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1. Introduction

   • When this policy mentions "we," "us," "our," "puphik Credit Ltd," "data controller," "controller," or "Company," it refers to:

     • Puphik Credit Ltd – Kenyan Company, PVTDLUK7VL, with the registered office at Bomet, KOSAL Plaza, 1st floor, Mobile number +254 (7)14 262 211 689R+CWC. The Company is responsible for the lending, which contains personal data about the Customers' clients, under this Privacy Policy.

   • When this policy mentions "visitor," "user," "you," "your," "data subject," "Customer," or "Client," it refers to the data subject in accordance with the Data Protection ACT 2019 definitions.

   • When this policy mentions "PUPHIK credit Limited" or "Services," it refers to the services of the Company. PUPHIK Credit Limited is an institution company that gives Emergency loans.

   • When this policy mentions "puphik website," "Site," or "Website," it refers to the https://puphikcredit.com site, including all its subdomains.

2. Acceptance of Privacy Policy and Terms of Services
   • Please read this Privacy Policy and our terms of service carefully and ensure that you understand it. Your acceptance of Puphik Credit Ltd Privacy Policy and Terms of Services is upon you to read and accept this Privacy Policy and Terms of Services when registering or signing up for any application form belonging to Puphik Credit Limited. If you do not accept and agree with our Privacy Policy and Terms of Services, you must not proceed by signing up for the application Forms.
3. Commitment to Protecting Privacy
   • We are committed to protecting your privacy. Authorized employees within Puphik Credit Limited on a need-to-know basis only use any information collected from you. We constantly review our systems and data to ensure the best possible service to our customers.
4. Definitions
   • In this privacy policy, we use the following terms: a) Personal Information/Personal data: Any information relating to an identified or identifiable natural person ("data subject"). b) Data subject: An identified or identifiable natural person who can be identified, directly or indirectly, based on particular information representing personal data. c) Processing: Any operation or set of operations performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation, or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment, or combination, restriction, erasure, or destruction. d) Restriction of processing: The marking of stored personal data with the aim of limiting their processing in the future. e) Profiling: Any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person. f) Pseudonymization: The processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person. g) Controller or controller responsible for the processing: The natural or legal person, public authority, agency, or other body that determines the purposes and means of the processing of personal data. h) Processor: Any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means. i) Recipient: A natural or legal person, public authority, agency, or another body to which the personal data are disclosed, whether a third party or not. j) Third party: A natural or legal person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor, are authorized to process personal data. k) Consent: An indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
5. How we collect Personal Data
   • When you visit our offices, or ask for information about our products, apply for specific products or services, respond or participate in a survey, contact us with a query or complaint, we may ask for certain Personal Data that will assist us in providing you with a service that meets your needs and circumstances. We may also collect Personal Data from you from time to time via surveys or contests. Participation in these surveys or contests is completely voluntary, and you may choose whether or not to participate and disclose this information.
   • Information requested may include contact information (such as name and address) and demographic information (such as zip code, age level). Contact information will be used to notify you about our processes. Survey information will be used for purposes of monitoring or improving the use and satisfaction of services.
   • We collect information from you for using our Services, including but not limited to:
     • Country
     • First name
     • Middle/Last name
     • Business name
     • National ID copy
     • Gender
     • Title
     • Mobile
     • Email
     • Date of birth
     • Address
     • City
     • Province/State
     • Zipcode
     • Landline phone
     • Working status
     • Credit score
     • Borrower photo
     • Description
     • Borrower files
     • Loan details such as released date, maturity date, loan product, collection dates, repayment cycle, collateral, other income, expenses, files, photographs
   • Puphik Credit Limited will be the collector of these Personal Data mentioned above that is provided, collected and/or processed pursuant to this Privacy Policy and Data Processing Agreement.
   • If a data subject contacts the controller by email, WhatsApp, or via a contact form, the personal data transmitted by the data subject are automatically stored/saved. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.
6. How we process Personal Data
   • We will use your Personal Data only in accordance with our Privacy Policy. If you do not wish us to continue using your Personal Data in this manner, you can request that your details be deleted or redacted by contacting us via email info@puphikcredit.com.
   • We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity, and our legitimate interests such as personalizing, improving or operating our services, better understanding your needs, fulfilling requests, complying with legal obligations, and protecting against fraudulent, harmful, unauthorized, or illegal activity.
   • We process Personal Data for purposes such as delivering services, providing reports, keeping you updated on service announcements, providing support, and meeting contract or legal obligations.
   • We may also use your Personal Information to send you automated SMS or email messages or marketing materials regarding our services. You may opt out of receiving such marketing SMS or email messages by unsubscribing from our database via info@puphikcredit.com.
7. Sharing your Personal Data / Use and disclosure of Personal Information
   • We will use the personal information that we gather from you to provide our Services and carry out administrative tasks relating to our business.
   • We do not sell or rent your Personal Data to third parties unless you have granted us permission to do so, including clients of Puphik Credit Limited to whom your loan relates and referees, etc. However, we will share Personal Data within Puphik Credit Limited and with third-party service providers for data processing or storage.
   • We also share Personal Data with business partners, service vendors, and authorized third-party agents to provide requested services or transactions.
   • We work with specific service providers who may be processing your data while providing their services to us. We have data processing agreements with these companies to maintain strict privacy and data security standards.
8. Security and Retention of your Personal Data
   • We take precautions to protect your information, and only authorized employees who need the information to perform specific jobs are granted access to personally identifiable information.
   • Puphik Credit Ltd is committed to protecting the Personal Data you share with us. We retain your Personal Data depending on the type of data and the purpose for which we process the data.
9. Rights of the Data Subject
   • Each data subject has various rights, including the right to information, access, rectification, erasure, data portability, object, and withdraw consent. These rights allow data subjects to have control over their personal data.
10. Complaints and Contact
    • If you have any concerns or complaints about how we handle your personal information, or if you have any questions about this policy, please contact us via info@puphikcredit.com.
11. Amendments to This Statement
    • Our Privacy Policy may change from time to time. We will communicate any privacy policy changes on our website and, if the changes are significant, we will provide a more prominent notice via SMS or email notification.

Last updated: 28th August 2023