Last updated: 3 January 2022
At Tribbe, we respect your privacy and are committed to protecting it. It’s important to us therefore that you understand how exactly we protect your privacy as well as what data we collect and for what purpose.
This policy describes the types of information Tribbe Nation LLC. (“Tribbe”, “Company” or “We”) may collect from you or that you may provide when you visit and utilize Tribbe software available through our apps, software, and the website tribbe.africa (collectively, our “Website“). This includes our practices for collecting, using, maintaining, protecting, and disclosing that information and the basis for doing so.
This policy applies to information we collect on the Website, in e-mail, text and other electronic messages between you and this Website and, through mobile and desktop applications you download from this Website or other services (such as the Google Play Store or the Apple App Store), which provide dedicated non-browser-based interaction between you and this Website.
Collection and Use of Personal Data
We process data:
- in order to provide the services and fulfill our obligations pursuant to the Terms of Service. For example, we cannot provide our services without a verified phone number, form of National ID, an email address to sign into your account, conduct customer services and support, or send educational materials; we cannot provide the service without users providing financial wallets for us to retrieve or send money too;
- where necessary to comply with a legal obligation, a court order, or to exercise and defend legal claims;
- to protect your vital interests, or those of others, such as in the case of emergencies;
- where you have made the information public;
- where necessary in the public interest;
- where necessary for the purposes of Tribbe’s or a third party’s working with Tribbe’s legitimate interests, such as those of visitors, members or partners;
- where you provide consent (for example, to join Tribbe’s mailing lists).
We also process your data based on our legitimate interest in:
- providing a quality service and in improving that service;
- ensuring the services are secure;
- protection against fraud, spam and abuse, etc.;
- understanding how Tribbe users and visitors interact with our websites and services so that we can continuously improve the experience and effectiveness of doing so.
Categories of data we collect
We collect information about you, including information that directly or indirectly identifies you, through your use of Tribee. We do so:
- when you provide the information, through filling out forms or otherwise providing information on our websites and the Tribbe App including the IPRS data system ;
- when we connect to your financial institutions in order to retrieve mobile-money and card payment transaction data on your behalf to perform services;
- when you use location services to record transactions in our mobile apps and to enable personalized advertising and discounts at venues and small business working with Tribbe;
- when you correspond with us to receive customer support via email or WhatsApp.
- Your verified phone number and email address that you provide to us as a username by logging into your e-mail account in the Tribbe App during onboarding.
- Your IP address when you interact with our website and apps.
- When you choose to directly link financial accounts to Tribbe, your login credentials (including usernames and passwords) for the accounts you link to our services, and other information from the financial accounts that you link to our service (including account balances, transactions and holdings).
- Your location when you record a transaction in our mobile applications and have previously activated location services.
- Records and copies of your correspondence (including e-mail addresses different than that used to establish your account), if you contact our team.
- Your responses to surveys that we might ask you to complete for research purposes.
- Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.
- To provide you with customer support or service offerings, including responding to and resolving your inquiries and requests via email or WhatsApp.
Cookies & technical data
Tribbe collects information as visitors and users browse and interact with the website and/or the Tribbe App.
When you visit our website, we may place a cookie on your browser so that our system can recognize you when you make a return visit. Third parties may also place cookies on your browser for targeted advertising purposes. That cookie allows us to recognize your browser on a return visit. We do not otherwise collect or process data when you are a visitor.
Opting out of Cookies
There are a number ways to limit the cookies that your browser accepts or limit the way in which they’re used.
One way to limit cookies is by opting out of third party cookies/advertising networks, like Google Analytics and the Digital Advertising Alliance. Some people use what are called “Ad Blockers” to limit advertising/tracking. We don’t endorse any particular Ad Blocker, but want you to know that it’s an option since you’re reading this and are likely quite privacy-minded.
Opting out of cookies using the above methods likely won’t cause problems with our services per se, but it makes it harder for us to spend our advertising budget effectively. We we will not know how you discovered Tribbe and or if you are a Tribbe App user. Depending on the services you block, it might also make it harder for us to know how you’re using the Tribbe App, or know if you’re running into problems.
