Privacy Policy

Effective Date: August 6, 2024

This Privacy Policy describes our policies and procedures on the collection, use, and disclosure of your information when you use our service and informs you about your privacy rights and how the law protects you. If you disagree with our policies and practices, you can choose not to use our services. For more information about Zuri Cash, please visit the “Privacy Policy” section on our official website. This policy may change from time to time, and if a specific product has its own privacy policy or user service agreement with special provisions, that product’s privacy policy will take precedence; for matters not covered by that product’s privacy policy or user service agreement, this policy will apply. We use your personal data to provide and improve the service. By accessing or using the service, you agree to the collection and use of information in accordance with this Privacy Policy.

Introduction

Zuri Cash respects your privacy rights and is committed to protecting your personal data. When you use our products and/or services, we may collect and use your information. Through this “Zuri Cash Financial Privacy Policy” (“this policy”), we aim to explain our business situations and the types of personal information we need to collect, as well as the ways we provide you with access, update, delete these information and protection measures, and the rules we must follow when we share, transfer, or publicly disclose your personal information. This policy is closely related to the Zuri Cash financial services you use and the various business functions included in those services (collectively referred to as “our products and/or services”). We hope you read this policy carefully before using our products and/or services and confirm that you have fully understood the contents of this policy (especially the content in bold) and can make choices you deem appropriate according to the guidance of this policy. The relevant terms involved in this policy are explained concisely for your better understanding.

It is particularly noted that this policy only applies to the products and/or services defined in this policy.

How we collect your personal information
How we use your personal information
How we use cookies and similar technologies
How we retain, share, transfer, and disclose your personal information
How we protect your personal information
Your rights
How we handle minors’ personal information
Security and privacy statement
How this policy is updated
How to contact us
Definitions of keywords in this policy

How We Collect Your Personal Information

We will collect and use the personal information you provide actively or that is generated during your use of the products and/or services, following the principles of legality, fairness, and necessity for the purposes described in this policy. If we intend to use your personal information for purposes not described in this policy, or use information collected for a specific purpose for another purpose, we will notify you reasonably and obtain your consent again before using it.

1.1 Personal Data

While using our services, we may ask you to provide certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:

Phone number
Email address
Name
Gender
Date of birth
ID Card Number
Educational information
Marital status
Occupational information
Address information

1.2 Usage Data

We obtain your personal information through the following two channels:

Information you provide directly: We may collect and store the information you provide when using Zuri Cash financial services, including the information you provide when filling in online forms, applying for products and/or services, participating in feedback, resolving disputes, or contacting us regarding Zuri Cash financial services, and the information generated about your transactions and activities during your use of our services. Usage data is collected automatically while using the service.
Information we collect proactively: When you use Zuri Cash’s website, app, and related services, we collect information sent by your computer, mobile phone, and other access devices.

1.3 Information from Third-Party Social Media Services

If you decide to grant us access to a third-party social media service, we may collect, with your consent, personal data that is already associated with your third-party social media service account, such as your name, email address, and activity. You may also have the option to share additional information with us through your third-party social media service account. If you choose to provide such information and personal data during registration or otherwise, you are giving Company permission to use, share, and store it in a manner consistent with this Privacy Policy.

1.4 Mobile Data When Using the Application

When using our application, in order to enjoy our financial services and provide data basis for anti-fraud systems, we may collect and sync the following information with your prior permission:

Location

Purpose of Permission Usage: We need access to users’ rough location data to ensure the security of their accounts and our platform. By knowing a user’s rough location, we can identify and prevent potential offshore money laundering, illegal access, and other offences. This permission helps us to protect the privacy of our users by not accessing or storing their precise location information while securing our services.
How Data is Used: When a user attempts to log in or access the service from a location different from their usual area of activity, the app can use rough location data to identify and flag these unusual behaviours. This helps prevent unauthorised offshore access, which in turn protects user accounts from fraud or hacking.
How Data Security is Ensured: We promise that your SMS messages will be encrypted and transmitted through HTTPS (https://app.zuricash.live). Without your permission, your data will not be shared with any third party.

