Jafari Credit

Jafari Credit Limited takes data privacy seriously. We recognise and value the trust that individuals place in us when providing us with personal data and we are committed to safeguarding the privacy and security of personal data we may collect from visitors to our websites and/or the customers to whom we provide our services.

This Privacy notice aims to help you understand our personal data collection, usage, and disclosure practices by explaining:

Who we are and what we do.
What personal data we collect about you.
How we obtain the personal data about you.
How we use your personal data.
Who we share your personal data with.
Which countries we transfer your personal data to.
How long we keep your personal data.
How we protect your personal data.
What rights you have in relation to your personal data.
How we use cookies and similar technologies.
How you can contact us.
How we will update this Privacy notice.

By providing your personal data to us (whether via one of our websites, by email, in person or over the phone), you agree to the processing set out in this Privacy notice. Further notices highlighting certain uses we wish to make of your personal data together with the ability to opt in or out of selected uses may also be provided to you when we collect personal data from you.

Please note: This Privacy notice does not apply to, and Jafari Credit Limited is not responsible for, any third-party websites which may be accessible through links from this website. If you follow a link to any of these third-party websites, they will have their own privacy policies and you will need to check these policies before you submit any personal data to such third-party websites.

This Privacy notice aims to help you understand our personal data collection, usage, and disclosure practices by explaining:

1. Who we are and what we do

Jafari Credit Limited is a micro lender whose goal is to be the preferred credit provider for civil servants. We serve our customers with integrity and transparency while ensuring timely access to credit.

Please see "Who is the data controller of your personal data" below for more information on the entities that control and process personal data within Jafari Credit Limited.

2. What personal data we collect about you

We may collect and process different types of personal data while operating our business and providing our services. These include:

Basic personal details such as your name and job title.
Personal details of your next of kin and referees/colleagues
Contact data such as your telephone number and postal or email address.
Financial data such as payment related information or bank account details.
Demographic data such as your address, preferences, or interests.
Website usage and other technical data such as details of your visits to our websites or information collected through cookies and other tracking technologies.
Personal data provided to us by or on behalf of our customers or generated by us in the course of providing our services, which may, where relevant, include special categories of personal data.
Recruitment related data such as your curriculum vitae, your education and employment history, details of professional memberships and other information relevant to potential recruitment to Jafari Credit Limited.
Data that you may provide to us in course of registering for and attending events or meetings.
Any other personal data relating to you that you may provide.

3. How we obtain the personal data about you

We may collect or receive your personal data in several ways:

Where you provide it to us directly, for example by corresponding with us by email, or via other direct interactions with us such as completing a form manually or on our website or registering for and using one of our online tools.
Where we monitor use of, or interactions with, our websites, any marketing we may send to you, or other email communications sent from or received by Jafari Credit Limited.
Third party sources, for example, where we collect information about you to assist with "know your client" checks as part of our acceptance procedures or where we receive information about you from recruitment agencies for recruitment purposes.
Publicly available sources - we may, for example, use such sources to help us keep the contact details we already hold for you accurate and up to date or for professional networking purposes, e.g., LinkedIn.

4. How we use your personal data

We will only use your personal data where we are permitted to do so by applicable law. Under the Kenyan Data Protection Act, the use of personal data must be justified under one of several legal grounds. The principal legal grounds that justify our use of your personal data are:

Contract performance: where your information is necessary to enter or perform our contract with you.
Legal obligation: where we need to use your information to comply with our legal obligations.
Legitimate interests: where we use your information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights.
Legal claims: where your information is necessary for us to defend, prosecute or make a claim against you, us or a third party.
Consent: where you have consented to our use of your information (you will have been presented with a consent form or facility in relation to any such use and may withdraw your consent through an unsubscribe or similar facility).

We may use your personal data in the following ways. In each case, we note the grounds that we rely on to use your personal data.

