Data Protection Policy and Procedures
Data Processing Terms and Conditions for Treasure Store Limited
Treasure Store Limited is committed to protecting and respecting your privacy.
Scope of the Data Processing Terms and Conditions
These Data Processing Terms and Conditions together with our Terms of Use and Loan Account
Agreement as set out ………….. and any additional terms of use applies to your use of:
1. SOT mobile application software (App) available on the Google Play Store (App Site), once
you have downloaded or streamed a copy of the App onto your mobile telephone or handheld
device (Device).
2. Any of the services accessible through the App (Services) or those available on the App Site
or other third-party Sites (Service Sites).
This policy sets out the basis on which any personal data we collect from you, or that you
provide to us, will be processed by us
Please read the following carefully to understand our views and practices regarding your
personal data and how we will treat it. By downloading the App, you confirm that you have
read, understood and accept the terms of this Policy set out hereunder. You also consent to
the collection, use, storage, processing and disclosure of your personal information in the
manner set out in these Terms and Conditions.
You can withdraw your consent to our collection, processing or use of your personal
information at any time by making a request on customercare@sot.co.ke or via a contact
link on the App. Once fulfilled, Treasure Store Limited will proceed to close your account.
A. Information we may collect from you
We may collect and process the following data about you for the purposes set out in C below.
a) Information you give us about you (Submitted information):
This information may be collected through any of the following mechanisms:
• provided by filling in forms in the App or App Site (together our Sites);
• provided by corresponding with us (for example, by e-mail or chat);
•provided by registering to use the App Site, downloading or registering the App,
subscribing to any of our Services (such as applying for a loan), searching for an app or
Service, sharing data via the App’s social media functions, entering a competition,
promotion or survey, and reporting a problem with the App, our Services, our App Site or
any of Our Service Sites.
This information may include your name, address, e-mail address and phone number, the
Device’s phone number, SIM card details, age, username, password and other registration
information, financial and credit information (including your mobile money account details,
bank account details, and bank verification number, where applicable), personal description and
photograph.
b) Information we collect about you and your device.
Each time you use one of our Apps we may automatically collect the following information:
technical information, including the type of mobile device you use, unique device
identifiers (for example, your Device’s IMEI or serial number), information about the
SIM card used by the Device, mobile network information, your Device’s operating
system, the type of browser you use, or your Device’s location and time zone setting
(Device Information);
information stored on your Device, including contact lists, call logs, SMS logs, Facebook
friends, contact lists from other social media accounts, photos, videos or other digital
content (Content Information);
• data from your use of any other third-party application on the Device or the Service Sites;
and
•details of your use of any of our Apps or your visits to any of Our Service Sites;
including, but not limited to, traffic data, location data, weblogs and other communication
data (Log Information).
c) Location information.
We may also use GPS technology OR other location services to determine your current location
d) Information we receive from other sources (Third Party Information).
Due to the nature of the Services which we provide, we are required to work with a number of
third parties (including credit reference agencies and mobile network providers) and we may
receive information about you from them.
e) Unique application numbers.
When you install or uninstall a Service containing a unique application number or when such a
Service searches for automatic updates, that number and information about your installation, for
example, the type of operating system, may be sent to us.
B. Tracking and cookies
We may use mobile tracking technologies and/or website cookies to distinguish you from other
users of the App, App Site, or Service Sites. This helps us to provide you with a good experience
when you use the App or browse any of the Service Sites and also allows us to improve the App
and Our Service Sites
C. Uses made of the information
Information collected by us shall be processed and used for the purpose of determining whether
or not to provide a loan to you, the amount of such loan and the terms and conditions applicable
to such loan or provide any of our Services to you. We are unable to make this determination
unless we collect and process data in accordance with our terms and conditions.
Save in compliance with an order of the Court, Arbitral Panel, Tribunal, Regulatory Directive or
Order or any other legal or regulatory obligation, we do not disclose information about
identifiable individuals to other parties, but we may provide them with anonymous aggregate
information about our users (for example, we may inform them that 500 men aged under 30 have
applied for a loan on any given day).
D. Disclosure of your information
We may disclose some or all of the data we collect from you to credit reference bureaus.