Calendar Permission

Purpose of Permission Usage: We collect data from the user’s mobile phone calendar, including the calendar event title, calendar event description, and calendar event start and end times
How Data is Used: We collect the user’s calendar time in order to remind the user at the appropriate point in time to prevent the user’s credit from being adversely affected by forgetting to make a payment.
How Data Security is Ensured: We promise that your SMS messages will be encrypted and transmitted through HTTPS (https://app.zuricash.live). Without your permission, your data will not be shared with any third party.

SMS Permissions
1. Purpose of Permission Usage: When you use our application, we will use your financial SMS information to assess your cash flow. We can identify the bank accounts you may hold and your transaction records and use this information to detect potential fraud or illegal use of our services. You may refuse or agree to grant this permission, but if you refuse to provide SMS permissions, we may not be able to accurately assess your risk and credit.
2. How Data is Used: With your permission, we will collect your SMS permissions. The collected information will include the content of the sender, the date of the sent SMS, and the mobile number of the sender, which will help us identify your banking information and banking patterns. We will also collect and process your phone data, such as SMS logs.
3. How Data Security is Ensured: We promise that your SMS messages will be encrypted and transmitted through HTTPS (https://app.zuricash.live). Without your permission, your data will not be shared with any third party.
Application List Permissions
1. Purpose of Permission Usage: We use your mobile application list to evaluate your operating environment to prevent fraud and hidden virus software. Illegal software may steal your funds through virus intrusion. We need to identify and analyze your risk level to process loans and help prevent fraud.
2. How Data is Used: We will collect the version number of the installation package, the app name, installation time, last update time, and package name to prevent your personal information from being illegally obtained, to more accurately prevent fraud, protect account security, and identify whether you are a real natural person user.
3. How Data Security is Ensured: The collected information will be highly encrypted and securely uploaded via HTTPS server (https://app.zuricash.live). Without your permission, your data will not be shared with any third party.
Mobile Phone Permissions
1. Purpose of Permission Usage: We need access to your device permissions, which helps us obtain your device information, including hardware information such as the operating system, system version, IMEI number, IMSI number, MAC address, serial number, Android ID, screen size, etc. This information helps us identify your device and ensure that unauthorized devices do not operate on your behalf to prevent fraudulent behavior.
2. How Data is Used: Upon your authorization, this data is used to ensure the security and authenticity of your device.
3. How Data Security is Ensured: We promise that without your permission, your data will not be shared with any third party. We will encrypt and upload your device information through HTTPS server (https://app.zuricash.live).
Contact Permissions
1. Purpose of Permission Usage: We request access to your contact list to assist you in quickly inputting emergency contact details and to implement fraud prevention measures to validate the authenticity of your emergency contacts.
2. How Data is Used: We only collect the information of emergency contacts you designate, including their relationship to you, name, and phone number. This data is used for risk management and anti-fraud verifications.
3. How Data Security is Ensured: Be assured, we will never share this information with any third parties without your explicit consent. The data will be securely transmitted to the Zuri Cash server (https://app.zuricash.live).

The permissions we request will be consistent with the service functions provided. If our business functions are adjusted, the device permissions we request will also be adjusted accordingly. We will separately prompt you whether to enable these permissions and explain the purpose of permission requests when we first call the device permissions. Please note that enabling these permissions means you authorize us to collect and use this personal information to achieve the above functions. If you disable permissions, you cancel these authorizations, and we will no longer continue to collect your personal information and cannot provide you with the corresponding functions of these authorizations. Your decision to disable permissions will not affect the processing of personal information based on your prior authorization.

