In this Data Privacy Notice (“Privacy Notice”) we explain how we collect and use
your personal information that we obtain when you use our services, visit or use our
websites or mobile applications, how we share your information and the steps we take to
protect your information.
1.Who we are and the application of this Privacy Notice
This Privacy Notice applies to Leizam Ventures LTD Developers and Owners of Bill Eazy APP (“Bills Eazy”, “we”,
“our” or “us”).
We are committed to the privacy and security of your Personal Data (as defined in section 2
below). This Privacy Notice describes how we collect and use Personal Data, in accordance
with applicable law and our standards of ethical conduct.
Bills Eazy, will be the “data controller” in relation to any Personal Data provided to us
directly, in person, via email, phone, and post or via the following website or its registered sub domains: www.billseazy.com(the
“Website”) or the mobile app: Bills Eazy (the "App"). This means that Bills Eazy is
responsible for deciding how it will hold and use Personal Data about you.
By
using or navigating the Website or App or any product or service offered by us
(collectively, the "Services"), you acknowledge that you have read, understand,
and agree to be bound by this Privacy Notice. You should not provide us with any of your
information if you do not agree with the terms of this Privacy Notice.
We
encourage you to review and check the Website regularly for any updates to this Privacy
Notice. We will publish the updated version on the Website and by continuing to deal with
us, you accept this Privacy Notice as it applies from time to time.
2.Data
Protection Principles
“Personal
Data” means any information that enables us to identify you or the beneficiary of your
transaction with us, directly or indirectly, such as name, email, address, telephone number,
any form of identification number or one or more factors specific to you or your
beneficiary’s physical, physiological, mental, economic, cultural or social
identity.
We
are committed to complying with applicable data protection laws and will ensure that
Personal Data is:
-
Used
lawfully, fairly and in a transparent way;
-
Collected
only for valid purposes that we have clearly explained to you and not used in any
way that is incompatible with those purposes;
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Relevant
to the purposes we have told you about and limited only to those
purposes;
-
Accurate
and kept up to date;
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Kept
only as long as necessary for the purposes we have told you about; and
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Kept
securely.
3.What Personal Data do we collect and how do we collect it?
Personal
Data You Give Us. We
may collect Personal Data when you give it to us, including when you indicate that you would
like to receive any of our Services, when you register with us, when you complete forms online,
when you speak with us over the telephone, when you speak with us in person, when you write to
us, and when you visit the Website and, in certain circumstances as set out in this Privacy
Notice, when you have provided your information to a related company operating under the Leizam Ventures
LTD or billseazy.com or Bills Eazy APP. We will also collect details of transactions you carry out through the Website
and/or App and of the fulfilment of such transactions.
The types of Personal Data we collect will depend on the products or services you have requested
from us. Any Personal Data collected is necessary for us to perform a contract and without
such data we may not provide the desired Services.
We may collect and process the following Personal Data:
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Personal details, such as data which may identify you and/or the beneficiary of your
transaction with us. This may include name, title, residential and/or business
address, email, telephone and/or fax numbers and other contact data, date of birth,
gender, images, signature, passport/visa details or any Personal identification document number applicable under the current law and or jurisdiction;
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Financial details, such as data relating to you and your beneficiary’s payment data and
bank account obtained for the purposes of money transfers; and/or
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Additional details requested by law enforcement or requested pursuant to our compliance
procedures in connection with efforts to prevent money laundering, terrorist
financing and criminal activity, such as relationship to the beneficiary of the
transaction, the purpose of the transaction and proof of funds.
Cookies and similar technologies.
When you use our Website and or mobile apps we collect information via cookies and similar technologies,
including the IP address of visitors, behavioral information, browser type and version, time
zone setting, screen resolution settings, browser plug-in types and versions, operating system
and platform. We may use this data for the following purposes:
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To measure the use of our Website and Services, including number of visits, average
time spent on a Website, pages viewed, page interaction data (such as scrolling,
clicks, and mouse-overs), etc., and to improve the content we offer;
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To administer the Website and for internal operations, including troubleshooting, data
analysis, testing, research, statistical and survey purposes; and
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As part of our efforts to keep the Website safe and secure;
Due to their core role of enhancing or enabling usability or site processes, disabling cookies
may prevent you from using certain parts of our Website. It will also mean that some
features on our Website will not function if you do not allow cookies.
4.How we use your Personal Data?
We use Personal Data and other data you provide to us only for the following purposes permitted
by applicable laws:
-
When necessary for the performance of a contract with you:
We may use your data on the basis of our need to perform our obligations under a contract
with you, to complete your transactions or other requests made by you, to respond to and
process your queries or requests, or to contact you as necessary in connection with our
performance of a contract with you. For example, if you enter into a contract for our
bill payment services, your data will necessarily be shared with the payment service
provider that will pay out funds to your designated beneficiary, it may be shared with
our agents and/or contractors to facilitate the refund of a qualifying payment order to
you and it may be used if we find it necessary to contact you in connection with our contract.