To provide our payroll lending services to you and to conduct our business - to administer and perform our services, including to carry out our obligations arising from any agreements entered between you and us (please note that our Standard Terms of Engagement apply where we provide payroll lending services).
Legal grounds: contract performance, legitimate interests (to enable us to perform our obligations and provide our services to you), consent.
To facilitate use of our websites and to ensure content is relevant - to respond to requests for information or enquiries from visitors to our websites and to ensure that content from our websites is presented in the most effective manner for you and for your device.
Legal grounds: legitimate interests (to allow us to provide you with the content and services on the websites), consent, contract performance.
For marketing and business development purposes - to provide you with details of new services, where you have chosen to receive these. We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you or you may opt out by contacting us as set out in section 11 below.
Legal grounds: legitimate interests, consent.
For research and development purposes - analysis to better understand your and our customer services and marketing requirements and to better understand our business and develop our services and offerings.
Legal grounds: legitimate interests (to allow us to improve our services).
For recruitment purposes - to enable us to process applications for employment submitted via the Careers section of our website and to assess your suitability for any position for which you may apply at Jafari Credit Limited.
Legal grounds: legitimate interests (to ensure that we can make the most appropriate recruitment decisions for Jafari Credit Limited), contract performance (for us to take steps at your request to enter into a contract with you).
To fulfil our legal, regulatory, or risk management obligations - to comply with our legal obligations (performing client due diligence/"know your client", or reputational risk screening, identifying conflicts of interests); for the prevention of fraud and/or other relevant background checks as may be required by applicable law and regulation and best practice at any given time (if false or inaccurate information is provided and fraud is identified or suspected, details may be passed to fraud prevention agencies and may be recorded by us or by them); to enforce our legal rights, to comply with our legal or regulatory reporting obligations and/or to protect the rights of third parties.
Legal grounds: legal obligations, legal claims, legitimate interests (to cooperate with law enforcement and regulatory authorities, to ensure that you fall within our acceptable risk profile and to assist with the prevention of crime and fraud). Where we process special categories of personal data we may also rely on substantial public interest (prevention or detection of crime) or legal claims.
To ensure that we are paid - to recover any payments due to us and where necessary to enforce such recovery through the engagement of debt collection agencies or taking other legal action (including the commencement and carrying out of legal and court proceedings).
Legal grounds: contract performance, legal claims, legitimate interests (to ensure that we are paid for our services).
To inform you of changes - to notify you about changes to our services or our Standard Terms of Engagement or this Privacy notice.
Legal grounds: legitimate interests (to ensure we can notify you about changes to our service, Standard Terms of Engagement etc).
To reorganise or make changes to our business - In the event that we are undergo a re-organisation (for example if we merge, combine or divest a part of our business), we may need to transfer some or all of your personal data to the relevant third party (or its advisors) as part of any due diligence process or transfer to that re-organised entity or third party your personal data for the same purposes as set out in this Privacy notice or for the purpose of analysing any proposed re-organisation.
Legal grounds: legitimate interests (to allow us to change our business).

5. Who we share your personal data with

We may share your personal data with a variety of the following categories of third parties:

Our professional advisors (e.g., legal, financial, business, risk management or other advisors), bankers and auditors.
Our insurers and insurance brokers.
Other third-party external advisors or experts engaged in the course of the services we provide to our clients and with their prior consent, such as technology service providers.

We may also process your personal data to comply with our regulatory requirements or in the course of dialogue with our regulators; as applicable, which may include disclosing your personal data to government, regulatory or law enforcement agencies in connection with enquiries, proceedings, or investigations by such parties anywhere in the world or where compelled to do so. Where permitted, or unless to do so would prejudice the prevention or detection of a crime, we will direct any such request to you or notify you before responding.

6. Which countries we transfer your personal data to

Regardless of the location of our processing, we will impose the same data protection safeguards that we deploy within our jurisdiction and implement appropriate measures to ensure that your personal data is protected in accordance with applicable data protection laws.

