Data Privacy Statement
1.0 Introduction
Your privacy is important to us. This privacy statement explains the personal data Nena App (“Nena”) collects, how we processes it, and for what purposes. This statement should be read together with the Terms and Conditions of Use for other products and services. Where there is a conflict, this statement will prevail.
2.0 Definitions
References to “You” means:
i) Customer – the person who subscribes to, uses or purchases any of our products and services or accesses our websites and includes any person who accesses any of the products and services you have subscribed to.
ii) Any agent, dealer and/or merchants who has signed an agreement with us and is recognised as a merchant or agent in accordance with any applicable laws or Regulations.
iii) Any visitor that is a person (including contractors/subcontractors or any third parties) who gains access to any of our premises.
iv) Any supplier who has been contracted by us and executed a Supplier contract.
“Nena”, “we” or “us”, “our” and “ours” means Alderlite Limited.
3.0 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):
a) Register for a specific product or service;
b) Buy, subscribe to or use our product or service online, on the cloud, on a mobile or other device;
c) Ask us for more information about a product or service or contact us with a query or complaint;
d) Respond to or participate in a survey, marketing promotion, prize competition or special offer;
e) Visit, access or use Nena or third-party websites;
f) We may also collect your information from other organizations including credit-reference bureaus, fraud prevention agencies and business directories;
g) We may collect your information when you interact with us as a supplier, agent, merchant or dealer as prescribed in this statement;
h) We also collect information when you visit any of our premises.
We do not onboard minors (any person under 18 years of age) except where you additionally register on their behalf as their parent and/or legal guardian. If you allow a child to use our services, you should be aware that their personal information could be collected as described in this statement.
4.0 What Information is Collected?
The information we collect and store about you includes but is not limited to the following:
i) Your identity and MSIN registration information, including your name, photograph, address, location, phone number, identity document type and number, date of birth, email address, age and gender.
ii) Your credit or debit-card information, information about your bank account numbers and SWIFT codes or other banking information.
iii) Your preferences for particular products and services, based on information provided by you or from your use of our (or third-party) network, products and services.
iv) Your contact details such as when you call us or interact with us through our chatbot, email (we may record your conversations), social media or other interactions with us.
v) Your account information, such as your handset type/model, top-ups and billing statements.
vi) Your call data records: phone numbers that you call or send messages to (or receive calls and messages from), log of calls, messages on the Nena App and your location (where permission is granted on the App).
Save for customer service interactions as noted above, we do not record or store message or call contents.
5.0 Use of Information
We may use and analyse your information for the following purposes:
i) Processing products and services that you have bought from us;
ii) Responding to any of your queries or concerns;
iii) Verifying your identity information through publicly available and/or restricted government databases in order to comply with applicable regulatory requirements;
iv) Keeping you informed generally about new products and services and contacting you with offers or promotions based on how you use our products and services unless you opt out of receiving such marketing messages;
v) To comply with any legal, governmental or regulatory requirement or for use by our lawyers in connection with any legal proceedings;
vi) In business practices including quality control, training and ensuring effective systems operations;
vii) To protect our network including managing the volume of calls, texts and other use of our network;
viii) To understand how you use our network, products and services for purposes of developing or improving products and services;
ix) Preventing and detecting fraud or other crimes;
x) For research, statistical, survey and other scientific or business purposes;
xi) Provide aggregated data (which does not contain any information which may identify you as an individual) to third parties for research and scientific purposes;
xii) Administer any of our online platforms/websites.
6. Categories of Data
Categories of Personal Data as defined in the Data Protection Act of Kenya may be processed depending on the particular types of products and services you have subscribed to.
7. Lawful Basis for Processing Your Information
We will process your personal information based on any of the lawful bases provided for under the Data Protection Law:
i) The performance of a Product/Service Agreement with you;
ii) Alderlite’s legitimate business interests;
iii) Compliance with a mandatory legal obligation;
iv) Consent you provide;
v) Public interest;
vi) Your vital interest.
8. Retention of Information
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we
9.0 Disclosure of Information
9.1 Any disclosure of your information shall be in accordance with applicable law and regulations. We shall assess and review each application for information and may decline to grant such information to the requesting party.
