PORTS SACCO Privacy Policy.
We respect your right to privacy, and we guard it jealously. In this respect, this Privacy Policy
sets out details of the personal data the SACCO collects, processes and for what purposes. This
Policy should be read alongside, and in addition to, the Data Protection Policy and therefore read
it carefully. The policy applies to all customers, suppliers, agents, and all visitors frequenting any
of the SACCOs premises.
Unless otherwise defined in this Privacy Policy, terms used have the same meaning as in the Terms.
Terms
1. Customer/Member- An individual who joins PORTS SACCO and uses any of our
products and services or accesses our website and applications. It also includes any
person who accesses any of the products and services you have subscribed to.
2. Agent– A person or entity who has signed an agreement with PORTS SACCO and is
recognized as a merchant or agent in accordance with any applicable laws or Regulations.
3. Visitor – A person (including contractors/subcontractors or any third parties) who gains
access to any PORTS SACCO premises.
4. Vendor/supplier– Any supplier who has been contracted by PORTS SACCO and
executed a supplier contract.
5. Employee– An individual who works for PORTS SACCO, typically under a contract of
employment, in exchange for wages or salary.
About Us
In this Privacy Policy, references to “we” or “us” are to Ports DT Savings and Credit Co-
operative Society Limited, which was founded and registered in the year 2017 under the Co-
operative Societies Act, Cap 490 as a SACCO Society Number CS1726 whose main business is
to mobilize savings and provide credit to its members, who will be the controller of any personal
data processed as described in this Privacy Policy..
Scope.
This Privacy Policy applies only to your use of our products and services or access to our
website, facilities and applications. Other linking sites found on our website and applications
may also gather information and you should consult those other parties’ privacy policies as
appropriate and applicable.
Collection of Information.
We collect your personal information with your knowledge and consent when you do any of the
following (please note that this list is not exhaustive):
1. Apply for a specific product or service, including but not limited to SACCO
membership application, loan applications, member updates, ATM applications,
M-Port Cash, Port Sacco Apps, and e-commerce platforms.
2. Subscribe to or use a PORTS SACCO product or service online, on the cloud, on
a mobile or other device.
3. Visit, access or use our websites and portals.
4. Respond to or participate in a survey, marketing promotion, prize competition or
special offer.
5. Subscribe to our services, Short Message Service (SMS), email or social media
platforms.
6. Ask us for more information about a product or service or contact us with a query
or complaint.
7. We may also collect your information from other organizations including credit-
reference bureaus, fraud prevention agencies and business directories.
8. We may collect your information when you interact with us as a visitor, supplier,
agent.
9. We also collect information when you visit any of our premises.
10. When you apply for insurance claims arising from demise of our members
We do not onboard minors (any person under 18 years of age) except where you additionally
register.
What Information is collected?
The information we collect and store about you includes but is not limited to the following:
1. Your identity and employment information, including your name, photograph, address,
location, phone number, identity document type and number, date of birth, email address,
age, gender, employment number, NHIF number, NSSF number, marital status, family
details, belief, biometric data, postal address, Tax information, salary information, bank
information and health status during member enrollment, during nominee declaration,
Internal Funds Transfer, Opening a Fixed Deposit Account, Account Activation, Pesa
Tele App onboarding, Online Onboarding and loan origination application, E-channels
onboarding, Opening a Call Deposit Account, Member Details Update, Standing Order
placement, RTGS Service and employee onboarding process
2. Name, family details, age, profiling information such as level of education, bank account
information, income brackets, etc. collected as part of surveys conducted by us or our
agents on behalf of PORTS SACCO.
3. In our loaning processes we shall collect your employment information, including your
name, Phone number, Employment number, Email address, Biometric, Property details,
Marital status, Family details, Tax information, salary information, bank information,
phone number, identity document type and number, PIN number/ Tax information, salary
/ Business income and postal address.
4. In our marketing activities we collect your Names, Email address, Phone number,
Residence address, Employment number and SACCO membership number.
5. Your preferences for products and services, based on information provided by you or on
your use of PORTS SACCO products and services.
6. Your call data records, Email contact details and social media contact details whenever
you contact SACCO.
7. We use Closed Circuit Television (CCTV) surveillance recordings. CCTV Devices are
installed at strategic locations to provide a safe and secure environment in all PORTS
SACCO premises as a part of our commitment to community safety, security and crime
prevention.
8. We maintain a register of visitors in which we collect and keep your personal data such
as names, company/institution details, telephone number, vehicle registration details and
National ID number. This information is collected for health, safety, and security
purposes.
9. When you use PORTS SACCO WIFI for guests and visitors, we collect and record the
device address and log traffic information in the form of sites visited, duration and date
sent/received.
10. We may use your medical information to manage our services and products to you e.g., in
tax exemption computations.
11. When you visit us, PORTS SACCO collects your personal information for accident and
incident reporting reasons. This includes gathering data from the injured individual or
someone experiencing health issues, such as their name, address, age, next of kin, and
details of the incident, including relevant medical history. The purpose of collecting this
data is because PORTS SACCO is legally obligated to document workplace
incidents/accidents and report specific types of accidents, injuries, and hazardous
situations to the appropriate authority responsible for enforcement.