We may disclose your personal information to any member of our group, which means our subsidiaries, affiliates, our holding company and its subsidiaries.
We may disclose your personal information to third parties:
• in the event that we sell or buy any business or assets, in which case we may disclose
your personal data to the prospective seller or buyer of such business or assets;
• Treasure Store Ltd or substantially all of its assets are acquired by a third party, in which
case personal data held by it about its customers will be one of the transferred assets;
• if we are under a duty to disclose or share your personal data in order to comply with any
legal or regulatory obligation or request; and/or
• in order to enforce our Terms and Conditions and other agreements or to investigate
potential breaches; outsource delinquent and defaulted accounts to third party debt
collectors; report defaulters to any credit bureau; or
• if we outsource data processing services from third parties such as Amazon and or any
other data processor that we may appoint from time to time; or
for the purpose of publishing statistics relating to the use of the App, in which case all information will be aggregated and made anonymous.
E. Where We store your personal data
The data that we collect from you may be transferred to, and stored at, a destination outside your
country of origin or residence (as applicable). It may also be processed by staff operating outside
your country of origin or residence (as applicable), who work for us or for one of our suppliers.
These staff members may be engaged in the fulfilment of your requests on the Service Sites.
Data stored outside Kenya may be subject to the laws of the country in which it is stored. By
submitting your personal data, you agree to the collection, transfer, storing or processing of your
personal data in the manner set out above. We will take all steps reasonably necessary to ensure
that your data is treated, stored and processed securely and in accordance with these Terms and
Conditions.
Where we have given you (or where you have chosen) a password that enables you to access
certain parts of Our Service Sites, you are responsible for keeping this password confidential. We
ask you not to share a password with anyone. Unfortunately, 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 transmitted to Our Service Sites; 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 unauthorised access
F. Data Security
We implement and maintain appropriate safeguards to protect personal data, taking into account
in particular the risks to you, presented by unauthorised or unlawful processing or accidental
loss, destruction of, or damage to their personal data.
Safeguarding will include the use of encryption and pseudonymisation where appropriate. It also
includes protecting the confidentiality (i.e. that only those who need to know and are authorised
to use personal data have access to it), integrity and availability of the personal data. We
regularly evaluate and test the effectiveness of those safeguards to ensure the security of our
processing of personal data.
G. Your rights
We will use your data for the purposes of determining whether or not to provide a service to you.
We may also use your data to compile statistics relating to our user base or loan portfolio and
may disclose such information to any third party for such purposes, provided that such
information will always be anonymous.
You are entitled to:
• access, upon written request from you or authorised person, any personal data we collect
from you;
• to object, through written notice, to our processing of all or part of your personal data
• correction by us of false or misleading data we may have regarding you;
• deletion by us, of false or misleading data about you;
• receive, upon written request from you or authorised person, the personal data we collect
from you in a structured, commonly used and machine-readable format
• transmit, upon written request from you or authorised person, the data to another data
controller or data processor without any hindrance.
We will request for your consent prior to using your personal information for marketing
purposes. You shall be entitled to prevent such usage by informing us, within 10 days of being
informed of the proposed use, that you do not wish to disclose such information. You can also
exercise the right at any time by contacting us at customercare@sot.co.ke.
As a Data Subject you have the right not to be subject to decisions based solely on automated
Processing, including Profiling, except where necessary for entering into, or performing, a
contract, with Branch; it is based on your explicit Consent and is subject to safeguards; or is
authorised by law and is also subject to safeguards
You have the rights set out in Section 26 of the Data Protection Act, 2019 as further set out in the
Data Processing Terms and Conditions.
H. Changes to Terms and Conditions
Any changes we may make to these Terms and Conditions in the future will be posted on this
page and, where appropriate, notified to you when you next start the App or log onto one of the
Service Sites. The new terms may be displayed on-screen and you may be required to read and
accept them to continue your use of the App or the Services. In any event, by continuing to use
the App or any Services after the posting of any changes, you confirm your continuing
acceptance of these Terms and Conditions together with such changes, and your consent to the
terms set out therein.
The data collected is voluntary and not mandatory or pursuant to any law in Kenya.
Questions, comments and requests regarding these Terms and Conditions are welcomed and
should be addressed to customercare@sot.co.ke
