Last Updated: March, 2025
Our privacy policy (this policy) sets out how Ocluse Chama (each “we”, “us”) manage personal information we collect about you. If you have any feedback on this policy, or you wish to contact us, please email us at admin@ocluse.com. We look forward to hearing from you. We may vary this policy from time to time. We will ensure that the most updated version is on our website. We invite you to check the policy on the website from time to time.
In Kenya, personal information is information, or an opinion about you or from which you can reasonably be identified.When we collect and use personal information about you in Kenya, we manage that personal information under this privacy policy, Privacy and Data Protection Policy 2018 and the Kenyan Data Protection Act, 2019 (the DPA).
We collect personal information about you when we take a record of that personal information. We collect personal information about you only where we need to or where that personal information is related directly to your operations with Ocluse Chama. For example, we collect personal information about you so we can: supply services to you; manage our commercial relationship and arrangements with you; help us to understand your requirements and develop our products and services; offer you our products or other products as they become available and that may be of interest to you; make products available to you at your request; improve the services and products we offer; and If you are an Ocluse Chama customer, we may collect other personal information about you from dealing with you to help us conduct our financial activities efficiently.
We or our service providers may collect personal information about you including:
We keep information while you are a customer with us and for only as long as we need it.
Generally we will keep your information for 7 years but sometimes we need to keep it for longer such as:
Mostly, we collect personal information about you directly from you. We may collect personal information about you from other sources, like when:
Sometimes, we collect personal information about you that is available publicly or from others who:
We will take steps reasonably available to us to protect your personal information from:
We will do this by ensuring that access to your personal information is password protected and available only to those of our employees that need to use, disclose or manage it under this policy.
Personal information that we can’t protect is personal information that you share with us on our social media channels such as email addresses and first and last names.
If, despite our best efforts, a data breach occurs, we will take immediate steps to determine the breach, its cause and how to fix it.
We will advise you of the extent of the data breach (if known) and the most appropriate means of regaining control of that information. We will also notify the Office of the Data Protection Commissioner or any other regulator, if appropriate and comply with all other relevant legal requirements.
We may use personal information about you to:
We may also use your personal information to tell you about our products and services or products and services from our service partners that may be available to you. That may include telling you about competitions or other promotional events in which we invite you to participate. That correspondence is called direct marketing.
You can tell us to stop sending you direct marketing at any time. Please see below for our contact details.
We may also use personal information about you to:
We do not use Government related identifiers (such as KRA PIN or National ID) to identify you in our records. We may collect and use some of your Government related identifiers, but only for reasons required and permitted by Proceeds of Crime and Anti-Money Laundering Act, 2009, the Proceeds of Crime And Anti-Money Laundering Regulations, 2013 Privacy and Data Protection Policy 2018 and the DPA. For example, we may use those identifiers to help us to check your identity before we make products available to you or for tax reasons.
We may exchange personal information about you with:
Financial Service partners such as Safaricom;
suppliers that help us to conduct our business. Amongst other suppliers, that may include suppliers that help us to:
Those suppliers may:
Our arrangements with suppliers will limit use of your personal information to the services they supply to us. We will ask suppliers to in turn ensure their arrangements with contractors limit those contractors’ use of your personal information to help the suppliers perform services for us.
We will require suppliers or their subcontractors to return, destroy or de-identify personal information about you that they hold when they cease performing services for us. If you want information on how those suppliers manage your personal information, please email us at admin@ocluse.com
Suppliers we share personal information with include:
We use Google Analytics services to improve and analyse our app experiences.
We may share information with Google for that purpose. When you use:
Google uses the information Ocluse Chama shares with them to help us understand how you engage with Chama app. Also, Google may use that information for
other purposes. Please read Google’s Privacy Policy to learn more about how Google uses and processes data.
We may transfer your personal data outside the Republic of Kenya if the transfer is necessary for one of the other reasons set out in the DPA including the performance of a contract between us and yourselves, reasons of public interest, to establish, exercise or defend legal claims or to protect your vital interests and where you are physically or legally incapable of giving consent and, in some limited cases, for our legitimate interest.
We may collect personal information about you because the law requires us to do so.
For example, the law requires us to collect personal information about you to:
You can ask us any time to stop sending you direct marketing information. When we email you with direct marketing, you can respond by clicking unsubscribe and we will stop sending you direct marketing. We do not charge you a fee for asking us to stop direct marketing.
You can ask for access to personal information we hold about you anytime. We may ask you to detail the information you require if you want only some of that personal information.
If you want to access the personal information we hold about you, please email us at admin@ocluse.com.
You may also want to access personal information we have disclosed about you to third parties or to make a complaint to those third parties. The privacy policies of those third parties will tell you how you can make an access request or a complaint to them.
Generally, we will give you access to the information you request. There may be some circumstances, permitted by the APPs, in which we will not give you that access. For example, we may not give you access to information where:
We will give you written reasons if we refuse to give you access to personal information you request, unless there are reasonable grounds (such as confidentiality obligations we owe) for not giving you those reasons. In any case, we will give you an explanation if we do not give you access to information because of a commercially sensitive decision-making process.
We will give you access to the information you request in the manner you request (for example, by email), if we are reasonably able to do so. If we are not able to do so or if we have a reason for not giving you access to all the information you request, we will try and work with you to give you access to personal information we hold about you in a way that meets your needs and our needs.
We will respond to any request you make for access to personal information we hold about you within a reasonable time after you make the request. The time it takes will depend on the amount of information you seek and whether we have to make more enquiries of you to clarify your request. We expect to respond to any request you make for access within 30 days after we receive your request.
Depending on the amount of information you request, we may charge you a fee for organising the information you request from us. We will give you an estimate of the fee before we organise the information. Then, we can work with you to check whether you wish to limit your request to reduce the charges.
We take steps, reasonably available to us, to ensure that the personal information we hold about you is accurate, up-to-date and complete. To assist us, we ask that you contact us and update the personal details we hold about you (for example, your name and contact details), if those details change. You can contact us by email to admin@ocluse.com.
You may consider that the personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading. You can request us to correct the personal information we hold about you by email to admin@ocluse.com.
If we receive your request to correct information but consider that the information does not need correcting, we will give you a written notice setting out our reasons. Also, we will give you details of how you can:
We will respond to any correction request you make within a reasonable time after you make the request.
We will not charge you for correcting or associating a statement to personal information at your request.
If you have a complaint start with us, but there are other ways
If you have a complaint about the way we manage the personal information we hold about you, please email us at admin@ocluse.com.
If we cannot resolve your complaint in a manner that is satisfactory to you and within 30 days of receiving your complaint, you can reach out to the office of the Data Protection Officer.