How We Use Your Personal Information

To comply with national laws and regulations, and regulatory requirements, and to provide you with services and improve service quality, or to ensure the security of your account and funds, we will use your information in the following situations:
1. To achieve the purposes stipulated in this policy’s “What Information We Collect About You” section.
2. To ensure service stability and security, we will use your information for identity verification, security prevention, fraud detection, prevention or prohibition of illegal activities, risk reduction, archiving, and backup purposes.
3. To inform you about the status of your use of our services, we will send you service reminders.
4. To report to relevant departments according to legal and regulatory requirements.
5. To invite you to participate in customer surveys related to our services.
6. To improve, enhance, and optimize Zuri Cash’s online financial services.
7. To process your applications or feedback requests regarding Zuri Cash’s products and/or services.
8. After de-identifying data through technical means, the de-identified data will not be able to identify the subject. Please understand and agree that in this case, we have the right to use the de-identified information; we have the right to analyze and commercially utilize the user database without disclosing your personal information.
9. We may conduct statistical analysis on the usage of our products and/or services and may share these statistics with the public or third parties to showcase the overall usage trends of our products and/or services. However, these statistics do not include any of your personally identifiable information.
When displaying your personal information, we will use content replacement and anonymization methods to desensitize your information to protect its security.
When we intend to use your personal information for purposes not covered by this policy or use information collected for a specific purpose for other purposes, we will seek your consent in advance. Please understand that the products and/or services we provide to you will be continuously updated and changed. If you choose to use other products and/or services not listed in this policy, we will explain the purpose, method, and scope of information collection in detail and obtain your explicit consent before collecting your personal information. If you refuse to provide the aforementioned information, you may not be able to use that service, but it will not affect your use of other services.

How We Use Cookies and Similar Technologies

3.1 Use of Cookies

To provide you with a more convenient browsing experience, we sometimes store small data files called cookies on your computer or mobile device. A cookie is a plain text file stored by a web server on your computer or mobile device, which can only be retrieved or read by the server that created it. Each cookie is unique to your web browser or mobile application. Cookies typically contain an identifier, site name, and some numbers and characters. With cookies, websites can remember a user’s single visit (using session cookies) or multiple visits (using persistent cookies). Cookies help websites save settings such as the language of your computer or mobile device, font size, and other browsing preferences. This means that users do not need to reconfigure their preferences on each visit. If a website does not use cookies, it will treat the user as a new visitor every time a page is opened. For example, if you log in to a website and then go to another page, the website will not recognize you, and you will be logged out again.
To provide you with more convenient and personalized services, we use cookies and other technologies to offer the following services:
- (1) Remembering Your Account: For instance, when you access information or services that require you to log in, we encrypt and store your login name in a cookie file on your computer. Since it is stored in irreversible encryption, others cannot recognize your login name even if they use your computer. You do not need to perform any additional steps; all collection, storage, and encryption work are handled automatically by the system. Cookies may help you avoid re-entering your account information for using our services.
- (2) Analyzing Your Use of Our Services: For example, we may use cookies and web beacons to understand your usage of our services or which pages or services you prefer.
- (3) Advertising Optimization: We may show you products or advertisements that you might be interested in based on statistics about the websites you visit. These statistics do not include any personal information and may be used to evaluate the effectiveness of ads. Cookies and web beacons help us provide relevant ads based on your information rather than general advertising.
- (4) We may also use web beacon technology to collect anonymous access data. Similarly, these statistics do not include your personal information.
We will not use cookies for any purposes other than those described in this policy. You can manage or delete cookies according to your preferences using the cookie-clearing features of your browser or operating system software at any time. You can clear all cookies stored on your computer; most web browsers automatically accept cookies, but you can usually modify your browser settings to refuse or delete cookies based on your needs. However, doing so may require you to manually adjust user settings on each visit to our website and may affect the security and convenience of the services you use, but it will not affect your normal use of other services we provide.

3.2 Use of Web Beacons, Pixel Tags, and Similar Technologies In addition to cookies, we also use web beacons and pixel tags and other similar technologies on our website. For example, emails we send to you may contain clickable URLs linking to our website content. If you click the link, we will track this click to understand your product and service preferences and improve customer service. Web beacons are typically transparent images embedded in a website or email. With pixel tags in emails, we can know whether the email has been opened. If you do not wish your activities to be tracked in this way, you can always choose to unsubscribe.