9.2 We may disclose your information to:
i. Law-enforcement agencies, regulatory authorities, courts or other statutory authorities in response to a demand issued with the appropriate lawful mandate and where the form and scope of the demand is compliant with the law.
ii. Our subsidiaries, associates, partners, software developers or agents who are involved in delivering our products and services you order or use.
iii. Fraud prevention agencies.
iv. Publicly available and/or restricted government databases to verify your identity information in order to comply with regulatory requirements.
v. Survey agencies that conduct surveys on behalf of Alderlite.
vi. Emergency service providers when you make an emergency call (or where such disclosure to emergency service providers is necessary for your rescue, health and safety), including your approximate location.
vii. Any other person that we deem legitimately necessary to share the data with.
9.3 We shall not release any information to any individual or entity that is acting beyond its legal mandate.
9.4 We will get your express consent before we share your personal data with any third party for direct marketing purposes.
9.6 Direct Marketing
i. You may be required to opt in or give any other form of explicit consent before receiving marketing messages from us.
ii. You can ask us to stop sending you marketing messages at any time by writing to us or logging into our website and checking or unchecking relevant boxes to adjust your marketing preferences, by following the opt-out links on any marketing message sent to you, or by contacting us at any time through the provided contacts.
iii. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product or service already taken up, warranty registration, product or service experience or other transactions.
10. The Use of Cookies
i. We may store some information (using “cookies”) on your computer when you visit our websites. This enables us to recognise you during subsequent visits. The type of information gathered is non-personal, such as the Internet Protocol (IP) address of your computer, the date and time of your visit, which pages you browsed, and whether the pages have been delivered successfully.
ii. We may also use this data in aggregate form to develop customised services tailored to your individual interests and needs. Depending on the browser you are using, you may be prompted before accepting any cookies or you may prevent your browser from accepting any cookies at all. This may, however, cause certain features of the website to be inaccessible.
11. The Use of Hyperlinks
i. Our websites may provide hyperlinks to other locations or websites on the Internet. These hyperlinks lead to websites published or operated by third parties who are not affiliated with us and are included to enhance your user experience for information purposes only.
ii. We do not endorse, recommend, approve or guarantee any third-party products and services by providing hyperlinks to an external website or webpage, and we do not have any cooperation with such third parties unless otherwise disclosed. We are not responsible for the content of any externally linked website or webpage.
iii. By clicking on a hyperlink, you will leave our webpage and will be subject to the terms of use, privacy and cookie policies of the other website you choose to visit.
12. Access to and Updating Your Information
To update your information, go to the Nena App, select account information and edit. Certain fields may not be available for editing based on identity documents provided unless you submit validated documents to support the change.
13. Safeguarding and Protection of Information
We have put in place technical and operational measures to ensure the integrity and confidentiality of your data through controls around information classification, access control, cryptography, physical and environmental security, monitoring and compliance.
14. International Data Transfers
From time to time, we may need to transfer your personal information outside the Republic of Kenya. Where we send your information outside Kenya, we will ensure that it is properly protected in accordance with applicable Data Protection Laws.
15. Your Rights
Subject to legal and contractual exceptions, you have rights under data protection laws in relation to your personal data, including:
a) The right to be informed that we are collecting personal data about you;
b) The right to access personal data we hold about you and request information on how we process it;
c) The right to request correction of inaccurate or incomplete personal data;
d) The right to request erasure of your personal data, noting that we may retain it where legally required or entitled to do so;
e) The right to object to or withdraw consent to processing of your personal data, subject to legitimate or legal grounds for continued processing;
f) The right to request restricted processing of your personal data, noting that we may be legally entitled or obligated to continue processing;
g) The right to request transfer of your personal data in an electronic format.
If you wish to exercise any of these rights, please contact us at dpo@nena.co.ke
. We may request specific information to confirm your identity and protect your personal data. We aim to respond to all legitimate requests within a reasonable time, though complex or multiple requests may take longer, in which case we will keep you informed.
16. How to Contact Us
If you would like to contact us regarding this privacy policy, please email dpo@nena.co.ke
.
Data Protection Officer
dpo@nena.co.ke
www.nena.co.ke
17. Right to Lodge a Complaint
You have the right to lodge a complaint with the relevant supervisory authority responsible for personal data protection within the Republic of Kenya.
18. Non-Compliance with This Statement
We reserve the right to terminate any agreement with you for failure to comply with this statement and to reject any application for information that is contrary to it.
19. Amendments to This Statement
We reserve the right to amend or modify this statement at any time. The most current version will be available on our website at www.nena.co.ke
, and any amendment will take effect from the date of notification on the website.
Statement Effective Date
2025