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Data Protection & Privacy Policy (Ver. 1, 2023)
1. Privacy Statement
This Statement provides information on how Progressive Credit Limited
(hereinafter “PCL” approaches processing your personal data. Our focus and
commitment to respecting your privacy and safeguarding your personal data
remains stronger than ever.
1.1 Terms used in this Statement
1.1.1 Personal Data
Information that directly or indirectly identifies or says something about
you is referred to as personal data. Examples include your name and address,
and information such as your income. Information relating to a sole trader,
commercial partnership or professional partnership is also considered
personal data.
1.1.2 Processing Data
Processing means anything that can be done with personal data. This includes
the collection, storage, use, transfer and removal of data.
1.2 Whose Personal Data does PCL Process?
We process personal data if we have, want to have, or have had a business
relationship with you, or if we have had contact with you.
The people whose personal data we process includes:
- Existing clients both domestic and foreigners
- Potential customers
- People who show an interest in the PCL’s products and services
- People who are connected in one way or another with a business or
organization with which we have, want to have, or have had a business
relationship, such as third-party participants - Security providers and guarantors
2. Which Data does PCL Process?
| Types of Data | What kind of data might be involved | Examples of how PCL will use the data |
|---|---|---|
| Information that allows an individual to be identified directly or indirectly | Name, address, telephone number, e-mail address, information provided in your identity documents to fulfil PCL’s Know Your Customer (KYC) requirements | For identification purposes, to draw up an agreement / contract or to contact you |
| Information relating to or used for agreements / contracts or financial statements | Information about your financial situation, the products you have. Information used for obtaining finance | To assess creditworthiness, or to assess whether a product is suitable for you |
| Payment and transaction data | When a payment is made, information about the person who paid, when the payment took place and what the loan balance remaining | To ensure correct / timely processing of funds is performed. Also, for anti-money laundering / counter terrorism financing and sanctions monitoring. For your security and ours. |
| Special categories of personal data / Criminal data | Information concerning your health, information about criminal records, data which reveal your ethnic origin or political inclinations, biometric data | We process biometric data for identification purposes and criminal data in the context of Anti-Money Laundering |
| Data we receive from Third Parties | Data obtained from Credit Reference Bureaus and Company Registry | We use this information to check Directors and credit rating details |
3. How does PCL collect your Personal Data?
We receive your personal data when you provide it to PCL, when getting into
a contract with us, and from services provided by businesses we engage such
as lawyers or property valuers.
4. How long does the PCL Retain your Data?
We generally retain data for seven years following termination of the
business relationship unless there is a legal obligation to preserve it
longer.
5. Processing of special category of Data at PCL
We process special categories of personal data where permitted by law and
where consent is acquired. Consent may be withdrawn at any time.
6. Does PCL use Automated Individual Decision-making including Profiling?
We do not envisage that any decisions will be taken about you that produce
legal effects or significantly affect you.
7. Who at PCL has access to your Data?
Within PCL your personal data can be accessed only by individuals who need
to have access owing to their role and for official business purposes.
8. Does PCL use your Personal Data for any other Purpose?
If there is no sufficiently strong correlation between purposes, we will ask
for your consent.
9. Does PCL Transfer your data to other countries outside Kenya?
Where data is transferred outside Kenya, additional safeguards are applied
to protect your personal data.
10. Customer Data Rights at the PCL
10.1 Right to Access
You may ask through the branch or relationship officer to access all the
information that we have and process in relation to you. The data
protection office shall respond within 30 days.
10.2 Right to be Forgotten
You may request that we erase data concerning yourself that we have
captured, provided your interest outweighs PCL’s interest.
10.3 Right to Data Portability
You have the right to request PCL to supply you with data in a structured,
machine-readable format or transfer it to another party where feasible.
10.4 Right to Rectification
You may request correction or supplementation of incorrect or incomplete
personal data.
10.5 Right to restriction of processing
You may request that we restrict the personal data relating to you that we
process.
10.6 Right to object to Direct Marketing
You have the right to request PCL to stop sending marketing communication.
11. Whom to contact to place a complaint or log in an inquiry regarding Personal Data?
If you have any questions concerning the processing of personal data by us,
please contact your Relationship Officer or Branch with which you do
business.