BIDII CHAMA PRIVACY POLICY

INTRODUCTION

Diamond Trust Bank Kenya Limited (“us”, “we”, or “our”) operates the Bidii Chama website, the Bidii Chama Web Portal, Bidi Chama USSD (Unstructured Supplementary Service Data), and the Bidii Chama Mobile App mobile application (the “Service”).

This policy informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

1.0 Definitions

1.1 Service

Service means the Bidii Chama website, Bidii Chama Web Application, the Bidii Chama Mobile application and Bidii Chama USSD operated by Diamond Trust Bank Kenya Limited.

1.2 Personal Data

Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

1.3 Usage Data

Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

1.4 Cookies

Cookies are small pieces of data stored on your device (computer or mobile device).

1.5 Data Controller

Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the way any personal information is, or is to be, processed.

For the purpose of this Privacy Policy, we are the Data Controller of your Personal Data.

1.6 Data Processors (or Service Providers)

Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

1.7 Data Subject (or User)

Data Subject is any living individual who is using our Service and is the subject of Personal Data.

 

2.0 Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

We collect your personal information with your knowledge and consent when you do any of the following:
a) Register for the Bidii chama services by providing your information.
b) ask for more information about a product or service or contact DTB with a query or complaint.
c) respond to or participate in a survey, marketing promotion, prize competition or special offer.
d) interact with us as a supplier, agent, merchant or dealer as prescribed in this statement; or
e) visit any of our premises.

1. f) We may also collect your information from other organizations including credit-reference bureaus, fraud prevention agencies and business directories.
2. g) visit, access or use Bidii Chama or third-party websites.

We will also receive personal data about you from various third parties and public sources.

 

2.1 Types of Data Collected

2.1.1 Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

• Your identity information, including your name, photograph/selfie, address, location, phone number, identity document type and number, Tax number date of birth, email address, age, gender, login name, screen name, nickname, or handle and mobile number portability records.
• Your transaction information when you use Bidii Chama services.
• Information provided by you or from your use of Bidii Chama services.
• Your contact with us, such as when you call us or interact with us.
• Your social media information or emails to us.
• Your public record or data that you have made public.
• Your preferences for products and services, based on information provided by you or on your use of Bidii Chama services.
• Information about your bank account numbers and SWIFT codes or other banking information.
• Your name, family details, age, profiling information such as level of education, bank account status, income brackets, etc. collected as part of surveys conducted on our service or by our agents.
• Your personal information from users for the purpose of identity verification through OCR technology. This may include but is not limited to government-issued identification documents and other registration documents. The information collected may contain personal details, including full name, date of birth, address, and a photograph.

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

2.1.2 Business Data

While using our Service, we may ask you to provide us with certain identifiable information that can be used to contact or identify your Business or Business Activity (“Business Data”). This information may include, but is not limited to:

• Business Registration Information
• Business Name
• Business Contact information
• Business Location
• Business Stakeholder Information
• Web Cookies and Usage Data

2.1.3 Usage Data

We will use the data you supply, including your government-issued Identification numbers, to capture additional secondary data to enrich your customer data for regulatory compliance purposes.

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device (“Usage Data”).

This Usage Data may include information such as your computer’s Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Service by or through a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

2.1.4 Location Data

We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customize our Service.

You can enable or disable location services when you use our Service at any time, through your device settings.

2.1.5 Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with small amounts of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies are also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

• Session Cookies. We use Session Cookies to operate our Service.
• Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
• Security Cookies. We use Security Cookies for security purposes.

3.0 Use of Data

Diamond Trust Bank Kenya Limited uses the collected data for various purposes:

• To provide and maintain our Service
• To notify you about changes to our Service
• To allow you to participate in interactive features of our Service when you choose to do so
• To provide customer support
• To gather analysis or valuable information so that we can improve our Service
• To monitor the usage of our Service
• To detect, prevent and address technical issues
• Responding to any of your queries or concerns
• To carry 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
• To prevent and detect fraud or other crimes and for debt recovery
• To administer any of our online platforms/websites
• In business practices including quality control, training and ensuring effective systems operations
• To bill you for using our services or taking the appropriate amount of credit from you
• To understand how you use our network, products and services for purposes of developing or improving products and services
• For research, survey and other scientific or business purposes
• To provide you with news, special offers and general information about other goods, services and events which we offer that are like those that you have already purchased or enquired about unless you have opted not to receive such information
• To verify your identity information through publicly available and/or restricted government databases to comply with applicable regulatory requirements.

 

 

 

4.0 Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), Diamond Trust Bank Kenya Limited legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

Diamond Trust Bank Kenya Limited may process your Personal Data because:

• We need to perform a contract with you;
• You have given us permission to do so;
• The processing is in our legitimate interests, and it’s not overridden by your rights;
• To comply with the law.

