Privacy Policy

1.0 Introduction

Your privacy is important to us. This privacy statement explains the personal data SILQU collects, how SILQU processes it, and for what purposes. This statement should be read together with the Terms and Conditions of Use for other SILQU services. Where there is a conflict, this statement will prevail.

2.0 Definitions

References to

2.1 “You” mean

i. Customer – The person who subscribes to, uses or purchases any of our products and services or accesses our websites and includes any person who accesses any of the products and services you have subscribed to.

ii. Any agent and/or dealer who has signed an agreement with us and is recognized as an agent in accordance with any applicable laws or Regulations.

iii. Any visitor that is a person (including contractors/subcontractors or any third parties) who gains access to any SILQU premises.

2.2 “Silqu”, “we” or “us”, “our” and “ours” means SILQU

The word “includes” means that what follows is not necessarily exhaustive and therefore the examples given are not the only things/situations included in the meaning or explanation of that text.

3.0 Statement Details

3.1 Collection of Information

3.1.1 We collect your personal information with your knowledge and consent when you do any of the following (please note that this list is not exhaustive):

a) Visit, access or use Silqu or third-party websites;

b) Access our dashboard as a tenant, landlord and/or property manager of a property registered in our system.

c) Raise an enquiry through our system.

d) Navigate SILQU demo website.

e) When you dial our USSD

f) When you access our telegram bot.

g) We also collect information when you visit any of our premises.

h) Respond to or participate in any survey, marketing promotion, prize competition or special offer.

3.1.2 We do not onboard minors (any person under 18 years of age) except where you additionally register on their behalf as their parent and/ or legal guardian. If you allow a child to use our services, you should be aware that their personal information could be collected as described in this statement.

3.2 What Information is collected?

The information we collect and store about you includes but is not limited to the following:

3.2.1 Your identity, including your name, photograph, address, phone number, identity document type and number, date of birth, email address, age, family details and gender.

3.2.2 Your credit or debit-card information, information about your bank account numbers and SWIFT codes or other banking information.

3.2.3 Your transaction information when you use our SILQU service.

3.2.4 Your contact with us, such as when you: call us or interact with us through social media, our chatbot Maya, email (we may record your conversations, social media or other interactions with us), register your biometric information such as your fingerprints etc, visit any of our premises.

3.2.5 We maintain a register of visitors in which we collect and keep your personal data such as names, company/institution details, telephone number and National ID number. This information is collected for health, safety and security purposes.

3.3 Use of Information

We may use and analyze your information for the following purposes:

3.3.1 Responding to any of your queries or concerns;

3.3.2 Verifying your identity information through publicly available and/or restricted government databases in order to comply with applicable regulatory requirements;

3.3.3 Billing you for using our services;

3.3.4 Carrying out credit checks and credit scoring;

3.3.5 Keeping you informed generally about new products and services and contacting you with offers or promotions based on how you use our or third-party products and services unless you opt out of receiving such marketing messages (you may contact Silqu at any time to opt out of receiving marketing messages);

3.3.6 to comply with any legal, governmental or regulatory requirement or for use by our lawyers in connection with any legal proceedings;

3.3.7 In business practices including to quality control, training and ensuring effective systems operations;

3.3.8 To understand how you use our products and services for purposes of developing or improving products and services;

3.3.9 Preventing and detecting fraud or other crimes and for debt recovery;

3.3.10 For research, statistical, survey and other scientific or business purposes;

3.3.11 Provide aggregated data (which do not contain any information which may identify you as an individual) to third parties for research and scientific purpose;

3.3.12 Administer any of our online platforms/websites.

3.4 Categories of Data

Categories of Personal Data as defined in the Data Protection Act of Kenya may be processed depending on the particular types of products and services you have subscribed to.

3.5 Lawful Basis for processing your information

We will process your personal information based on any of the lawful basis provided for under the Data Protection Law:

3.5.1 The performance of a Product/Service Agreement with you;

3.5.2 Silqu’s legitimate business interests;

3.5.3 Compliance with a mandatory legal obligation;

3.5.4 Consent you provide;

3.5.5 Public interest;

3.5.6 Your vital interest

3.6 Retention of Information

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, the need to comply with our internal policy and the applicable legal, regulatory, tax, accounting or other requirements.

