1. Who we are
FahariPay Limited ("FahariPay") is the data controller for personal data processed through our website and services. We are registered with the Office of the Data Protection Commissioner (ODPC) under registration number [●]. Contact our data protection officer at privacy@usefaharipay.com.
2. Data we collect
| Category | Examples |
|---|---|
| Identity & contact | Name, ID or passport number, date of birth, photo, email, phone, address, KRA PIN |
| Business information | Directors, beneficial owners, registration documents, ownership structure |
| Financial & transaction | Account details, balances, transactions, counterparties, source of funds |
| Technical | IP address, device and browser data, log-ins, cookies |
| Communications | Messages, calls and support requests |
3. How we use your data
We use personal data to:
- verify identities and businesses (KYC/KYB) and meet anti-money-laundering, counter-terrorist-financing and sanctions obligations;
- open and operate accounts and process payments;
- detect and prevent fraud and financial crime;
- provide support and communicate with you;
- improve and secure our services; and
- meet legal, regulatory, tax and reporting obligations.
4. Legal bases
We process personal data to perform our contract with you, to comply with legal obligations, for our legitimate interests (such as security and fraud prevention), and with consent where required, for example for certain marketing.
5. Sharing your data
We share data only where necessary, with:
- our banking, payment and liquidity Partners, to provide the services;
- identity-verification, screening and fraud-prevention providers;
- cloud hosting and IT service providers;
- other PrimePay group companies, where needed to provide services;
- regulators, law-enforcement agencies and the Financial Reporting Centre, where the law requires.
We never sell personal data.
6. International transfers
Some Partners and providers may process data outside Kenya. Where we transfer data abroad, we do so in line with the Data Protection Act, 2019, with appropriate safeguards in place.
7. How long we keep data
We keep personal data for as long as needed to provide our services and meet legal obligations. Anti-money-laundering records are generally kept for at least seven years after a transaction or the end of the relationship. [Confirm retention periods with counsel.]
8. Your rights
Under the Data Protection Act, 2019 you have the right to be informed, to access your data, to correct it, to object to processing, and in some cases to have it deleted or transferred. Some rights are limited where we must keep data by law. To exercise your rights, email privacy@usefaharipay.com. You may also complain to the Office of the Data Protection Commissioner.
9. Security
We protect data with encryption in transit and at rest, access controls, monitoring and regular reviews. No system is perfectly secure, but we work hard to keep your data safe and will notify you and the ODPC of qualifying breaches as required by law.
10. Cookies
We use essential cookies to run our website and, with your consent, analytics cookies to understand how it is used. You can control cookies in your browser settings.
11. Changes
We may update this policy and will post the new version here with a new "last updated" date.