5.0 Retention of Data

Diamond Trust Bank Kenya Limited will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Diamond Trust Bank Kenya Limited will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

6.0 Transfer of Data

Your information, including Personal Data, may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside KENYA and choose to provide information to us, please note that we transfer the data, including Personal Data, to KENYA and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Diamond Trust Bank Kenya Limited will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

7.0 CHAMA LOANS

• The chama loans facilitated through this app are peer-to-peer (P2P) and are not issued or guaranteed by Bidii Chama or the bank. All loans are funded and managed by the chama members as per the group’s independent rules and agreements. Bidii Chama only provides a digital platform to facilitate record-keeping, transaction management, and communication within the group.
•  The loan terms, conditions, and eligibility criteria for loans are determined and agreed upon by the chama members. The app does not regulate or enforce group-specific rules. Users are responsible for adhering to the bylaws of their chama. Any disputes regarding loan amounts, interest rates, repayment timelines, or penalties must be resolved internally by the chama.
•  Loan agreements are established between individual members of the Chama. Bidii Chama is not a party to these agreements. Loan terms, such as interest rates, repayment periods, and penalties, must be recorded in the app by the group administrator for transparency. Members are advised to review all terms carefully before accepting any loan.
•  Users must ensure that they fully understand their group’s loan terms and conditions before participating in lending or borrowing activities. Borrowers are responsible for timely repayment as per their chama’s agreement.
•  Bidii Chama is a tool to support group financial management and does not provide loans, guarantee repayments, or mediate disputes.
•  The app is not responsible for any losses, disagreements, or defaults that occur as part of lending and borrowing activities. Users acknowledge that their group operates independently, and the app is not liable for the group’s decisions or actions.
•  All loan records are confidential and accessible only to authorized group members. Bidii Chama does not share or use financial data for purposes outside of app functionality, as outlined in our Privacy Policy.

7.1 Business Transaction

If Diamond Trust Bank Kenya Limited is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

7.2 Disclosure for Law Enforcement

Under certain circumstances, Diamond Trust Bank Kenya Limited may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

1. a) Law-enforcement agencies, regulatory authorities, courts or other statutory authorities in response to a demand issued with the appropriate lawful mandate and where the form and scope of the demand is compliant with the law
2. b) Our subsidiaries, associates, partners, software developers or agents who are involved in delivering the services you order or use
3. c) Publicly available and/or restricted government databases to verify your identity information in order to comply with regulatory requirements
4. d) Debt-collection agencies
5. e) Survey agencies that conduct surveys our behalf
6. f) Any other person that we deem legitimately necessary to share the data with.

7.3 Legal Requirements

Diamond Trust Bank Kenya Limited may disclose your Personal Data in the good faith belief that such action is necessary to:

• To comply with a legal obligation
• To protect and defend the rights or property of Diamond Trust Bank Kenya Limited
• To prevent or investigate possible wrongdoing in connection with the Service
• To protect the personal safety of users of the Service or the public
• To protect against legal liability

7.4 Security of Data

Diamond Trust Bank has put in place technical and operational measures to ensure integrity and confidentiality of your data via controls around: information classification, access control, cryptography, physical and environmental security and monitoring and compliance The security of your data is important to us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

8.0 “Do Not Track” Signals Under California Online Privacy Protection Act (CalOPPA)

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

9.0 Your Data Protection Rights

You have certain data protection rights, Diamond Trust Bank Kenya Limited aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data, we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

• The right to be informed that we are collecting personal data about you
• The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your Personal Data.
• The right of restriction. You have the right to request that we restrict the processing of your personal information.
• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where Diamond Trust Bank Kenya Limited relied on your consent to process your personal information.

If you wish to exercise any of the rights set out above, please contact us on [email protected].

Please note that we may ask for specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within a reasonable time. Occasionally it could take us longer if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

10.0 Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

10.1 Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

10.2 Behavioral Remarketing

Diamond Trust Bank Kenya Limited uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Services

10.2.1 Google AdWords

Google AdWords remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: Here

Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

10.2.2 Twitter

Twitter remarketing service is provided by Twitter Inc.

You can opt-out from Twitter’s interest-based ads by following their instructions: https://support.twitter.com/articles/20170405

You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy

10.2.3 Facebook

Facebook remarketing service is provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950

To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217

Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation

 

11.0 Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

12.0 Children’s Privacy

Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

13.0 Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

14.0 Contact Us

If you have any questions about this Privacy Policy, please contact us by email: [email protected] or phone: +254 111 189 999.