4.1 Retention of Your Personal Data The company will retain your personal data only for the period necessary to fulfill the purposes set out in this privacy policy. We will retain and use your personal data as required to comply with legal obligations (e.g., if we need to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The company will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period unless it is used to enhance security or improve the functionality of our services, or if we are legally required to retain such data for a longer period. Typically, we will retain data for up to 1 year after you stop using our services, after which it will be deleted or anonymized.

4.2 Sharing Your Personal Information We may share your personal information in the following situations:

With Service Providers: We may share your personal information with service providers to monitor and analyze the use of our services and to contact you.
With Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to adhere to this privacy policy. Affiliates include our parent company and any other subsidiaries, joint venture partners, or other companies we control or jointly control.
With Business Partners: We may share your information with our business partners to provide you with certain products, services, or promotions.
With Other Users: When you share personal information or otherwise interact with other users in public areas, all users may view this information and potentially distribute it externally. If you interact with other users or register through third-party social media services, contacts on those third-party services may see your name, profile, pictures, and descriptions of your activities. Similarly, other users will be able to view the activities you describe, communicate with you, and view your profile.
With Your Consent: With your consent, we may disclose your personal information for any other purposes.

4.3 Transfer of Your Personal Data We do not transfer your personal information to any company, organization, or individual, except in the following cases:

We transfer your personal information to others with your explicit consent;
As required by applicable laws, regulations, legal procedures, or mandatory administrative or judicial requirements;
In the event of mergers, acquisitions, or bankruptcy liquidation, if personal information transfer is involved, we will require the new company or organization holding your personal information to continue to adhere to this policy, or we will request that the company or organization seek your authorization again.

4.4 Public Disclosure of Your Personal Data We will only publicly disclose your personal information in the following situations:

With your explicit consent, disclose the personal information you have designated in the manner you have agreed to;
In cases of legal requirements, legal procedures, litigation, or mandatory government demands, we may disclose your personal information. Subject to legal and regulatory requirements, when we receive such disclosure requests, we will require corresponding legal documents such as subpoenas or investigation letters. We believe that requests for information should be as transparent as possible within the limits of the law. We carefully review all requests to ensure they have a legitimate basis and are limited to law enforcement authorities for specific investigative purposes with legal rights to access the data.

4.5 Exceptions to Prior Authorization for Sharing, Transfer, or Public Disclosure of Personal InformationAccording to relevant laws, regulations, and national standards, we do not need to obtain your prior authorization for sharing, transferring, or publicly disclosing your personal information in the following situations:

Related to fulfilling obligations prescribed by laws and regulations;
Directly related to national security or national defense;
Directly related to public safety, public health, or major public interests;
Directly related to criminal investigation, prosecution, trial, and enforcement of judgments;
Necessary for protecting your or others’ significant legal rights and interests such as life and property, but difficult to obtain consent;
Personal information you have disclosed to the public;
Collection of personal information from legally publicly disclosed information, such as legitimate news reports or government information disclosure channels.

How We Protect Your Personal Information

Our Technical and Operational Measures for Protecting Your Personal Information

We place a high value on the security of personal information and take all reasonable and feasible measures to protect your personal data:

5.1 Data Security Technical Measures We have adopted industry-standard security measures and common industry security technologies to prevent unauthorized access, modification, leakage, damage, or loss of your personal information:

Encryption Technology: We use encryption technology to store your personal information securely, ensuring transaction and personal information security through security management, policies, processes, network architecture, and more.
Network Security: Our network services use encryption technologies like Transport Layer Security (TLS) protocols and HTTPS to provide secure browsing services, ensuring the safety of your personal information during transmission.
Data Masking: When using your personal information, such as for display or association calculations, we employ various data masking techniques including content replacement and hashing to enhance the security of personal information during use.
Malware Prevention: We use white-box code security testing, black-box security testing, and intrusion detection and prevention technologies to protect your personal information from malicious code.

