TransUnion Kenya

Last revised: 22 September 2022 

Version 1.0 

© 2022 TransUnion LLC
All Rights Reserved

No part of this publication may be reproduced or distributed in any form or by any means, electronic or otherwise, now known or hereafter developed, including, but not limited to, the Internet, without the express written permission of TransUnion. This document is protected by U.S. and International copyright laws. This document and the subject matter contained herein is TransUnion proprietary and confidential information, and may not be shared or used for any purposes other than the purpose for which it was provided by TransUnion, without the express written permission of TransUnion. By using this document, you are agreeing that you will not attempt, directly or indirectly, to reverse engineer, decompile, or disassemble any TransUnion services or service information, any confidential or proprietary criteria developed or used by TransUnion relating to services you receive from TransUnion, or any of the TransUnion confidential and proprietary information contained herein. The entire right, title and interest in and to this document and TransUnion services, and all copyrights, patents, trade secrets, trademarks, trade names, and all other intellectual property rights associated with any and all ideas, concepts, techniques, inventions, processes, or works of authorship including, but not limited to, all materials in written or other tangible form developed or created by TransUnion, shall at all times vest exclusively in TransUnion. You acknowledge that any misuse, misappropriation or threatened misappropriation of TransUnion’s intellectual property rights, or any breach or threatened breach of the foregoing restrictions, may cause immediate and irreparable injury to TransUnion, and in such event, TransUnion shall be entitled to seek injunctive relief. Nothing stated herein will be construed to limit any other remedies available to TransUnion including, but not limited to suspension and/or termination of the services provided to you.

Requests for permission to reproduce or distribute any part of, or all of, this publication should be mailed to:

Law Department
TransUnion
Delta Corner Annex, 2^nd Floor, Ring Road,
Westlands, Nairobi.

The “tu” logo, TransUnion, and other trademarks, service marks, and logos (the “Trademarks”) used in this publication are registered or unregistered Trademarks of TransUnion LLC or their respective owners. Trademarks may not be used for any purpose whatsoever without the express written permission of the Trademark owner.

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Table of contents

Introduction

1. Who we are and how to contact us
   • Information for Good^®
   • Jointly responsible parties
2. What we use personal information for
   • Operating our products and administering accounts.
   • Security and breach reporting.
   • Feedback to clients.
   • Monitoring and improving our products
   • Product or systems development and testing
   • Providing technical support and responding to queries
3. The kinds of personal information we use and where we get it
4. How long we keep personal information
5. Our legal basis for handling personal information
   • Legitimate interests
6. Who we share personal information with
   • Clients
   • Service providers
   • Third-party usage
   • Regulators and law enforcement
7. Where we store and send personal information
8. Your rights concerning your personal information
9. Where to lodge a complaint

Introduction

This privacy notice provides information about how we use and share the personal information of people using our business products and technical support facilities.

1. Who we are and how to contact us

Information for Good^®

We’re in an era of rapid digital transformation where consumers demand more access to seamless, personalized products and services online. However, the existence of personal data that fuels this platform economic boom poses a threat to individuals endangering their information security.

Now more than ever — and likely more so in the future — consumers and corporates need new levels of trust and transparency.

As a global information and insights company, TransUnion seeks to make trust possible in modern commerce. We do this by curating robust and actionable picture of each consumer so they’re reliably represented in the marketplace. This enables businesses and consumers to transact with confidence and achieve great things. We call this Information for Good^®.

We are a company with registered offices at Delta Corner Annex, 2^nd Floor, Ring Road Westlands, Nairobi. Notice covers only the activities of TransUnion within the Republic of Kenya.

Jointly responsible parties

TransUnion companies sometimes cooperate with other TransUnion companies when sharing and making decisions about your personal information. When this happens, all employees across the group ensure each company involved complies with data protection rules.

Contact our Consumer Services Team to enquire about any of our companies or exercise your rights regarding your personal information.

Contact details
Contact us about personal information issues, including the contents of this notice via:

• Post:TransUnion P.O Box 46406-00100 Nairobi
• Telephone:TransUnion Contact Centre: +254 768262495, +254 768617074, +254 768253748­, +254 706565285

2. What we use personal information for

Operating our products and administering accounts

We use personal information to operate our products and administer the accounts of people who use them.

Example

We hold username and password details to control access to products.