Another way of limiting cookies is by controlling cookies in your web browser’s settings. (Disabling cookies in this way is more likely to actually break or worsen the experience when using some of our services). Here are instructions for the most common browsers:
- Google Chrome
- Internet Explorer
- Microsoft Edge
- Mozilla Firefox
- Safari (Desktop)
- Safari (Mobile)
- Android Browser
Recipients of personal data
We do NOT sell users’ data.
- To contractors, service providers, and other third parties we use to support our business, in particular providing infrastructure, insight synthesis and analytics services, and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
- With respect to aggregating your banking and other financial accounts, you or we will transmit your account credentials to third-party aggregation partners, who will use them to link, gather and maintain your account balances, transactions, and holdings used to provide our services. This is a supplement to our own protocol we built to capture and organize MPESA/AIRTEL MONEY transaction information by scraping the SMS receipts of your device.
- Our primary transaction aggregation service partner is UTU (https://utu.io). You acknowledge and agree to the terms of their work process, and you expressly them as a grant aggregation partner the right, power, and authority to access and transmit your information as reasonably necessary to provide the Services to you.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.
- To fulfill the purpose for which you provide it.
- In aggregated form, and/or information that does not identify any individual.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may also disclose your personal information:
- To comply with any court order, law or legal process, including to respond to any government or regulatory request.
- To enforce or apply our Terms of Service or terms of sale and other agreements, including for billing and collection purposes.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Tribbe, our users or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Categories of third-party providers
Categories of services used to process data include:
Infrastructure & Fulfillment
Tribbe partners with third-parties to provide storage and server access that acts as infrastructure for our website and apps. In addition, we partner with third-parties to fulfill payments and transactions in fulfillment of our terms.
Tribbe partners with third-parties to aggregate financial information from your financial institutions when you enable this functionality in Settings in your Tribbe App.
Tribbe partners with third-parties to help us monitor and analyze website traffic and can be used to keep track of user behavior, helping us to improve the services and experience of using them.
Performance and Logging
Tribbe partners with third-parties that assist us in monitoring the stability of the website and Tribbe App and resolving issues or errors with the service.
Tribbe partners with third-parties to manage receipt of consent to send marketing emails and sending those same emails.
We delete all account data related to your account after a period of time in the event that you elect to delete your Tribbe account from within your Tribbe App.
Once an account has become inactive beyond the period of time described below, we will delete its data and send the money in the Tribbe account back to the registered phone number within 30-60 days.
We will delete accounts and their data a minimum of three years after the expiration of the subscription.
After deletion, we retain your email address in order to be able to confirm deletion of associated data.
Children under the age of 18
In accordance with Kenyan law, our Website is not intended for children under 18 years of age. No one under 18 may provide any personal information to the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website, download the Tribbe App, register for an account on the Website, or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at firstname.lastname@example.org.
We have established a number of procedures to help you manage your personal data.
You may delete your account by visiting your account settings in the Tribbe App. This will delete all personal data with the exception of email correspondence. Note that the process to delete all data associated with your account will take up to thirty (30) days, with log files retained for up to eighteen (18) months.
Adjust Notification and Email Preferences
Updating Account Information
You may correct, amend, or update your email and/or password at any time by adjusting that information in the Settings tab of your Tribbe App. You may cease aggregation of transactions from your financial institutions in addition to our proprietary protocol for capturing MPESA/ AIRTEL Money transaction data at any time through the individual account settings in the Tribbe App.
Object, Restrict, or Withdraw Consent
You may withdraw consent for processing in the situations described above. Other data processing we conduct is necessary for the fulfillment of our Terms of Service and/or our legitimate interest and/or legal reasons, and deletion of your account and data is required to cease processing.
Universal privacy rights and use of data with consumer retail partners
Tribbe does not transfer information to third parties for direct marketing purposes. In the event we decided to do so in the future, we would provide affirmative consent and opt-out procedures. That said, one of Tribbe’s fundamental value-add services to users is finding deals related to a person’s spending patterns, and delivering these as advertisements on your Tribbe App for you to take advantage of. When doing this, we get the information about such deals from our partners and own the identification of which users to present which deals to, then delivering the advertisements to them. We do not disclose your any identifiable information about you to advertising partners for any reason.
The Services offered by Tribbe are operated from Kenya. If you are located outside of Kenya and choose to use the Services or provide information to us, you acknowledge and understand that your information will be transferred, processed, and stored in Kenya, as it is necessary to provide the Services and perform the Terms of Service.