Customer Care: +254 758 515 151

Privacy Policy

INTRODUCTION

We promise to remain committed to keeping your personal data confidential and safeguarding it. All processing of personal data will be carried out lawfully, fairly and in a transparent manner in relation to any data subject. 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

  • Customer/Member– An individual who joins TRANS NATION DT 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.
  • Agent– A person or entity who has signed an agreement with TRANS NATION DT SACCO and is recognized as a merchant or agent in accordance with any applicable laws or Regulations.
  • Visitor – A person (including contractors/subcontractors or any third parties) who gains access to any TRANS NATION DT SACCO premises.
  • Vendor/supplier– Any supplier who has been contracted by TRANS NATION DT SACCO and executed a supplier contract. Employee– An individual who works for TRANS NATION DT SACCO, typically under a contract of employment, in exchange for wages or salary.

About Us

  • In this Privacy Policy, references to “we” or “us” or “our” are to TRANS NATION DT SACCO, which was founded and registered in the year 1993 under the Co-Operative Societies Act, Cap 490 as a SACCO Society No C/S 6826 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.

  • Agent– A person or entity who has signed an agreement with TRANS NATION DT SACCO and is recognized as a merchant or agent in accordance with any applicable laws or Regulations.
  • Visitor – A person (including contractors/subcontractors or any third parties) who gains access to any TRANS NATION DT SACCO premises.
  • Vendor/supplier– Any supplier who has been contracted by TRANS NATION DT SACCO and executed a supplier contract. Employee– An individual who works for TRANS NATION DT SACCO, typically under a contract of employment, in exchange for wages or salary.

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.

    The following Principles will be adhered to in processing your Personal Data;

    1. Lawfulness, fairness and transparency; We shall inform you when we intend to collect your Personal Data, how we will use the data and whether it will be passed to a third party.
    2. Purpose limitation; Our data collection will be for a purpose that is lawful and transparent. The data will not be processed in a manner that is at odds with the original purpose.
    3. Data minimization; We shall only collect personal data that is adequate and relevant.
    4. Accuracy; We shall carry out regular review of data for the purpose of amending any outdated or inaccurate data.
    5. Storage limitation; We will delete or anonymize any of your personal data once it has served its purpose.
    6. Integrity and confidentiality; We will ensure that we have adequate safeguards in place to protect your personal data.
    7. Accountability; We will always strive to ensure we comply with the requirements of the law.

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, SACCO account applications, loan applications, member updates, ATM applications, TN Cash App, and e-commerce platforms.
    2. Subscribe to or use a TRANS NATION DT 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 claims arising from demise of our members.

    We do not onboard minors (any person under 18 years of age) except where you additionally register.

KIND OF INFORMATION WE REQUEST YOU TO PROVIDE TO US

  • The following information regarding our customers/Members can be collected and stored about you but is not limited to the following;

    • 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, marital status, family details, postal address, Tax information, salary information, bank information and health status during member enrollment, during nominee declaration, Internal Funds Transfer, Opening Account, Account Activation, TN Cash App onboarding, Online Onboarding and loan origination application, E-channels onboarding, Member Details Update, Standing Order placement and RTGS Service.
    • In our loaning processes we shall collect your employment information, including your Name, Phone number, Employment number, Email address, 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.
    • Your call data records, Email contact details and Social media contact details whenever you contact SACCO. To make analysis geared towards improving services rendered to you and other members.
    • We use Closed Circuit Television (CCTV) surveillance recordings. CCTV Devices are installed at strategic locations to provide a safe and secure environment in all TRANS NATION DT SACCO premises as a part of our commitment to community safety, security and crime prevention.
    • For market research geared towards identifying our customers’ needs and how to satisfy them.
    • 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.
    • 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.

    We will process all the above information with your consent unless in instances where it is still in line with the law to continue processing this information when consent has been withdrawn.

HOW WILL WE USE YOUR PERSONAL DATA?

  • We will always ensure that we obtain consent from you before we carry out any processing on your data. However, this will not apply if your interests do not override our interest and in case of defense of a legal claim.

    We may use and analyze your information for the following purposes:

    • Processing products and services that you have applied for from us or through third parties on our e-commerce platform.
    • Executing deduction or recovery instructions for loans owed and collections of your SACCO contributions, fees, and charges from your employers, financial institutions etc.
    • 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.
    • 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.
    • Responding to any of your queries or concerns.
    • In order to meet the necessary regulatory obligations, we may verify your identity information by accessing publicly available and/or restricted government databases.
    • Carrying out credit checks and credit scoring.
    • 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).
    • In order 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.
    • In business practices including quality control, training, electronic records management, online meetings and ensuring effective systems operations.
    • To protect our network.
    • 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.
    • Preventing and detecting fraud or other crimes and for debt recovery.
    • 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.
    • Management of any of our online platforms/websites.
    • Management of human resource services to our employees.
    • To manage your membership/account that you hold with us.
    • To fulfil any contractual agreements between you and us.

