Taswira, an analytic and personal finance management application brought to you by Spin Mobile Limited and its affiliates (referred to in this policy as "we", "us", or "our"), is committed to maintaining the trust of our Clients and Customers. Please read this policy (the "Privacy Policy") carefully to learn more about our privacy practices and policies with respect to Consumer Data (defined below) that is collected and/or processed through our Internet application (the "Web App"), or administrative interface (collectively the "Service"), or engage with us in other related ways, including any communication, sales, marketing, or events.
For the purposes of this Privacy Policy:
This Privacy Policy applies to "Personal Data" of a Consumer, which is Data that is associated with an identified or identifiable natural person and is protected as personal data or personal information under applicable data protection law.
By using the Services, you signify your acceptance of this Privacy Policy. If you do not agree or are not comfortable with any policy described in this Privacy Policy, your only remedy is to discontinue use of the Services.
We may, as Data Processors, be contracted by a Client, acting as Data Controller, to provide the Services to their Consumers, in which case this Policy will apply with necessary modifications. In such case, the Client is responsible:
We collect personal information that you voluntarily provide to us when you register for the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use.
The personal information we collect may include the following:
When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
We may collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include Device and usage information, such as your IP address, browser and Device characteristics, operating system, language preferences, referring URLs, Device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through Cookies and similar technologies. You can find out more about this in our Cookie Notice: https://www.spinmobile.co/privacy-policy/
In order to enhance our ability to provide the Services, relevant marketing and offers, and update our records, we may obtain information about you from other sources, such as credit bureaus, affiliates, or other companies, public databases, joint marketing partners, affiliate programs, data providers, and from other third parties.
This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs, spending habits, and custom profiles.
We use your Personal Data to provide the Services to you pursuant to the applicable terms and conditions and in accordance with Data Protection Laws. We collect, process, and store your personal information for a variety of reasons, depending on how you interact with our Services, including:
We may need to share your personal information in the following situations:
We will, to the extent required by Data Protection Laws and the applicable contract, obtain assurances before disclosing Personal Data to a subcontractor or third-party agent that the recipient will:
Upon notice, we will act promptly to stop and remediate any unauthorized processing of Personal Data by the recipient. We will remain liable for onward transfers to subcontractors and third-party agents.
We may use Cookies and similar tracking technologies to access or store information. Specific information about how we use such technologies and how you can refuse certain Cookies is set out in our Cookie Notice: www.spinmobile.co/cookies.
Your Personal Data may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information in other countries in accordance with the Data Protection Laws. We will take all necessary measures to protect your Personal Data in accordance with this privacy notice and Data Protection Laws.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than the period of time in which users have an Account with us.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), we will securely store your personal information and isolate it from any further processing until deletion is possible.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the Account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at info@spinmobile.co.ke.
Our website may include links to other websites. Please note we are not responsible for the content or privacy practices of these external sites. We encourage you to exercise caution when leaving our website and to review the privacy statements of any site that collects personally identifiable information.
Occasionally, our site may request information through surveys or contests. Participation in these activities is entirely voluntary, and you can choose whether or not to disclose your information. The requested information may include contact details and demographic information. Contact details will be used to notify winners and award prizes, while survey information will be utilized to monitor and enhance the Services.
a) Withdrawing your consent
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent by contacting us using the contact details provided in Section 15 below. However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
b) Opting out of marketing and promotional communications
You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails we send, or by contacting us using the details provided in Section 15 below. You will then be removed from the marketing lists. However, we may still communicate with you—for example, to send you service-related messages that are necessary for the administration and use of your Account, to respond to service requests, or for other non-marketing purposes.
c) Account Information
If you would like to review or change the information in your Account or terminate your Account, you can log in to your Account settings and update your user Account.
Upon your request to terminate your Account, we will deactivate or delete your Account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms, and/or comply with applicable legal requirements.
You understand that we have a legitimate and protected interest in the development of our system used for crunching and automated analytics of the data we receive from you. This interest extends to the manner in which we have reproduced, arranged, and presented your data at the conclusion of the crunching process. The resultant data is then anonymized and becomes proprietary to us, granting the exclusive right to it for historical, scientific, and statistical purposes. This usage may extend to both state and non-state actors in policy development and enterprise, all aimed at the betterment of society.
d) Cookies and similar technologies:
Most Web browsers are set to accept Cookies by default. If you prefer, you can usually choose to set your browser to remove Cookies and to reject Cookies. If you choose to remove Cookies or reject Cookies, this could affect certain features of the Services.
If you have questions or comments about your privacy rights, you may email us at info@spinmobile.co.ke.
We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date, and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to stay informed of how we are protecting your information.
We prioritize openness, transparency, and accountability. If you ever have concerns about our policies, terms, or the delivery of our services, we have a thorough mechanism in place to address them once you bring them to our attention. We actively encourage our Clients and Consumers to engage with us and continue doing so.
Our commitment to providing you with the best possible experience led us to intentionally establish a dispute resolution mechanism. This allows us to enhance our Services, ensuring value for your money and time. We pledge not to let you down and to adhere to the principles of natural justice, in accordance with alternative dispute resolution methods outlined in the law.
We ask that you commit to utilizing alternative dispute resolution mechanisms before initiating any formal dispute resolution processes. This approach enhances the effectiveness of our Service delivery and helps protect sensitive information handled by all parties from unnecessary exposure to third parties.
Spin Mobile Limited
2nd Floor, Block C, Cassia Court Complex, Kiambere Road, Upperhill Nairobi
Office Tel: +254 723 81 55 86
P.O. Box 56013 - 00200 | Kenya
Email: info@spinmobile.co
Effective Date: 30th November 2023
This Cookies Policy explains what Cookies are and how "we" use them. You should read this policy so you can understand what type of Cookies "we" use, the information "we" collect using Cookies, and how that information is used.
Cookies do not typically contain any information that personally identifies a user, but personal information that "we" store about you may be linked to the information stored in and obtained from Cookies. For further information on how "we" use, store, and keep your personal data secure, see our Privacy Policy.
"We" do not store sensitive personal information, such as mailing addresses, Account passwords, etc., in the Cookies "we" use.
a) Interpretation
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
b) Definitions
For the purposes of this Cookies Policy:
Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on your personal computer or mobile Device when you go offline, while Session Cookies are deleted as soon as you close your web browser.
"We" use both session and persistent Cookies for the purposes set out below:
a) Necessary / Essential Cookies
Type: Session Cookies
Administered by: "Us"
Purpose: These Cookies are essential to provide you with services available through the Website and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that you have asked for cannot be provided, and "we" only use these Cookies to provide you with those services.
b) Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: "Us"
Purpose: These Cookies identify if users have accepted the use of Cookies on the Website.
c) Functionality Cookies
Type: Persistent Cookies
Administered by: "Us"
Purpose: These Cookies allow us to remember choices you make when you use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use the Website.
d) Tracking and Performance Cookies
Type: Persistent Cookies
Administered by: Third-Parties
Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the Device you use to access the Website. "We" may also use these Cookies to test new advertisements, pages, features, or new functionality of the Website to see how our users react to them.
If you prefer to avoid the use of Cookies on the Website, you must first disable the use of Cookies in your browser and then delete the Cookies saved in your browser associated with this website. You may use this option for preventing the use of Cookies at any time.
If you do not accept "our" Cookies, you may experience some inconvenience in your use of the Website, and some features may not function properly.
If you'd like to delete Cookies or instruct your web browser to delete or refuse Cookies, please visit the help pages of your web browser:
If you have any questions or concerns about this Policy, you can contact us:
Spin Mobile Limited