12. We may collect and process certain personal information, including names, employment
numbers, residence addresses, CCTV records, IP addresses, SACCO membership
numbers, email addresses, and phone numbers. This data is collected for the sole purpose
of conducting investigations when necessary. We understand the importance of
safeguarding your privacy and assure you that any personal information collected will be
treated confidentially and in accordance with applicable data protection laws. We will
only retain this information for as long as necessary to fulfill the investigation purposes
outlined above.
Use of Your Information.
We may use and analyze your information for the following purposes:
1.Processing products and services that you have applied for from us or through third
parties on our ecommerce
2. Executing deduction or recovery instructions for loans owed and collections of your
SACCO contributions, fees, and charges from your employers, financial institutions etc.
3. In the event of defaulted loans, your contact information, and your defaulted loan, may be
shared with your guarantors, your employers, debt collectors, auctioneers, and our legal
service providers. This sharing of information is necessary for the purpose of facilitating
debt recovery and ensuring the proper handling of defaulted loans.
4. As a data subject acting as a guarantor, which in the event of loan defaults by the
borrower, your contact details may be disclosed to other co-guarantors. This disclosure is
made in default notices to ensure transparency and facilitate communication among all
parties involved in the loan agreement.
5. Responding to any of your queries or concerns.
6.To meet the necessary regulatory obligations, we may verify your identity information by
accessing publicly available and/or restricted government databases.
7. Carrying out credit checks and credit scoring.
8. Unless you choose not to receive marketing messages, we will keep you updated about
new products and services, as well as reach out to you with offers or promotions based on
your usage of our own or third-party products and services. (At any given time, you have
the option to contact us and choose to opt out of receiving marketing messages).
9. To meet any legal, governmental, or regulatory obligations or to support our legal
representation in any legal proceedings, we may use your information as required.
10. In business practices including quality control, training, electronic records management,
online meetings and ensuring effective systems operations.
11. To protect our network.
12. We gather information on how you utilize our products and services to gain insights and
enhance their quality. This is done with the intention of developing and improving our
offerings to better meet your needs.
13. Preventing and detecting fraud or other crimes and for debt recovery.
14. For research, statistical, survey and other scientific or business purposes.
Provide aggregated data (which do not contain any information which may identify you
as an individual) to third parties for research and scientific purposes.
15. Management of any of our online platforms/websites.
16. Management of human resource services to our employees.
17. To manage your membership account that you hold with us.
18.To fulfil any contractual agreements between you and us
Storage of Information
1.All information is stored on our secure servers. When you register on any of our
platforms, we will ask you to choose a password which enables you to access the
platform, where applicable. You are responsible for keeping this password confidential.
We ask you not to share this password with anyone.
2. In addition, we (or third parties acting on our behalf) may also store or process
information that we collect about you in countries outside Kenya, which may have lower
standards of data protection. Specifically, servers used for SACCO operations are in Kenya. We have put in place technical and organizational security measures to prevent the loss or unauthorized access to your personal data. However, whilst we have used our
best efforts to ensure the security of your data, please be aware that we cannot guarantee
the security of information transmitted over the internet.
We utilize cloud services for data storage. Your personal data, as provided in accordance
with this privacy statement, may be processed and stored securely using these cloud
services.
Legal Basis for Processing Your Information
Our legal basis for collecting and using the personal information described above will depend on
the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you:
1. Where we have your consent to do so.
2. Where we need the personal information to perform a contract with you (provide
you with a product/service you have applied for)
3. Where the processing is in our legitimate interests and not overridden by your
rights.
4. In some cases, we may also have a legal obligation to collect personal information
from you.
5. If we ask you to provide personal information to comply with a legal requirement
or to perform a contract with you, we will make this clear at the relevant time and
advise you whether the provision of your personal information is mandatory or
not (as well as the possible consequences if you do not provide your information).
6. Similarly, if we collect and use your personal information in reliance on our
legitimate interests (or those of any third party), we will make clear to you at the
relevant time what those legitimate interests are.
Disclosure of Your Information
We may disclose your personal information to third parties when permitted by law including:
1. With your consent.
2. To our suppliers for them to help us provide our product/services to you, this includes:
3. Loyalty program providers.
4. Our provider of customer relationship management services (which allows us, for
example, to send personalized email communications to you);
5. Our provider of file storage and management services if you email us directly.
6. Our payment services provider when you make a payment for a service on the website to
enable us to process your payment.
7. Our identity verification partner to verify your identity where you choose to select this
option.
8. Where you have agreed, to our refer-a-member program provider, solely to enable your
participation in the program.
9. Suppliers of channel and integrated services we require to provide you with our products
and services.
10. Our customer service software if you contact our support team; and
11. Our third-party review and ratings partner, who assists us with collecting and moderating
your review and rating of our product/services.
These suppliers’ use of your personal data may be subject to their own privacy policies, which
are available on their websites, and which we suggest you familiarize yourself within the
relevant circumstances set out above.