5.2 Other Security Measures for Protecting Personal Information We manage and regulate the storage and use of personal information through data classification, tiered management, data security management standards, and secure development practices:

Access Controls: We implement strict data access controls and multi-factor authentication to protect personal information. We also enforce comprehensive security controls through strict confidentiality agreements with those accessing the information, as well as monitoring and auditing mechanisms to prevent unauthorized use.
Security Audits: We conduct personal information security audits using code security checks and data access log analysis.
Information Security Committee: We have established an Information Security Committee with dedicated security teams responsible for personal information security matters.
Training: We conduct security and privacy protection training to enhance employees’ understanding of the importance of protecting personal information.

5.3 Handling Security Incidents

Security Assurance: The internet environment is not 100% secure. We will do our best to ensure the safety of the information you send us. If our physical, technical, or administrative protection facilities are breached, leading to unauthorized access, disclosure, alteration, or destruction of information and affecting your legal rights, we will bear the corresponding legal responsibility.
Incident Notification: In the event of a personal information security incident, we will promptly inform you of the basic situation, possible impacts, actions taken or to be taken, suggestions for self-protection and risk reduction, and remedial measures. We will notify you of the incident through email, letters, phone calls, push notifications, or other means. If it is difficult to notify each individual, we will issue an announcement in a reasonable and effective manner. We will also report the incident to regulatory authorities as required.
Contact Us: If you find that your personal information, especially your account and password, has been leaked, please contact us immediately through the contact methods provided at the bottom of this policy so we can take appropriate measures.

5.4 How We Store and Retain Your Personal Information

Retention Period: We will retain your personal information only for the period necessary to achieve the purposes stated in this policy and within the time limits specified by laws, regulations, and regulatory requirements. To protect your consumer rights, unless otherwise required by laws and regulations, we will retain your personal information for up to one month after your account is canceled. After this period, we will delete or anonymize your personal information.
Termination of Services: If you stop using our services, we will cease collecting and using your information, except as required by laws, regulations, or regulatory authorities. If we terminate our services or operations, we will stop collecting your personal information and notify you at least thirty days in advance. After terminating the services or operations, we will delete or anonymize your personal information.

Your Rights

Zuri Cash places great importance on your concerns about personal information. In accordance with Kenya laws, regulations, and standards, we strive to ensure you can exercise the following rights regarding your personal information:

6.1 Access to Your Personal Information

You have the right to access your personal information at any time, except as required by laws and regulations. If you wish to exercise your data access rights, you can access the following:
- Your Application Information: Path in the mobile app: Bill page - My Application Status Inquiry.
- Your Transaction Information: Path in the mobile app: Bill page - My Bills and other historical transaction information.
If you cannot access this personal information through the links above, you may contact us using the methods provided in the “How to Contact Us” section of this policy. We will respond to your access request and complete verification and processing within 15 working days.
For other personal information generated during your use of our products or services, we will provide it as long as it does not require excessive effort. If you wish to exercise your data access rights, you can contact us using the methods provided in the “How to Contact Us” section of this policy.

6.2 Correction/Deletion of Your Personal Information When you find errors in the personal information we process about you, you have the right to request corrections. You can submit a correction request through the methods listed in “Access to Your Personal Information.” If you cannot correct the personal information through the links above, you may contact us using the methods provided in the “How to Contact Us” section of this policy. We will respond to your correction request and complete verification and processing within 15 working days.

