Progressive Credit Limited
Data Protection &
Privacy Policy
- Privacy Statement
- Data We Process
- How We Collect Your Data
- Data Retention
- Special Categories of Data
- Automated Decision-Making
- Internal Data Access
- Other Purposes
- International Transfers
- Your Rights
- App Permissions
- User Consent
Privacy Statement
This Statement provides information on how Progressive Credit Limited ("PCL") approaches the processing of your personal data. Our commitment to respecting your privacy and safeguarding your personal data remains stronger than ever.
1.1 Personal Data
Information that directly or indirectly identifies or says something about you — including your name, address, income, or information relating to a sole trader, commercial partnership or professional partnership.
1.2 Processing Data
Processing means anything that can be done with personal data — including the collection, storage, use, transfer and removal of data.
1.3 Whose Personal Data Does PCL Process?
We process personal data if we have, want to have, or have had a business relationship or contact with you, including:
- Existing clients (domestic & foreign)
- Potential customers
- Interested individuals
- Third-party participants
- Security providers
- Guarantors
Which Data Does PCL Process?
| Type of Data | What It Includes | How PCL Uses It |
|---|---|---|
| Identification Data | Name, address, phone, email, identity documents (KYC) | Identification, contract preparation, and communication |
| Financial Data | Financial situation, products held, information for obtaining finance | Creditworthiness assessment and product suitability |
| Payment & Transaction Data | Payer details, payment date, remaining loan balance | Correct fund processing; AML/CFT and sanctions monitoring |
| Special Categories & Criminal Data | Health, criminal records, ethnic origin, political inclinations, biometric data | Biometric identification and Anti-Money Laundering compliance |
| Third-Party Data | Data from Credit Reference Bureaus and Company Registry | Director verification and credit rating checks |
How We Collect Your Personal Data
We receive your personal data when you provide it directly to PCL, when entering into a contract with us, and from services provided by businesses we engage — such as lawyers or property valuers.
How Long Does PCL Retain Your Data?
Processing Special Categories of Data
We process special categories of personal data only where permitted by law and where consent has been acquired. You may withdraw your consent at any time.
Automated Decision-Making & Profiling
We do not envisage that any automated decisions will be taken about you that produce legal effects or significantly affect you.
Who at PCL Has Access to Your Data?
Within PCL, your personal data can only be accessed by individuals who require access owing to their role and for official business purposes.
Use for Other Purposes
If there is no sufficiently strong correlation between the original and any new purpose for using your data, we will ask for your explicit consent before proceeding.
International Data Transfers
Where data is transferred outside Kenya, additional safeguards are applied to protect your personal data in accordance with applicable data protection regulations.
Your Customer Data Rights
Right to Access
Request access to all personal information we hold about you. Our Data Protection Office responds within 30 days.
Right to Be Forgotten
Request erasure of your personal data, provided your interest outweighs PCL's interest in retaining it.
Right to Data Portability
Request your data in a structured, machine-readable format or transfer to another party where feasible.
Right to Rectification
Request correction or supplementation of any inaccurate or incomplete personal data we hold.
Right to Restriction
Request that we restrict the processing of personal data relating to you at any time.
Right to Object
Request that PCL stop sending you direct marketing communications at any time.
To exercise any of these rights, please contact your Relationship Officer or the Branch with which you do business.
App Permissions
To provide secure and reliable financial services, our application requests access to certain device features. We only request permissions necessary for core functionality. All data is transmitted securely using encrypted HTTPS protocols.
Camera
Used to enable identity verification and document submission during the loan application process.
- Capture ID documents for KYC verification
- Capture a selfie for identity confirmation
- Upload verification documents
Location
Used to verify your location during loan application and detect suspicious activity indicating fraud.
- Confirm application originates from a valid region
- Improve fraud detection and account security
- Enhance service availability in supported areas
Phone State
Used to identify the device accessing the application and prevent fraudulent activities.
- Device model and operating system
- Network information
- Device identifiers for security verification
Contacts
Requested only when necessary to support customer verification and improve fraud prevention.
- Does not modify or upload contacts without consent
- Does not contact your contacts directly
- Not shared with third parties for marketing
Call Logs
Limited access to 30 days of call log metadata to assist in fraud detection and credit risk analysis.
- Analyzes call timestamps and frequency only
- Does not record or listen to calls
- Does not access call audio or content
Storage
Required to allow you to upload required documents and download account statements.
- Upload identification documents
- Store temporary files during loan processing
- Download statements and loan documents
Data Protection Measures
User Consent
Permission Statement
To provide secure and reliable financial services, our application may request access to certain features of your device. These permissions allow us to verify your identity, detect fraud, process loan applications, and improve service security.
All collected data is transmitted securely using encrypted HTTPS protocols and handled in accordance with our Privacy Policy and applicable data protection regulations.
We only request permissions that are necessary for the core functionality of the application.
Permissions We Request
Camera
We request access to your device camera to enable identity verification and document submission during the loan application process.
- Capture photos of identification documents for KYC verification
- Capture a selfie photo for identity confirmation
- Upload verification documents required for loan processing
Location
We request access to your device location to help verify your location during loan application and detect suspicious activity that may indicate fraud.
- Confirm that the application originates from a valid region
- Improve fraud detection and account security
- Enhance service availability in supported areas
Phone State
We request access to limited device information to help identify the device used to access the application and prevent fraudulent activities.
- Device model and operating system
- Network information
- Device identifiers necessary for security verification
Contacts
We request access to your contacts only when necessary to support customer verification and improve fraud prevention measures.
- Does not modify or upload your contacts without your consent
- Does not contact your contacts directly
- Does not share contact information with third parties for marketing purposes
Call Log
We may request access to limited call log information (30 days) to assist in fraud detection and credit risk analysis. This permission allows the application to analyze call history metadata such as call timestamps and call frequency.
- The application does not record or listen to phone calls
- The application does not access call audio or conversation content
External Storage
We request access to device storage to allow you to upload required documents and download account statements.
- Upload identification documents
- Store temporary files needed during loan processing
- Download statements or loan documents for your records
Data Protection
We implement strict security measures to protect your data, including:
Your personal data is used strictly for providing and improving our financial services.
Questions or Complaints?
Contact your Relationship Officer or the branch with which you do business. We're always here to help.