Anonymised information that can no longer be associated with you may be held indefinitely.

4.0 Disclosure of Information

4.1 Any disclosure of your information shall be in accordance with applicable law and regulations. Silqu shall assess and review each application for information and may decline to grant such information to the requesting party.

4.2 We may disclose your information to:

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.

b) our subsidiaries, associates, partners, software developers or agents who are involved in delivering Silqu products and services you order or use;

c) Fraud prevention and Anti money laundering agencies, credit reference agencies;

d) publicly available and/or restricted government databases to verify your identity information in order to comply with regulatory requirements;

e) debt-collection agencies or other debt-recovery organizations;

f) Survey agencies that conduct surveys on behalf of Silqu;

g) Emergency service providers when you make an emergency call (or where such disclosure to emergency service providers is necessary for your rescue, health and safety) including your approximate location;

h) Any other person that we deem legitimately necessary to share the data with.

4.3 Some of your information may be passed on to any person who pays rent for any of the tenants in our system.

4.4 Your information may be available to any third party involved in the operation of the mobile money service including Lipa Na M-PESA Merchants, mobile money interoperability partners and vendors of the M-PESA money transfer technology platform.

4.5 We shall not release any information to any individual or entity that is acting beyond its legal mandate.

4.6 We will get your express consent before we share your personal data with any third party for direct marketing purposes.

4.7 Direct Marketing

4.7.1 You may be required to opt in or give any other form of explicit consent before receiving marketing messages from us.

4.7.2 You can ask us to stop sending you marketing messages at any time by dialing *456*9*5#

4.7.3 Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product, service already taken up, warranty registration, product or service experience or other transactions].

5.0 Use of Cookies

5.1 We may store some information (using "cookies") on your computer when you visit our websites. This enables us to recognise you during subsequent visits. The type of information gathered is non-personal (such as: the Internet Protocol (IP) address of your computer, the date and time of your visit, which pages you browsed and whether the pages have been delivered successfully.

5.2 We may also use this data in aggregate form to develop customized services - tailored to your individual interests and needs. Should you choose to do so, it is possible (depending on the browser you are using), to be prompted before accepting any cookies, or to prevent your browser from accepting any cookies at all. This will however cause certain features of the web site not to be accessible.

6.0 Access to and Updating your Information

To update your information, you need to sign in to your portal or visit any of Silqu branches.

7.0 Safeguarding and Protection of Information

Silqu 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.

8.0 International Data Transfers

From time to time we may need to transfer your personal information outside the Republic of Kenya to provide a particular product or service. Where we send your information outside Kenya, we will make sure that your information is properly protected in accordance with the applicable Data Protection Laws.

9.0 Your Rights

Subject to legal and contractual exceptions, you have rights under data protection laws in relation to your personal data. These are listed below: -

a) Right to be informed that we are collecting personal data about you;

b) Right to access personal data that we hold about you and request for information about how we process it;

c) Right to request that we correct your personal data where it is inaccurate or incomplete;

d) Right to request that we erase your personal data noting that we may continue to retain your information if obligated by the law or entitled to do so;

e) Right to object and withdraw your consent to processing of your personal data. We may continue to process if we have a legitimate or legal reason to do so;

f) Right to request restricted processing of your personal data noting that we may be entitled or legally obligated to continue processing your data and refuse your request;

g) Right to request transfer of your personal data in [an electronic format].

10.0 How to Contact Us

If you would like to contact us on any topics in this privacy policy, you can email us on info@siqu.co.ke or submit a request via our digital platforms.

The Trio Complex
East Wing
Nairobi
Tel: +254 717 888 828/ 755 000 040
www.silqu.com

11.0 Right to Lodge Complaint

You have the right to lodge a complaint with the relevant supervisory authority that is tasked with personal data protection within the Republic of Kenya

12.0 Non-Compliance with this Statement

Silqu shall have the right to terminate any agreement with you for failure to comply with the provisions of this statement and reject any application for information contrary to this statement.

14.0 Amendments to this Statement

Silqu reserves the right to amend or modify this statement at any time. If Silqu amends this statement, You can access the most current version of the privacy statement by visiting our website so that you will always know how your personal information is being used or shared

Any amendment or modification to this statement will take effect from the date of notification on the Silqu website.


Statement Effective Date
1st June 2020

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