Deletion of Your Personal Information You can request the deletion of your personal information by calling our customer service under the following circumstances:
- If our processing of personal information violates laws and regulations.
- If we collect or use your personal information without your consent.
- If our processing of personal information violates the agreement with you. Upon receiving your deletion request, we will process the deletion according to your request and relevant laws and regulations and provide feedback. If we decide to comply with your deletion request, we will also notify the entities from whom we obtained your personal information, requesting them to delete it promptly unless required otherwise by laws and regulations or if these entities have independent authorization from you.
After you delete information from our services, it may not be immediately removed from backup systems, but it will be deleted when the backups are updated.
You can also withdraw our authorization to continue collecting your personal information by canceling your account.
Account Cancellation You can apply to cancel your account directly within our product and/or service, cancel Zuri Cash financial services, or cancel specific service functions you have applied for. You can complete account cancellation through the mobile app by accessing “My - Account Cancellation” or contact us through the methods provided in the “How to Contact Us” section of this policy. After verifying your cancellation information and contract performance, we will process your account cancellation request.
Responding to Your Requests For security reasons, you may need to provide a written request or prove your identity in other ways. We may first require you to verify your identity before processing your request. We will respond and complete verification and processing within fifteen working days. We generally do not charge fees for reasonable requests, but we may charge a fee for repetitive or excessive requests based on the situation. Requests that are groundlessly repetitive, require excessive technical measures (e.g., developing new systems or fundamentally changing existing practices), pose risks to others’ legal rights, or are impractical (e.g., involving information stored on backup tapes) may be refused. We cannot respond to your requests in the following situations:
- Related to fulfilling legal obligations by the personal information controller.
- Related to national security or defense.
- Related to public safety, public health, or significant public interests.
- Related to criminal investigation, prosecution, trial, and enforcement of judgments.
- Where there is sufficient evidence of subjective malice or abuse of rights by the personal information subject.
- To protect significant legal rights of individuals or others but difficult to obtain consent.
- Where responding to the request would severely harm the legal rights of individuals, organizations, or others.
- Involving trade secrets.

6.3 Right to Know About Data Sales According to our policy, we do not sell your personal data. If our policy changes, we will notify you before the change and provide options to refuse data sales.

6.4 Right to Refuse Data Sales You have the right to refuse the sale of your personal data. You can contact us through the following methods to exercise your rights:

Email: zuriCashCSKH@gmail.com
Phone: 0207905232

How We Handle Minors’ Personal Information

Our services are not intended for anyone under the age of 18. We do not knowingly collect personal information from anyone under 18. If you are a parent or guardian and you are aware that your child has provided personal data to us, please contact us. If we discover that we have collected personal data from anyone under 18 without parental consent, we will take steps to delete this information from our servers.

If we need to rely on consent as the legal basis for processing your information, and your country requires parental consent, we may need your parents’ consent to collect and use this information.

Security and Privacy Statement

We value your privacy and data security, and are committed to providing transparent and reliable services. Below are our commitments and measures to ensure your data is secure and to affirm that we are not spyware or malicious software:

No Spyware Commitment Our application does not contain any spyware, malware, or adware. We do not track your activities for unauthorized surveillance, nor do we secretly collect your personal information.
Transparent Data Collection and Use We only collect data that is necessary to provide and improve our services. All data collection and use is done with the user’s knowledge and consent, and strictly adheres to our privacy policy.
User Consent and Control We provide a clear mechanism for user consent and allow users to withdraw consent at any time. Users can manage their personal data through in-app settings or by contacting us, including requesting access, correction, or deletion of data.
Data Security Measures We use industry-standard encryption and access control technologies to ensure your data is secure. We conduct regular security audits and tests to maintain data integrity and security.
Compliance and Audits We comply with all applicable privacy laws and regulations and regularly conduct internal and external audits to ensure our practices meet industry standards.
User Support and Contact Information If you have any questions or concerns, please contact us at:

Email: zuriCashCSKH@gmail.com
Phone: 0207905232

We will provide assistance and answers as quickly as possible.