Security and breach reporting

We monitor access to our products to ensure only authorised people access our products and data. If we detect suspicious activity, we may suspend an account and investigate.

Feedback to clients

Sometimes we share data with clients (or their affiliates, business partners or group companies) about how their employees use our products. For example, how often and why a staff member uses a product. Clients may ask for this information in deciding whether to continue buying the product, or staff management in checking whether products are being used properly.

If the information shows employee misconduct, an employer might use that information as part of a disciplinary process.

Example

A bank suspects an employee is performing unauthorised credit report searches and asks us for details of the searches conducted by that person. The bank uses this information to support its internal investigation into that employee’s actions.

Monitoring and improving our products

Information, such as how different people use our products, how long they spend on particular tasks and what sort of information they look for, helps us customise and improve our products. We also use this information for security and system administration and to generate non-personalised information for client use.

Product or systems development and testing

We may use personal information while developing or testing our products, systems and security measures. Where possible, we create pseudonyms or otherwise anonymise such data.

Providing technical support and responding to queries

If you contact us with a question about one of our product or services, we use your personal information to provide the answer. This includes contacting you about your request and sometimes about queries raised by other users.
Queries: legal and regulatory purposes

We may also need to use your personal information for legal and regulatory purposes.

Example: Legal and regulatory purposes

If you make a complaint about us to our regulators, they’ll normally ask us to investigate your case. This will involve accessing your personal information. Similarly, if you start court proceedings against us, we’ll normally need to review how we have used your personal information to defend ourselves against your claim.

3. The kinds of personal information we use and where we get it

We obtain and use information from various sources summarised in the following table.

We need your personal information to provide our products correctly. You do not have to provide us with personal information for technical support requests, but this may impede the help we can provide.

4. How long we keep personal information

Simply put, we keep personal information for as long as necessary. More technically, we retain it to fulfil the purpose(s) of its provision, comply with applicable laws, and for as long as your consent to such purpose(s) remains valid after termination of our relationship.

5. Our legal basis for handling personal information

Legitimate interests

The Data Protection Act, 2019 allows personal information usage where necessary for legitimate purposes without undue adverse impact. We base most of our processing activities on the legitimate interests listed below.

6. Who we share personal information with

Clients

As mentioned in Section 2, if asked, we may supply usage information about a TransUnion product to an employer, its affiliates, business partners or group companies.

Service providers

We may provide information to third parties who help us use it for purposes described in Section 2.

Third-party usage

We may use a third-party email broadcasting service to send you service emails. However, unless you agree otherwise, these service providers cannot use your information for their purposes or on behalf of other organisations.

Sometimes we may need to supply information to third parties (such as our service providers or other companies in the TransUnion group) to help deal with a support request or further enquiry.

Regulators and law enforcement

We share personal information with government authorities and law enforcement officials if required by law or for legal protection of our legitimate interests in compliance with applicable laws.

7. Where we store and send personal information

We access and use your information from our base in Kenya. We will not transfer personal information to a country lacking laws that provide an adequate level of information protection — unless we have an agreement with the recipient requiring measures that offer a similar level of protection as the Data Protection Act No. 24 of 2019.

8. Your rights concerning your personal information

Access: You have the right to find out if and what personal information we hold about you. Refer your Data access rights queries to info@transunion.com or DPO_KE@transunion.com

Correction/Destruction/Deletion: If the information we hold about you is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained lawfully, you have a right to ask us to correct it or delete it or have us explore the available dispute resolution mechanism to enable correction or deletion of the same pursuant to Reg. 37 of the Credit Reference Bureau Regulation, 2020.

Objection to processing: You may object (on reasonable grounds) to processing your personal information unless legislation provides for such processing.

Objection to direct marketing: You may object to us using your personal information for direct marketing, and if you do, we will stop.

9. Where to lodge a complaint

We try to deliver the highest levels of customer service. However, if you’re ever unhappy, please contact us so we can investigate.

• Post:PO Box 46406-00100, Nairobi
• Telephone:+254 768262495, +254 768617074, +254 768253748­, +254 706565285

You can also contact our Data Protection Offficer at DPO_KE@transunion.com

You may complain to the Information Regulator:

• Email: info@odpc.go.ke
• Post: P.O Box 30920-00100, Nairobi

Site: https://www.odpc.go.ke/file-a-complaint/