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When necessary to comply with a legal or regulatory obligation:
We may use your data to comply with legal requirements and/or regulations specific to our
business. For example, when you contract with us for payment services, we are required
to perform a certain level of due diligence prescribed by law and/or commensurate with
any assessed risk which may result in the reporting of your data to legal and/or
regulatory authorities and/or a request from us for additional information from you to
assist in our risk assessment and/or to satisfy our compliance obligations.
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When you have provided your consent for the processing:
If you have consented and you have not withdrawn your consent, we may contact you with
marketing communications in relation to our Service or the services and products of Leizam Ventures LTD
Companies (see Section 10 Direct Marketing, below).
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When necessary in the pursuit of a legitimate interest of Bills Eazy
:If you provide information to us online or transact with us online, we may use your data
to improve the content of our Website and Services in order to enhance your experience.
We may use data, such as IP addresses and anonymous demographic data, to tailor your
experiences with our Services by showing content in which we think you will be
interested and displaying content according to your preferences. We may use aggregate
data for a variety of purposes, including analysing user behaviour and characteristics
in order to measure interest in (and use of) the various portions and areas of our
Services. We also may use the data collected to evaluate and improve our Services and
analyse traffic to our Services.
If in the future we use your Personal Data in the pursuit of our legitimate interest,
we will strive to align our interests with yours such that under no circumstances
will your data be used except as consented to by you or as otherwise permitted by
applicable laws.
In some circumstances we may anonymise your Personal Data so that it can no longer be
associated with you, in which case we may use such data without further notice to
you.
5.Is data collected shared with third parties?
Leizam Ventures LTD
We may share your personal data with other Leizam Ventures LTD Companies in order to enable or facilitate us to
provide you with any of the Services you have requested, where you have asked us to do so,
to provide the Services to you outside of normal business hours and, where you have
consented and not withdrawn your consent, for the Leizam Ventures LTD Companies’ direct marketing
purposes.
Third
party service providers
We may share your Personal Data with the following third party service providers to manage,
enable or facilitate certain aspects of the Services (including the maintenance of our
servers and processing or fulfilling orders for transactions):
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Compliance verification service providers
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Financial
services providers, such as banks/safaricom/Kenya Power LTD and Mobile Telco Companies whose services we provide
We have safeguards in place with such third party service providers requiring them to protect
your personal data. To obtain a copy of the relevant safeguard measures please contact
Leizam Ventures LTD Group Data Protection Officer as indicated in Section 1 above.
Corporate process
We may transfer your Personal Data to a third party as a result of a sale, acquisition, merger,
or reorganization involving Bills Eazy, Leizam Ventures LTD, or any of their respective
assets. In these circumstances, we will take reasonably appropriate steps to ensure that
your information is properly protected.
Legal and regulatory
We may also disclose your Personal Data in special cases if required to do so by law
enforcement agencies, law, court order, or other governmental authority, or when we believe
in good faith that disclosing this data is otherwise necessary or advisable, such as to
identify, contact, or bring legal action against someone who may be causing injury to
– or interfering with – the rights or property of Leizam Ventures LTD, the Services,
another user, or anyone else that could be harmed by such activities (for example, identify
theft or fraud).
6.How long is Personal Data retained?
Personal Data is used for different purposes and is subject to different standards and regulations.
In general, Personal Data is retained for as long as necessary to provide you with the
Services you request, to comply with applicable legal, accounting or reporting requirements,
and to ensure that you have a reasonable opportunity to access the Personal
Data.
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 unauthorised
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, and the applicable legal
requirements. For example:
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Legal and Regulatory Requirements.
Leizam Ventures LTD shall retain Personal Data and transactional data for those periods required to
comply with all retention and reporting obligations under applicable laws, including
without limitation commercial, tax and anti-money laundering laws and regulations.
Generally, this retention period will be a minimum of five years from the date of your
transaction or the date our business relationship with you is terminated.
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Customer Service (administration of customer relationship, complaint handling, etc.).
Bills Eazy may process and retain your Personal Data for as long as we have an on-going
relationship with you. Once our relationship has ended (for example because the Services
have been delivered and paid for in full, or you have exercised your right to withdraw
from the contract), we will, subject to any retention requirements under applicable
laws, erase or anonymise your Personal Data.
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Marketing.
Personal Data provided to us for marketing purposes may be retained until you opt out or until
Bills Eazy becomes aware that any such data is inaccurate.
7. Is correspondence that you send to us saved?
Yes. If you send us correspondence, including e-mails and faxes, we may retain such data along
with any records of your account. We may also retain customer service correspondence and
other correspondence involving you, us and any Leizam Ventures LTD subsidiary, our partners, and our
suppliers. We will retain these records in line with our Retention Policy.
8. Data Security
We are committed to maintaining the security of your Personal Data and have measures in place
to protect against the loss, misuse, and alteration of the data under our
control.
