1. Introduction
Overview. This Privacy Policy explains how FinoQ Africa (“FinoQ”, “we”, “us” or “our”) collects, uses, discloses and protects personal information when you use the FinoQ app, website and services. FinoQ does not hold customer funds or operate wallets. Wallets, sub-wallets and accounts are provided and held by licensed partner banks and Fintech-as-a-Service (FaaS) providers. You open these partner-managed wallets through FinoQ, which integrates with the partners so you can use them from one app.
Consent. By using FinoQ, you consent to the practices described in this Policy, including sharing your details with partner institutions to open accounts and sub-wallets for you (Section 4).
2. Information Collection
Personal Information. We collect personal data such as your name, date of birth, contact details, identification documents (national ID or passport, KRA PIN), selfie or liveness check, and financial information such as linked accounts, source of funds and transaction history.
Usage Data. We also gather information on how you access and use the app, including device identifiers, IP addresses, location where permitted, and usage statistics.
3. Use of Data
Service Provision. We process your data to verify your identity, request and manage the wallets and sub-wallets our partners provide for you, handle transactions through those partners, and provide customer support.
Account Opening with Partners. We use your data to have licensed partner banks and FaaS providers open bank accounts, sub-accounts or sub-wallets in your name or for your benefit.
Improvement of Services. We analyse data, in aggregated or de-identified form where possible, to improve app performance and user experience.
Legal Compliance. We comply with the Kenya Data Protection Act, 2019 and use data as necessary to meet KYC, Anti-Money Laundering (AML), counter-terrorism financing and Central Bank of Kenya requirements. We do not sell your personal data.
4. Data Sharing and Disclosure
Partner Banks and FaaS Providers. Your wallet is provided by a licensed partner, so to give you one we share your identity details, KYC documents, contact details and screening results with licensed partner banks and Fintech-as-a-Service providers. They use this data to open a bank account, sub-account or sub-wallet in your name or for your benefit, to run their own KYC and AML checks, and to process your transactions. Each partner processes your data under its own regulatory obligations and privacy policy. If you do not consent to this sharing, we cannot open a wallet for you.
Service Providers. We share data with third parties who help with identity verification, payment processing, hosting, messaging and other operational tasks. They may only use the data according to our instructions.
Legal Requirements. By using FinoQ, you expressly consent that we may disclose transactional data to law enforcement, regulatory agencies or AML authorities, including the Financial Reporting Centre, for investigations. This consent can be withdrawn by written notice, unless overriding legal obligations require disclosure.
Business Transfers. In the event of a merger, acquisition or asset sale, user information may be transferred under confidentiality commitments consistent with this Policy.
5. Data Security
Security Measures. We use robust security measures such as encryption in transit and at rest, secure servers and access controls to protect data from unauthorised access or disclosure.
Data Breach Notification. We will notify affected users and the Office of the Data Protection Commissioner of any data breach, as required by Kenyan law.
6. Data Subject Rights
Access and Control. You may request to access, correct or delete your personal data, or object to its processing, subject to legal or contractual restrictions such as AML record-keeping.
Withdrawing Consent. You may withdraw consent at any time. Withdrawing consent to partner sharing means we cannot keep your wallet open.
Data Portability. Where feasible, you can request a copy of your data in a machine-readable format.
7. International Data Transfers
Personal data may be transferred outside Kenya to partners and service providers. We ensure that receiving entities maintain adequate data protection standards, consistent with the Kenya Data Protection Act.
8. Children’s Privacy
We do not knowingly collect personal data from individuals under the age of 18. If you believe your child has provided us with personal information, please contact us immediately.
9. Changes to This Privacy Policy
We may update this Policy at any time. Any significant changes will be communicated through the app or by email, as required by law.
10. Contact Information
For questions or concerns about data privacy, please email us at info@finoq.africa.