Privacy Policy

Privacy Policy

Effective Date: September 17, 2025
Last Updated: September 17, 2025

1. Introduction

Intelli-Wealth Limited ("Company," "we," "us," or "our") operates the Intelli-Cash platform, a digital financial management solution for Village Savings and Loan Associations (VSLAs), chamas, agricultural cooperatives, and social groups across Africa. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our services.

We are committed to protecting your privacy and handling your personal data in accordance with the Kenya Data Protection Act, 2019, and other applicable data protection laws. By using our services, you consent to the practices described in this Privacy Policy.

2. Information We Collect

2.1 Personal Information

We collect personal information that you voluntarily provide to us, including:

Account Information:

  • Full name and contact details (phone number, email address)
  • National identification number or passport number
  • Physical address and location information
  • Date of birth and gender
  • Employment information and income details

Group Information:

  • Group name and registration details
  • Group leadership positions and roles
  • Meeting schedules and locations
  • Group constitution and bylaws

Financial Information:

  • Savings contributions and loan applications
  • Transaction history and payment records
  • Mobile money account details (M-Pesa, KCB BUNI numbers)
  • Credit history and repayment behavior
  • Social fund contributions and withdrawals

2.2 Automatically Collected Information

When you use our platform, we automatically collect:

Technical Information:

  • Device information (type, operating system, browser)
  • IP address and location data
  • Usage patterns and session duration
  • Log files and error reports

Communication Data:

  • SMS delivery reports and status
  • Email open rates and engagement
  • Customer support interactions
  • Platform notifications and alerts

2.3 Third-Party Information

We may receive information from third-party services:

  • Mobile money providers (transaction confirmations)
  • SMS service providers (delivery reports)
  • Credit reference bureaus (with your consent)
  • Government databases for verification purposes

3. How We Use Your Information

3.1 Primary Uses

We use your personal information to:

Service Provision:

  • Create and manage your account and group profiles
  • Process savings contributions and loan applications
  • Facilitate mobile money transactions
  • Send SMS notifications and alerts
  • Generate reports and analytics
  • Provide customer support services

Platform Operation:

  • Maintain platform security and prevent fraud
  • Troubleshoot technical issues and improve performance
  • Conduct data analysis for service enhancement
  • Ensure compliance with regulatory requirements

3.2 Secondary Uses

With your consent, we may use your information for:

  • Financial literacy training and education programs
  • Marketing communications about new features
  • Research and development of new services
  • Partnerships with other financial service providers

4. Legal Basis for Processing

Under the Kenya Data Protection Act and applicable laws, we process your personal data based on:

  • Contract Performance: To provide services you've requested
  • Legal Obligation: To comply with financial regulations and laws
  • Legitimate Interest: To improve services and prevent fraud
  • Consent: For marketing communications and optional services
  • Vital Interest: To protect your financial security and safety

5. Information Sharing and Disclosure

5.1 Within Your Group

We share relevant information with:

  • Group administrators and designated officers
  • Group members (as per group constitution and your consent)
  • Group auditors and oversight committees

5.2 Third-Party Service Providers

We share information with trusted partners who help us operate our platform:

Mobile Money Providers:

  • Transaction processing and verification
  • Account balance confirmations
  • Payment failure notifications

SMS Service Providers:

  • Message delivery and status reports
  • Bulk messaging for group communications

Cloud Service Providers:

  • Secure data storage and backup
  • Platform hosting and maintenance

5.3 Legal and Regulatory Disclosure

We may disclose your information when required by:

  • Kenyan financial regulators and authorities
  • Law enforcement agencies with valid legal requests
  • Court orders and legal proceedings
  • Anti-money laundering compliance requirements

5.4 Business Transfers

In case of merger, acquisition, or business transfer, your information may be transferred to the new entity, subject to the same privacy protections.