We employ modern and secure techniques to protect our systems from intrusion by unauthorized
individuals, and we regularly upgrade our security as better methods become
available.
Our datacentres and those of our partners utilise state-of-the-art physical security measures to
prevent unauthorized access to the facility. In addition, all Personal Data is stored in a
secure location behind firewalls and other sophisticated security systems with limited
(need-to-know) administrative access.
All Bills Eazy employees who have access to, or are associated with, the processing of Personal Data
are contractually obligated to respect the confidentiality of your data and abide by the
privacy standards we have established.
Please be aware that no security measures are perfect or impenetrable. Therefore, although we use
industry standard practices to protect your privacy, we cannot (and do not) guarantee the
absolute security of Personal Data.
9. Does this Privacy Notice apply to other websites?
No. Our Website/App may contain links to other Internet websites. By clicking on a third-party
advertising banner or certain other links, you will be redirected to such third-party
websites.
We are not responsible for the privacy policies of other websites or services. You should make
sure that you read and understand any applicable third-party privacy policies, and you
should direct any questions or concerns to the relevant third-party administrators or
webmasters prior to providing any Personal Data.
10. Direct marketing
With your consent, Bills Eazy or Leizam Ventures LTD or its Subsidiary may sometimes contact you (by email, SMS text, letter or
phone) in order to provide targeted marketing about our Services or the services of another
Leizam Ventures LTD subsidiary. Such marketing communications will only be sent to you if
you gave your consent (when you registered for our Services or at another point) and you
have not withdrawn such consent or if there is another legitimate basis to send such
communications to you.
All marketing e-mails you receive from us will include specific instructions on how to
unsubscribe and you may unsubscribe at any time.
Additionally, you can unsubscribe from marketing by contacting us by a method described in Section 13 of
this Privacy Notice.
You should note that we are opposed to third-party spam mail activities and do not participate
in such mailings, nor do we release or authorize the use of customer data to third parties
for such purposes.
11. What are my data protection rights?
Subject to verification of your identity, you may request access to and have the opportunity to
update and amend your Personal Data. You may also exercise any other rights you enjoy under
applicable data protection laws. Please use the contact details in Section 13 of this
Privacy Notice.
“Data Subjects” have the right to:
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Request access to any Personal Data we hold about them as well as related data, including
the purposes for processing the Personal Data, the recipients or categories of
recipients with whom the Personal Data has been shared, where possible, the period
for which the Personal Data will be stored, the source of the Personal Data, and the
existence of any automated decision making;
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Obtain without undue delay the rectification of any inaccurate Personal Data we hold about
them;
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Request that Personal Data held about them is deleted provided the Personal Data is not
required by us, a Leizam Ventures LTD subsidiary for compliance with a legal obligation under
applicable law or for the establishment, exercise or defence of a legal
claim;
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Under certain circumstances, prevent or restrict processing of your Personal Data, except
to the extent processing is required for the establishment, exercise or defence of
legal claims; and
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Under certain circumstances, request transfer of Personal Data directly to a third party
where this is technically feasible.
Also,where you believe that Bills Eazy has not complied with its obligations under this Privacy Notice
or the applicable law, you have the right to make a complaint to a relevant Data Protection
Authority or through the courts. Although not required, we would encourage you to let us
know about any complaint you might have, and we will respond in line with our Complaints
Procedure (see Section 12 of this Privacy Notice).
12. Privacy-Related Complaints Procedure
Where you believe that we have not complied with our obligations under this Privacy Notice, or the
applicable law, you have the right to make a complaint to our Data Protection and Privacy
team.
We would encourage you to let us know about any privacy related complaint you might have, and
we will respond in line with our complaints procedure – our contact details are set
out below.
Privacy-related complaints or concerns can be lodged with our privacy team:
dataprotection@billseazy.com
Bills Eazy employees are required to direct any privacy-related complaints or concerns to our privacy
team.
Bills Eazy will aim to send an acknowledgement within 10 days of receipt of the
complaint/concern.
Bills Eazy will conduct an investigation in accordance with relevant laws and will aim to respond
substantively within 28 days of receipt of the complaint/concern.
If further time is required to investigate your complaint/concern, Bills Eazy will write to you
within 28 days of receiving the complaint/concern, informing you of the investigation
timeline which will be no longer than an additional two months for the complaint procedure
to be concluded.
In the case of a rejection of the complaint, Bills Eazy will provide you with a written explanation
for the rejection.
If the complaint/concern is considered justified, Bills Eazy will take reasonable steps to try to
address the complaint/concern to your reasonable satisfaction.
For all other complaints or concerns about our Services that are unrelated to privacy, please
contact our Customer Service department.
13. Contact Us
If you have any questions or concerns about this Privacy Notice or Bills Eazy's data practices,
please contact our privacy team:
dataprotection@billseazy.com
Any complaints will be handled in line with our complaints procedure as set out in Section 12 of
this Privacy Notice.