We are committed to transparent and secure data processing. We are committed to process any personal data in line with Kenya privacy standards and laws. In this privacy notice we provide you with information about what personal data we process and for what purposes, what are your rights and where you can contact us in case you have any questions or concerns about your personal data processing. We only process personal data where we have your consent or where we are entitled to do so based on other legitimate reasons, in particular where (a) processing is necessary for the performance of the Service and to enable us to contract with you in connection with provision of the Service, (b) processing is necessary for compliance with a legal obligation to which we are subject; (c) processing is necessary for the purposes of the legitimate interests pursued by us as the data controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of you as the data subject and which require protection of personal data, in particular where the data subject is a child.
We do not process any special categories of personal data, i.e. we do not process any personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
If you are not at least 18 years old, please seek advice of your parents, or other adult person who is the holder of parental responsibility before you start using the app or any of the Services.
Unless a definition of a capitalized term used in this Privacy Policy is defined below you will find the interpretation of the term in our Terms of Services.
Service means a set of features which allow users to track and analyze their financial situation or any other service provided by app (as the case may be). Services may be different for users of different platforms – Android, iOS and web and can also be divided into Free Features and Premium Features. Provider has the right to add or limit scope of services at any time.
User or you means a person who uses the app, Services, other applications, websites or reads Content created or made available by Provider.
An app means a program (application) which was created to record the Users’ expenses as well as other financial or nonfinancial records or content by User’s choice.
App means a specialized program (application) used by the User.
App Store means an app store platform allowing users to browse and download apps.
Website means a connected group of pages available at www.winguone.com on the World Wide Web, regarded as a single entity with certain Content maintained by Provider.
Premium features mean additional set of services which are bringing certain value for certain Users and are accessible during trial period or via an in-app-purchase. This set of features is not definite as the Provider can add or remove Premium features.
Content means something that is to be expressed in the app, Website or other media, as speech, writing, film, clip, video or any of various arts. Content can be created by Provider or by User.
Personal information or personal data means in general any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Third party means an organization which Provider cooperates (and which, as the case may be can provide certain parts of Service or operate an application used by a User).
Cookies means a small amount of data, which often includes an anonymous unique identifier, that is sent to your browser from a website’s computers and stored on your computer’s hard drive.
Web beacons means images (single-pixel gifs) embedded in a web page or email for the purpose of measuring and analyzing site usage and activity.
Offer means any unspecified marketing activity which can be displayed to User.
Law means the laws of the Republic of Kenya.
What information do we process about you and how is it collected?
When you choose to log into the app using your Google or Facebook account, we will receive some of your Google account information or Facebook account information in the extent corresponding to your Google/Facebook privacy settings. We are receiving from those services your email, name and surname.
Where you wish to obtain a Premium feature of our App, the payment service providers will collect information necessary in order to process the payment for our Services. We do not process information about your credit or debit card, as the payment is processed via the respective App Store. We identify you in our system via your respective App Store ID, which is a digital code. We do not obtain your identity information that you provided to the respective App Store.
When you use the app we collect details as how you use our app, in order to provide you with the Service those data are collected by analytical tools – Mixpanel, Fabric or Google Analytics.
When you use the app and you will grant us a permission for that, we can:
– Read your sms data. Unless you agree otherwise, we process this information in order to provide you with functionalities in our app that will help you track your expenses. – Receive crash analytics and bug reports – helps us fix any issues on the app. – Read, modify or delete your content in storage – allow us store your content on your device – View Wi-Fi connection – which allows us to switch from offline to online mode to synchronize your content and show advertisments.
The above permissions are opt-in and you can always change your setting in your mobile device in Settings – Apps – Permissions section.
Your data may be used for providing services you request in relation to your use of the app or other Services provided by WinguOne. Sending communications or contacting you with relevant information regarding our services or with Offers. We use your data for statistical and marketing analysis, system testing, maintenance and development or in order to deal with your request or claim through our customer service channel. Based on your data, we use your data to provide information we believe is of interest of you such as advices on financial behavior or special offers from our partners.
We may use analytics technology to create reports and analysis of your preferences (geodata, purchase preferences, planned spending), which will enable us to provide you with better Service and make you personalized Offers. We use Google Analytics, Facebook Analytics, Mixpanel and Fabric analytic services to be able to address you more relevant messages based on your behavior.
If you use an App provided by WinguOne, we may from time to time send a push notification or in-app message directly to your app. You may turn-off such communication within the app.
For technological reasons your account will be deleted from our servers within 1 month following your request. In the case of the company termination or discontinuation of service, your data will be permanently deleted.
The app uses in-app storage and we dont transfer data unless consented upon. Any data transfers made shall be made over secure TLS connections.
Communications
All private data exchanged with Provider is always transmitted over TLS.
Right of access to your data
You have right to request that we provide you with a confirmation as to whether or not we process your personal data and, where that is the case, grant you access to the personal data and the following information: (a) the purposes of the processing; (b) the categories of personal data concerned; (c) the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations; (d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; (e) the existence of the right to request from us rectification or erasure of personal data or restriction of processing of personal data concerning you or to object to such processing; (f) the right to lodge a complaint with a supervisory authority; (g) where the personal data are not collected from you, any available information as to their source; (h) the existence of automated decision-making, including profiling and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you. If your data were transferred to a third country or to an international organizatio, you have the right to be informed of the appropriate safeguards relating to the transfer. If you request so, we shall provide you with a copy of your personal data we are processing. For any further copies requested by you, we may charge a reasonable fee based on administrative costs. If you made the request by electronic means, and unless otherwise requested by you, the information shall be provided to you in a commonly used electronic form. The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.
You can delete all your data at anytime from the app by uninstalling the app. We reserve the right to use any aggregated or anonymous data derived from or incorporating your Personal Information.
Any information submitted to us you are responsible for maintaining the accuracy of such information.
The relationship between us in respect of your data protection is regulated by the laws of Kenya and directly applicable Regulations. We may need to change the information contained in this Privacy Policy from time to time. We advise you to check our Privacy Policy regularly for the latest version. We will notify you about significant changes in the way we treat personal information, by in-app notifications or placing a prominent notice on our Website.