Privacy policy

Our privacy policy

At Mophones (“Mosub Kenya Ltd”) we take your data and privacy very seriously. Our privacy policy below is aimed at keeping your personal and device data secure and stored in a legally compliant manner. This policy details:

  • Why we need some of your personal  information
  • How we collect, use, store, transfer and share it
  • How we process information related to your devices

Why do we need some of your personal  information?

  • Mophones is required to undertake know-your-customer (KYC) and due diligence measures to verify the identity of all customers that Mophones interacts with. Therefore, the processing of your personal and device information by Mophones serves to avoid identity theft and to comply with anti-money laundering legislation 
  • We require and process your personal and device information to substantiate the performance of the contract into which you will enter with us in the case of a finance product. 
  • We may also process your personal and device information from time to time to enable us to improve the quality of the devices and services that we offer and to offer you additional products and services.


When do we collect personal and device information?

We collect your personal and device information when you:

  • Sign up to purchase our products and services and fill out our customer registration form
  • Respond to our know-your-customer screening questions
  • Possess or use our products
  • Use the Mophones customer application on your device 
  • Make payments to u
  • Apply to us for employment.
  • Call or otherwise contact us including via SMS, USSD, website, or an in-store visit
  • Use the Mosub mobile application software (“App”) on your device
    • The App is available on the Google Play Store or Apple App Store
  • Participate in market studies, surveys or promotions


What personal information and device information do we process?

We process the following information about you:

Information you give us when we enter into a contract

    • When you purchase our products or services you provide us with your personal details in our customer agreement. These include your name, email address, occupation, birth date, gender, mobile number, national identity number (or other similar identification numbers as applicable), geographical location, photograph, and physical address.
    • For some products we might require additional KYC information from you such as your daily income/purchase potential or any information needed to comply with the terms and conditions of our contract with you.

    The collection of the above information is mandatory. Failure to freely consent and provide any of the above-listed information might prevent us from entering into an agreement with you and would prohibit us from providing any products or services to you.

    Information we collect about you from the continued use of our products and services

      • Each time you use our App we will automatically collect personal data including device, content, identity and usage data. We collect this data using cookies and other similar technologies.
      • We process the payments you make to us and your account information when using our services.
      • We process your overall account balance and payment history.
      • We also process in-app transaction history, preferences, feedback and survey responses 
      • We process your product location when analyzing your product performance, during repairs and replacement of the products and services, and while investigating loss or fraud.

      We also may collect other information about you, your device and your use of the App in ways that we describe to you at the time of collection or otherwise with your consent.

      Information from our website

      If you visit our website, we may collect information about you to distinguish you from other users and to improve your experience using cookies.

      Cookies

      Mophones uses cookies when you visit our website or mobile applications. Any personal data provided to or collected by Mophones via cookies and other tracking technologies is controlled by Mophones. Kindly familiarize yourself with our cookie practices.


      What are cookies?

      A cookie is a small file of letters and numbers that websites send to the browser which are stored in the user interface, which might be our computer, phones or applications, your personal computer, a mobile phone, a tablet, or any other device. Cookies allow us to distinguish you from other users of our website and mobile applications, which helps us to provide you with an enhanced browsing experience. For example we use cookies for the following purposes:

      • Recognising and counting the number of visitors and to see how visitors move around our website and mobile apps when they are using it (this helps us to improve the way our website works, for example by ensuring that users can find what they are looking for).
      • Identifying your preferences and subscriptions e.g. language settings, saved items, and items stored in your cart; and
      • Sending you notifications and commercial/advertising messages tailored to your interests.
      • Our approved third parties may also set cookies when you use our website and mobile app. Third parties include search engines, providers of measurement and analytics services, social media networks and advertising companies.


      Cookie preferences

      We use cookies to collect information and store your online preferences. By managing your cookie preference you enable or disable a specific set of cookies based on predefined categorisation:

      • Strictly Necessary Cookies: This cookie enables website functionality and is automatically enabled when you use the website. This is essential to the operation of the website to help you make the cart and checkout process possible. You cannot disable this category of cookie.
      • Analytics Cookies: It is important for us to understand how you use the website, for example, how efficiently you are able to navigate around it, and what features you use. Analytics Cookies enable us to gather this information, helping us to improve our website and your experience of it.
      • Functional Cookies: Functionality Cookies allow the website to remember the choice you made and provide you with enhanced personal features. The information these cookies collect is anonymised and doesn’t track your browsing activity on the website.
      • Targeting Cookies: It is important for us to know when and how often you visit the website, and which parts of it you have used (including which pages you have visited and which links you have visited). As with Analytics Cookies, this information helps us to better understand you and, in turn, to make our website and advertising more relevant to your interests. Some information gathered by Targeting Cookies may also be shared with third parties.
      • Third Party Cookies: Third party Cookies are not placed by us; instead, they are placed by third parties that provide services to us and/or to you. Third party Cookies may be used by advertising services to serve up tailored advertising to you on our website, or by third parties providing analytics services to us (these Cookies will work in the same way as Analytics Cookies described above).
      • Persistent Cookies: Any of the above types of Cookie may be a persistent Cookie. Persistent Cookies are those which remain on your computer or device for a predetermined period and are activated each time you visit our website.
      • Session Cookies: Any of the above types of Cookie may be a session Cookie. Session Cookies are temporary and only remain on your computer or device from the point at which you visit our Site until you close your browser. Session Cookies are deleted when you close your browser.



      Consent

      Before Cookies are placed on your computer or device, you will be shown a prompt requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies (unless those Cookies are strictly necessary); however certain features of our website may not function fully or as intended. You will be given the opportunity to allow and/or deny different categories of Cookie that we use.

      In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third- party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.


      The links below provide instructions on how to control Cookies in all mainstream browsers:


      Information from third parties

        We process information about you that we receive from third parties including Credit Reference Bureaus, Mobile Network Providers, Data and Analytics Firms, Business Process Outsourcing Firms, Financial Institutions and Firms performing credit scoring, KYC, fraud, money- laundering, anti-financial crime or similar screening directly or on our behalf., as well as marketing partners and analytics providers that may use mobile tracking technologies and/or website cookies to distinguish you from other users 


        Information obtained from analytic tools in our products

          We process information related to your devices and the application on your device including temperature settings, battery life, SIM communications and performance, and customer usage information


          Information obtained from our App

            With your permission, the App may access the following device permissions, depending on your device’s operating system and the version of the App that you have downloaded:

            • We may request you to upload photos as part of our identity verification process. 
            • We will retrieve information about your contact lists (such as contact names and numbers, contact frequency, and date of last contact). We may use this information in our credit and underwriting models to determine whether you are eligible for our services. We use automated processing to understand your network relationships, and this also helps our fraud models verify your identity. We will never reach out to any of your contacts or provide any of your information to your contacts unless you separately and expressly direct us to do so.
            • Accounts on your device: We check the list of user accounts created on your device and the email address used to create each account. This helps our fraud models verify your identity. We also use this information in its credit and underwriting models to determine ongoing credit worthiness..
            • Location: This helps our fraud models verify your identity. We also use this information in our credit and underwriting models to determine ongoing credit worthiness. We also use location data for research purposes.
            • Phone status and identity: When you register the App, we will retrieve your phone number from your device automatically. This ensures that the mobile number is active and accurate, and that it is linked to the device you are using to open the account.
            • Text messages: We will retrieve information about the SMS stored in your device (such as message ID, direction, timestamp, phone number, and keywords). We use this information in its credit and underwriting models. We use automated processing to understand your financial activity, and this also helps our fraud models verify your identity. We will never share the contents of your text messages.
            • Receive text messages: This is used to automatically confirm the one-time password (OTP) sent to the user via SMS.
            • Read, modify, or delete the contents of your SD card: We may request you to upload photos of your identification document. We may also request you to upload photos of documents as proof of income.
            • Run foreground service: This permission is needed by the App to upload photos.
            • Run at startup: This allows the App to send notifications to your device upon restart of your device.
            • View and change network connectivity: This is used to notify us when network connectivity changes so that we can determine whether you are connected to the internet or not.
            • View Wi-Fi connections: We use the IP address and network type of your device to detect and prevent fraud.
            • Receive data from the internet. We need this permission in order to send requests through the App and to allow the App to access the internet.
            • Prevent phone from sleeping: This permission is required by some of the features and services within the App, such as in-app messaging.
            • Retrieve running apps: We will retrieve a list of apps installed on your device. We use this information in our credit and underwriting models.


            How does Mophones process my personal information and device information?

            We process your personal information for the following purposes:

            • To carry out our obligations relating to your contract including communicating with you, providing you with our products and services under our contract and related information.
            • To develop your credit profile and determine your eligibility for additional products and services that we may offer from time to time.
            • To communicate with you about any delinquencies in payments.
            • To investigate cases of fraud or illegal activity.
            • To improve, test, and monitor the effectiveness of our products and services.
            • To develop and test new features and notify you about changes to our services.
            • To improve the safety and security of our services.
            • To comply with any applicable legal and/or regulatory requirements.