Jafari Credit Limited has a data sharing agreement in place signed by all its related entities with standard contractual clauses. Similarly, where a third-party service provider processes the personal data of Kenyan residents on our behalf, we will ensure that appropriate measures are in place to ensure an adequate level of protection for your personal data, usually by including standard contractual clauses in our agreements with such third-party service providers (alongside other supplementary technical or contractual measures where necessary).

Please contact us as directed below if you would like to see a copy of the specific safeguards applied to the export of your personal data.

7. How long we keep your personal data

We will retain your personal data for as long as is necessary to fulfil the purpose for which this data was collected and any other permitted linked purpose.

If your personal data is used for two purposes, we will retain it until the purpose with the latest period expires; but we will stop using it for the purpose with a shorter period once that period expires. Our retention periods are also based on our business needs and good practice.

8. How we protect your personal data

We recognise that information security is an integral element of data privacy. While no data transmission (including over the Internet or any website) can be guaranteed to be secure from intrusion, we implement a range of commercially reasonable physical, technical, and procedural measures to help protect personal data from unauthorised access, use, disclosure, alteration, or destruction in accordance with data protection law requirements.

Information that you provide to us is stored on our or our service providers' secure servers and accessed and used subject to our security policies and standards, or those agreed with our service providers.

Everyone at Jafari Credit Limited and any third-party service providers we may engage that process personal data on our behalf (for the purposes listed above) are also contractually obligated to respect the confidentiality of personal data.

Alongside our role, please also note that where we have given you (or where you have chosen) a password which enables you to access certain parts of our online services, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of. We ask you not to share a password with anyone.

9. What rights you have in relation to your personal data

If you have any questions about our use of your personal data, you should first contact us via the details provided in section 12 below.

Under certain circumstances and in accordance with Kenya Data Protection Act, 2019 or other applicable data protection laws, you may have the right to require us to:

provide you with further details on the use we make of your information.
provide you with a copy of information that we hold about you.
update any inaccuracies in the personal data we hold.
delete any personal data that we no longer have a lawful ground to use.
where processing is based on consent, to withdraw your consent so that we stop that processing.
object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights.
restrict how we use your information whilst a complaint is being investigated.

You may also ask us not to process your personal data for marketing purposes. We will inform you if we intend to disclose your information to any third-party service provider for this purpose. As indicated in section 4 above, you can exercise your right to prevent such processing at any time by using an unsubscribe facility or contacting us at dpo@centum.co.ke

We are also required to take reasonable steps to ensure that your personal data remains accurate. To assist us with this, please let us know of any changes to the personal data that you have provided to us by contacting us at dpo@centum.co.ke or by using any relevant facilities that we provide.

While it is our policy to respect the rights of individuals, please be aware that your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g., the prevention or detection of crime), our interests (e.g., the maintenance of legal privilege) and some of these rights may be limited (for example the right to withdraw consent) where we are required or permitted by law to continue processing your personal data to defend our legal rights or meet our legal and regulatory obligations.

If you contact us to exercise any of these rights, we will check your entitlement and respond in most cases within a month.

10. How we use cookies and similar technologies

When you visit our websites, we may send a cookie to your computer. This is a small data file stored by your computer to help improve functionality or tailor information to provide visitors with more relevant pages. For details of the cookies employed by us, please see our Cookie Policy, which forms part of this Privacy notice. We may also analyse website traffic to identify what visitors find most interesting so we can tailor our websites accordingly.

11. How you can contact us

If you have any questions about this Privacy notice or how we process your personal data, please contact us by sending an email to:

dpo@centum.co.ke or by writing to:

Data Protection Officer
Centum Investment Company Limited
8th Floor, South Tower, Two Rivers, Nairobi Kenya.
10518-0100 Nairobi

12. How we may update this Privacy notice

We may change the content of our websites and how we use cookies without notice and consequently our Privacy notice and Cookie Policy may change from time to time in the future. We therefore encourage you to review them when you visit the website to stay informed of how we are using personal data.

Privacy notice