6. Data Security

6.1 Security Measures

We implement comprehensive security measures including:

Technical Safeguards:

  • End-to-end encryption for sensitive data
  • Secure Socket Layer (SSL) protection
  • Multi-factor authentication options
  • Regular security audits and penetration testing
  • Automated backup and disaster recovery systems

Administrative Safeguards:

  • Employee training on data protection
  • Access controls and authorization levels
  • Regular policy reviews and updates
  • Incident response procedures

Physical Safeguards:

  • Secure data centers with restricted access
  • Environmental controls and monitoring
  • Hardware security modules for encryption keys

6.2 Data Breach Response

In case of a data breach, we will:

  • Contain and assess the incident immediately
  • Notify affected users within 72 hours
  • Report to relevant authorities as required by law
  • Provide support and guidance to affected individuals
  • Implement additional security measures to prevent recurrence

7. Your Rights and Choices

Under the Kenya Data Protection Act, you have the following rights:

7.1 Access Rights

  • Right to Access: Request copies of your personal data
  • Right to Portability: Receive your data in a structured format
  • Right to Information: Understand how your data is processed

7.2 Control Rights

  • Right to Rectification: Correct inaccurate or incomplete data
  • Right to Erasure: Request deletion of your personal data
  • Right to Restrict Processing: Limit how we use your data
  • Right to Object: Opt-out of certain processing activities

7.3 Communication Preferences

  • Marketing Communications: Unsubscribe from promotional messages
  • SMS Notifications: Manage notification preferences
  • Email Preferences: Control frequency and types of emails

To exercise your rights, contact us using the information provided in Section 12.

8. Data Retention

8.1 Retention Periods

We retain your personal information for different periods based on:

Active Users: Data retained while your account is active Financial Records: 7 years as required by Kenyan financial regulations Transaction Data: 5 years for audit and compliance purposes Marketing Data: Until you withdraw consent or 2 years of inactivity Legal Hold: Extended retention when required by legal proceedings

8.2 Data Deletion

When retention periods expire, we:

  • Securely delete or anonymize personal data
  • Maintain statistical data without personal identifiers
  • Comply with any legal obligations for extended retention

9. Children's Privacy

Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from minors. If we discover we have collected information from a minor without proper consent, we will delete it immediately.

10. International Data Transfers

10.1 Cross-Border Processing

Your data may be processed in countries outside Kenya for:

  • Cloud hosting and backup services
  • Technical support and maintenance
  • Payment processing and fraud prevention

10.2 Transfer Safeguards

When transferring data internationally, we ensure:

  • Adequate protection levels in destination countries
  • Standard contractual clauses with service providers
  • Regular monitoring of transfer arrangements
  • Compliance with Kenyan data protection requirements

11. Cookies and Tracking Technologies

11.1 Cookie Usage

We use cookies and similar technologies to:

  • Remember your login preferences
  • Analyze platform usage and performance
  • Provide personalized experiences
  • Enhance security and prevent fraud

11.2 Cookie Management

You can control cookies through:

  • Browser settings and preferences
  • Third-party opt-out mechanisms
  • Our cookie preference center
  • Mobile app settings and permissions

12. Updates to This Privacy Policy

12.1 Policy Changes

We may update this Privacy Policy to:

  • Reflect changes in our services or practices
  • Comply with new legal requirements
  • Improve clarity and transparency
  • Address user feedback and concerns

12.2 Notification of Changes

We will notify you of material changes through:

  • Email notifications to registered users
  • Platform announcements and alerts
  • SMS notifications for significant changes
  • Updated posting date on this policy

13. Contact Information

13.1 Privacy Inquiries

For privacy-related questions, concerns, or requests, contact us:

Intelli-Wealth Limited
Data Protection Officer
Ramco Court Bellevue, South C
Nairobi City, 00100, Nairobi, Kenya

Email: hello@intellicash.africa
Privacy Email: privacy@intellicash.africa
Phone: +254 768 706 799
Business Email: intelliwealthafrica@gmail.com

13.2 Regulatory Authority

If you're unsatisfied with our response to your privacy concerns, you may contact:

Office of the Data Protection Commissioner
P.O. Box 743-00200
Nairobi, Kenya
Email: info@odpc.go.ke
Website: www.odpc.go.ke

14. Acknowledgment

By using the Intelli-Cash platform, you acknowledge that you have read, understood, and agree to the collection, use, and disclosure of your personal information as described in this Privacy Policy. This policy works together with our Terms and Conditions to govern your use of our services.

We are committed to maintaining your trust and protecting your privacy. If you have any questions or concerns about this Privacy Policy, please don't hesitate to contact us.


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