            We may also combine the information we receive from third party sources with the information you give to us and the information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).


            We process information about your devices for the following purposes:

            • To develop your credit profile.
            • To activate or deactivate your device depending on its credit status.
            • To monitor and investigate whether your device is being used in accordance with our terms and conditions found on our website and in the relevant product manual.
            • To investigate cases of fraud or illegal activity.
            • To monitor device performance including battery performance and charging information for the purposes of troubleshooting, data analysis, testing, research, statistical and survey purposes.
            • To analyze customer usage in order to improve efficiency of the device features.
            • To determine user location information to tailor our services according to the needs of a specific location.


            Does Mophones share my information with any third parties?

            We may share your information with selected third parties including:

            • Business processing outsourcing firms including those handling customer care, customer communications (such as WhatsApp Business) and payment collections.
            • Credit reference bureaus and other similar third parties offering credit scoring information, including reporting your credit histories with such parties.
            • IT service providers including Software developers, platform providers or cloud providers.
            • Firms performing Credit Scoring or similar services directly or on our behalf.
            • Firms performing KYC, fraud, money- laundering, anti-financial crime or similar screening directly or on our behalf.
            • Data processing firms, analytics firms or search engines to help us analyze our customer data.
            • Academic or research institutions.
            • Other business partners, suppliers and sub-contractors for the performance and execution of any contract we enter into with them or you.
            • Advertisers and advertising networks to market products and services to you.
            • Other affiliated entities within the Mophones group of companies. Any person or entity who invests in or finances (or may potentially invest in or finance), directly or indirectly, Mophones, and any of such person’s affiliates, officers, directors, employees, professional advisers, auditors, insurers or insurance brokers, service providers, partners and any delegate, agent, manager, administrator, nominee, attorney, trustee or custodian of any such person.
            • When required by law, regulation, court order or other court proceedings.


            What happens to my personal information if there was a change of control?

            If we sell or otherwise transfer part or the whole of Mophones or our assets to another organization (in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, liquidation), your information may be among the items sold or transferred. The buyer or transferee will have to honor the commitments we have made in this Policy.


              How do we store and transfer our personal information and device information?

              The personal information and device information that is collected through the provision of our services may be stored and processed in any country in which Mophones, its affiliates or service providers maintain facilities, subject to the requirements of any applicable laws.

              By using the services and as part of our customer agreement, you consent to the transfer, storing or processing of your personal information and device information to any country in which Mophones, its affiliates or service providers maintain facilities. In these cases, we ensure that both ourselves and our service providers take adequate and appropriate technical, physical and organizational security measures to protect your personal information and device information and the use and disclosure of your personal information and device information as described in this policy.

              We use appropriate, reasonable safeguards to help keep your personal information and device information secure. We also take reasonable steps to verify your identity before granting you access to the service. As you will know, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data during transmission, and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.


              How long do we keep your personal information and device information?

              We store your personal information and device information for the duration of your repayment period. This period can be found on your customer agreement. Once your device has been repaid or upon the termination or deactivation of your account, Mophones, its affiliates, or its service providers may retain your personal and device information for as long as is required under applicable law in order to determine your eligibility for additional products or services, to perform analytics and help improve future product offerings and services or otherwise for backup, archival, and/or audit purposes or to comply with any applicable law.


              What do I need to know about profiling and automated decision making?

              As part of being a highly technical and innovative company, we may use Automated Decision Making (ADM) in order to improve your experience or to help fight financial crime. For example, so that we can provide you with fast and efficient services, we may use ADM to verify your identity documents or to confirm the accuracy of the information you have provided to us. None of our ADM processes have a legal effect on you.


              What are my rights?

              Subject to applicable data privacy laws:

              • You have the right to correct any personal information we hold on you that is inaccurate, incorrect, or out of date.
              • You have the right to request that we stop processing your personal information if this processing causes or is likely to cause unwarranted substantial damage or distress.
              • You have the right to request that we stop processing your personal information for direct marketing purposes.
              • You may have the right to confirm which of your personal information we possess and to request the identity of any third parties who have access to this information.
              • You have the right to request that any decision which significantly affects you is not based solely on automated decision making.


              How can I reach you?

              • If you have any questions about this privacy policy or our products and services, please send us an e-mail to support@mophones.co.

              Mophones may modify or update this policy from time to time, so please review it periodically. We may provide you additional forms of notice of modifications or updates as appropriate under the circumstances. Your continued use of our products and services after any modification to this policy will constitute your acceptance of such modification.