1. If we sell or buy any business or assets, in which case we may disclose your information
to the prospective seller or buyer of such business or assets, if they continue to use your
information substantially in accordance with the terms of this Privacy Policy and the Data
Protection Policy.
2. If all, or substantially all our assets or the assets of our subsidiary, are acquired by a third
party if they continue to use your information substantially in accordance with the terms
of this Privacy Policy and the Data Protection Policy, in which case information held by
us will be one of the transferred assets; and
3. If we are under a duty to disclose or share your information to comply with any legal
obligation, or to enforce or apply our Terms and other agreements; or to protect our
rights, property, or safety, our users, or others. This includes exchanging information
with other companies and organizations for the purposes of fraud protection and credit
risk reduction.
Data Retention
1. We retain personal information we collect from you where we have an ongoing legitimate business need to do so and in line with relevant laws and our Records Policy (for example, to provide you with a product service you have requested, you continue to
be a member of PORTS SACCO or to comply with applicable legal, tax or accounting requirements).
2. When we have no ongoing legitimate business need to process your personal information,
we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is
possible.
Your Rights.
You have the following data protection rights:
1. You have the right to request access to your personal data and obtain a copy of the
information we hold about you, along with information on how and why we process your
data.
2. You have the right to request the correction of inaccurate personal data and the
completion of incomplete personal data.
3. You have the right to object to decisions based solely on automated processing, including
profiling, which produce legal effects concerning you or similarly significantly affect
you.
4. You have the right to request the deletion of your personal data when it is no longer
necessary for the purposes for which it was collected, if you withdraw your consent, or if
you object to the processing and there are no overriding legitimate grounds for the
processing.
5. You can edit your personal details via the approved member update procedure whenever
you wish. We maintain a procedure to help you confirm that your personal information
remains correct and up-to-date or choose whether you wish to receive material from us or
some of our partners.
6. You have the right to request the transfer of your personal data to another data controller
in a structured, commonly used, and machine-readable format, where technically feasible.
7. In addition, you can object to processing your personal information, ask us to restrict
processing of your personal information or request portability of your personal
information. Again, you can exercise these rights by contacting us using the contact
details provided under the “Contacting PORTS SACCO” heading below.
8. You may unsubscribe from certain email communications by following the Unsubscribe
link in the email communication itself. You may also email us at info@portsacco.co.ke to
access, correct, or update your personal information on our systems. We will answer
every email as promptly as possible.
9. Similarly, if we have collected and processed your personal information based on your
consent, then you can withdraw your consent at any time. Withdrawing your consent will
not affect the lawfulness of any processing we conducted prior to your withdrawal, nor
will it affect processing of your personal information conducted in reliance on lawful
processing grounds other than consent.
10. If you have any privacy-related questions or unresolved problems, you may contact us
using the information provided at clause 15 below.
11. You have the right to complain to the Data Commissioner about our collection and use of
your personal information.
12. Our platforms may, from time to time, contain links to and from the websites of third
parties. If you follow a link to any of these websites, please note that these websites have
their own privacy policies. Please check these policies before you submit any personal
information to these websites.
Children
We strongly believe in protecting the privacy of children. In line with this belief, we do not
knowingly collect or maintain personal information from persons under 18 years of age, and no
part of the Website is directed to persons under 18 years of age. If you are under 18 years of age,
then please do not use or access the Website at any time or in any manner. We will take
appropriate steps to delete any personal information of persons less than 18 years of age.
Cookies
1. PORTS SACCO website uses cookies. Cookies are small files stored on your computer’s
hard drive which are used to collect your personal information. You may choose to refuse
cookies but, if you do so, some of the functionality of the Website may no longer be
available to you.
2. For more information about cookies, including further details as to what they are and how
to refuse them, please see our Cookies Policy.
Links to Third Party Websites
When clicking on a link within our platforms, you will be taken to third party websites, the use
of which has been arranged by and is the responsibility of the third party. On these websites you
may be asked to submit some information about yourself. Please make sure you are familiar with
the terms and conditions and privacy policy of the third-party website before submitting your
information. The third party may use your personal information for the purposes in their privacy
policy and in accordance with the terms of the third-party website.
Updating this Privacy Policy.
We reserve the right to amend or modify this statement at any time. Any amendment or
modification to this statement will take effect from the date of uploading on the PORTS SACCO
website.
Contacting PORTS SACCO
If you have any questions, comments or complaints about this Privacy Policy, please contact us
using the details below:
Protection Officer:
PORTS SACCO,
Physical Address Port Sacco Plaza, Mwakilingo Road, Mombasa
P.O Box 95372-80104
Mombasa, Kenya
TEL: +254 111-173-000
Email: info@portsacco.co.ke
Right to Lodge a Complaint
If you believe that PORTS SACCO has infringed your data protection rights or if you are
dissatisfied with how we handle your personal data, you have the right to lodge a complaint with
the Office of the Data Protection Commissioner (ODPC) at https://www.odpc.go.ke/