How This Policy is Updated

Our privacy policy may change. We will not reduce your rights under this policy without your explicit consent. We will post any changes to this policy on the Zuri Cash Financial official website.
For significant changes, we will also notify you in a timely manner through one of the following ways:

(1) Pop-up reminder when you log in to the relevant client software or use Zuri Cash Financial services;

(2) Pop-up reminder when you update the client software version;

(3) Push notification when you use Zuri Cash Financial services;

(4) Announcement on the Zuri Cash official website.

Significant changes referred to in this policy include but are not limited to:

(1) Major changes in our business and service model, such as business functions, purposes of processing personal information, types of personal information processed, ways of using personal information, etc.;

(2) Major changes in our ownership structure, organizational structure, etc., such as changes in ownership caused by business adjustments, bankruptcy mergers, etc.;

(3) Changes in the main objects of personal information sharing, transfer, or public disclosure;

(4) Major changes in your rights to participate in the processing of personal information and how these rights are exercised;

(5) Changes in the department responsible for handling personal information security, contact methods, and complaint channels;

(6) When a personal information security impact assessment report indicates a high risk.

To ensure you receive notifications in a timely manner, it is recommended that you notify us promptly when your contact information is updated. If you continue to use our services after the updated policy takes effect, it means you have fully read, understood, and accepted the updated policy and are willing to be bound by it. We encourage you to review this policy each time you use our services. You can view this policy in the Zuri Cash APP through “Profile - Zuri Cash Privacy Policy”.

How to Contact Us

We have established a dedicated department and a dedicated officer for personal information protection. If you have any questions, opinions, or suggestions regarding this policy or your personal information, please contact us through the following methods:

(1) Call customer service number: 0207905232

(2) Send an email to: zuriCashCSKH@gmail.com

(3) Go to the Zuri Cash APP and click on “Home - My - Help Center - Feedback”.

(4) Go to the Zuri Cash APP and click on “Home - My - Help Center - Customer Service Phone”.

The customer service department will work with the dedicated personal information protection department to respond to you promptly.

Generally, we will respond and complete the verification and processing within fifteen working days. If you are not satisfied with our response, especially if our personal information processing behavior has harmed your legitimate rights and interests, you can also seek a solution through the following external channels: filing a lawsuit with a court of competent jurisdiction or filing a complaint or report with the relevant regulatory authority.

Definitions of Keywords in This Policy

For the purposes of this Privacy Policy:

(1) ‘Account’ refers to the unique account created for you to access our services or parts of our services.

(2) ‘Affiliated Company’ refers to an entity that controls, is controlled by, or is under common control with a party, where “control” means owning 50% or more of the shares, equity interests, or other securities entitled to vote for directors or other managing authorities.

(3) ‘Application’ refers to the software program provided by the company downloaded onto any of your electronic devices, named Zuri Cash.

(4) ‘Company’ (referred to as “the Company”, “we”, “us” or “our” in this Agreement) refers to Zuri Cash, located at MVC8, Sameer Industrial Park, Road C, Nairobi, Kenya.

(5) ‘Cookies’ are small files placed on your computer, mobile device, or any other device by a website, containing details of your browsing history and many uses.

(6) ‘Country’ refers to Kenya.

(7) ‘Device’ means any device that can access the service such as a computer, cellphone, or digital tablet.

(8) ‘Personal Data’ refers to any information related to an identified or identifiable individual.

(9) ‘Service’ refers to the application or website or both.

(10) ‘Service Provider’ means any natural or legal person who processes data on behalf of the company. It refers to third-party companies or individuals employed by the company to facilitate the service, provide the service on behalf of the company, perform services related to the service, or assist the company in analyzing how the service is used.

(11) ‘Third-Party Social Media Service’ means any website or any social network website through which a user can log in or create an account to use the service.

(12) ‘Usage Data’ refers to data collected automatically, either generated by the use of the service or from the service infrastructure itself (for example, the duration of a page visit).

(13) ‘Website’ refers to Zuri Cash, accessible from https://support.zuricash.live

(14) ‘You’ refers to the individual accessing or using the service, or the company or other legal entity on behalf of which such individual is accessing or using the service, as applicable.