DATA RETENTION: FOR HOW LONG WILL WE RETAIN YOUR DATA?

  • We will keep your data to fulfil the purpose for which it was intended. This will be guided by our Data Retention Policy which will clearly specify for how long we shall keep your data. As a norm, we keep your financial data for seven years after the termination of the relevant agreement or ending of your business relationship with Trans Nation DT SACCO. We shall abide by Legal provisions that might require us to preserve data longer than seven years. Shorter retention periods will apply for some personal data.

    In specific situations, we may also keep data for longer than we are required by the retention period fixed by us. We will do this if, for example, the judicial authorities request camera images, in which case we will keep the images for longer than we usually do, or if you have submitted a complaint, in which case the underlying data must be kept for longer.

    In case we no longer require the personal data for the purposes for which we collected it, we may keep the data for archiving purposes, in the event of legal proceedings, or for historic or scientific research purposes or statistical purposes.

ACCESS TO YOUR PERSONAL DATA

  • You have a right to access your personal data from Trans Nation DT SACCO whenever you need it. Your personal data can be accessed only by individuals who need to have access owing to their role and for official business purposes. All our people who interact with your data are bound by a duty of confidentiality and have been trained in the Data protection law requirements.

USE OF PERSONAL DATA FOR ANY OTHER PURPOSE

  • Trans Nation DT SACCO Ltd will use your personal data for the purpose for which it was obtained or where the purpose is closely related to the purpose you gave consent. If the purpose differs significantly from the purpose consented to earlier, we will request you to voluntarily give consent to the new purpose. Consent can be withdrawn at any time. To do this, please contact dpo@tnsacco.co.ke

INFORMATION SHARING

  • We will endeavor to ensure that your personal data is confidential, error free and available. For us to be in a position to provide some services we may have to share your information with our data processors. We will strive to ensure that any personal data shared to third parties is handled in compliance with provisions of the law. Some of the parties that we may share your personal to include;

    • Regulatory bodies for them to carry out their duties.
    • Credit reference bodies.
    • Data processors who we have an agreement with.
    • Our payment services provider when you make a payment for a service on the website to enable us to process your payment.
    • Our identity verification partner to verify your identity where you choose to select this option.
    • Where you have agreed, to our refer-a-member program provider, solely to enable your participation in the program.
    • Suppliers of channel and integrated services we require in order to provide you with our products and services.

YOUR RIGHTS IN REGARDS TO YOUR PERSONAL DATA WITH TRANS NATION DT SACCO:

  1. Right to Access

    You may ask through our staff from any of our branches or via our email to access all the information that you provided about yourself. We shall respond to such requests within 30 days.

  2. Right to Erasure

    You may request that we erase data concerning yourself that we have captured, for example if you object to the processing of your personal data. This is done if your interest is greater than the Sacco interest in processing of the data.

  3. Right to Data Portability

    You have the right to request the SACCO to supply you with data that you previously provided to us in the context of a contract with us or with your consent, in a structured, machine-readable format, or that we transfer such data to another party. If you ask us to transfer data directly to another party, we can do this only if this is technically feasible.

  4. Right of Rectification

    If your personal data is false or misleading, you may request that we change or supplement the data.

  5. Right to restrict processing

    You may request to restrict the processing that is carried out on your Personal Data. This means that we will process fewer Personal Data relating to you.

  6. Right to object to Processing

    You have a right to object to processing of your personal data. However, this will not apply if your interests do not override our interest and in case of exercise or defense of a legal claim.

  7. Right to object to Direct Marketing

    The SACCO will from time to time inform you about services which may be of interest to you through emails, text messages, telephone or letters. You have the right to request the Sacco to cease sending these marketing notifications to you. If need be, place your request to dpo@tnsacco.co.ke

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.

LINK TO THIRD PARTY WEBSITES

When clicking on a link within our platforms, you may 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 THE 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 TRANS NATION DT SACCO website.

CONTACT INFORMATION:

If you have any questions, comments or complaints about this Privacy Policy, please contact us using the details below:
Trans Nation DT Sacco Ltd
TNSACCO Plaza
P.O BOX 15-60400 Chuka, Kenya
Email dpo@tnsacco.co.ke
Mobile Number: 0758515151