your personal data as well, including never sharing your TinyPesa© password with anyone.
If TinyPesa© learns of a systems security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Services, you agree that TinyPesa© may communicate with you electronically. TinyPesa© may post a notice on the website or mobile application if a security breach occurs. We may also send an email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice of a security breach), please email us at privacy@TinyPesa©.com
HOW WE USE THE PERSONAL INFORMATION WE COLLECT
Our primary purpose in collecting personal information is to provide you with a safe, smooth, efficient, fun and customized experience. We may use your personal information to:
- provide the services and customer support you request.
- process transactions and send notices about your transactions or your network activity.
- resolve disputes, collect fees, and troubleshoot problems.
- prevent potentially fraudulent, prohibited or illegal activities, and enforce our User Agreement through the use of our risk and fraud tools which may include use of Account Information, Identification Information, Financial Information, Device Information, Social Web Information and Geolocation Information.
- create an account connection between your TinyPesa© account and a third-party account or platform.
- customize, personalize, measure, and improve our services and the content and layout of our website.
- send you updates about new products and services that we are offering to customers.
- compare information for accuracy and verify it with third parties.
- perform other duties as required by law; and
- if you elect to share your Geolocation Information, we will use this information to enhance the security of the Services and we may use this information to provide you with location-specific options, functionality, offers, advertising, search results, or other location-specific content.
HOW WE SHARE PERSONAL INFORMATION WITHIN THE TINYPESA© NETWORK
To process payments on TinyPesa©, we need to share some of your personal information with the person or company that you are paying or is paying you. Your contact information, date of sign-up, the number of payments you have received and other verification metrics like social graph activity may be provided to users or companies when you transact with, on, or through TinyPesa©.
We work with vendors to enable them to accept payments from you using TinyPesa©. In doing so, a vendor may share information about you with us, such as your mobile phone number or TinyPesa© username, when you attempt to pay that vendor. We use this information to confirm to that vendor that you are a TinyPesa© customer and that the vendor should enable TinyPesa© as a form of payment for your purchase.
Regardless, we will not disclose your phone number or bank account number or Mobile money wallet Password or PIN such as MPESA pin ( we do not have access to this , your PIN number is only known to you) to anyone you have paid or who has paid you through TinyPesa©, except with your express permission or if we are required to do so to comply with a subpoena or other legal process.
HOW WE SHARE PERSONAL INFORMATION WITH OTHER PARTIES
TinyPesa© does not share your personal information with third parties for their promotional or marketing purposes.
Some personal information is public information and may be seen by anyone on the internet, whether or not they have a TinyPesa© account. Public information may also be seen, accessed, reshared or downloaded through TinyPesa©'s APIs or third-party services that integrate with our products.
Public information for personal profiles includes your TinyPesa© username, profile photo, first and last name, month and year of TinyPesa© account creation, and public transactions in which you've been involved.
Public information for business profiles includes TinyPesa© username, profile and background photos, business name, business description, and QR code. Public information for business profiles may be indexed by and searchable on search engines.
In addition to any public information, your TinyPesa© friends list may be seen by any logged-in TinyPesa© user.
We may share your personal information with:
- Our parent company, Neverest Ltd. and affiliates and subsidiaries it controls, but only for purposes allowed by this document.
- Law enforcement, government officials, or other third parties if Neverest Ltd. is compelled to do so by a subpoena, court order or similar legal procedure, when it is necessary to do so to comply with law, or where the disclosure of personal information is reasonably necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of the TinyPesa© User Agreement, or as otherwise required by law.
- Third party service providers who assist us in providing services to you or who provide fraud detection or similar services on our or any vendor’s behalf.
- The other TinyPesa© user participating in the transaction and, depending on the privacy setting of each TinyPesa© account transaction, your TinyPesa© friends and the TinyPesa© friends of the other user participating in the transaction, or the public, through the TinyPesa© feed on our website and mobile application and elsewhere on the internet.
- Service providers under contract who help with parts of our business operations (for example, fraud prevention, payment processing, or technology services). Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit.
- Other third parties with your consent or at your direction to do so, including if you authorize an account connection with a third-party account or platform.
- Information that we share with a third-party based on an account connection will be used and disclosed in accordance with the third-party’s privacy practices. Before authorizing an account connection, you should review the privacy notice of any third-party that will gain access to your personal information as part of the account connection. For example, personal information that TinyPesa© shares with a third-party account or platform such as a social media account may in turn be shared with certain other parties, including the general public, depending on the account’s or platform’s privacy practices.
- If you choose to use Siri or iMessage to send payments via TinyPesa© or to otherwise use the Services, such use is subject to Apple’s terms and conditions for use of iMessage and/or Siri, as applicable, and the terms of the TinyPesa© User Agreement. By using Siri or iMessage, you authorize us to share some of your TinyPesa© account data (including your friends list, list of persons you have transacted with most recently and most frequently, transaction instructions, and transaction notes) with Apple to allow it to facilitate transaction requests made through Siri or iMessage on iOS. Data shared with Apple will be used pursuant to Apple’s then-current user agreements and privacy policies. You can grant or revoke Apple’s access to TinyPesa© on iOS at any time under the “Siri” or “iMessage” settings on your iPhone.
HOW YOU CAN ACCESS OR CHANGE YOUR PERSONAL INFORMATION
You can review and update your personal information in your account settings at any time by logging in to your account.
LINKS TO OTHER SERVICES OR SITES
The Services may contain links to (or allow you to link to) other third-party services or websites. TinyPesa© does not control the information collection of third-party services or websites that can be reached through such links. We encourage our users to be aware when they are linking to a third-party service or website and to read the privacy statements of any third-party service or website that collects personally identifiable information.
HOW TO CONTACT US