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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, 2nd 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
  2. What we use personal information for
  3. 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
  6. Who we share personal information with
  7. Where we store and send personal information
  8. Your rights concerning your personal information
  9. Whom can you complain to if you are unhappy about the use of your personal information?

Introduction

This privacy notice provides information about how we use and share personal information relating to consumers who contact us with an enquiry, request or complaint.

 

In Brief

When you contact us with a request, complaint or enquiry, we will use your personal data in order to help us to respond to you.

Sometimes this will mean sharing personal information with third parties. For example, if you dispute the accuracy of information on your credit report, we may need to contact the organisation who provided us with that information to check whether it’s correct.

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, personalised products and services online. However, the currency of personal data that fuels this platform economic boom poses threats to individuals and endangers corporate 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 makes trust possible in modern commerce. We do this by curating a robust and actionable picture of each consumer so they are 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’re a company with registered offices at Delta Corner Annex, 2nd Floor, Ring Road, Westlands, Nairobi. Although we’re part of a larger group, this notice covers only the activities of TransUnion within the Republic of Kenya.

Contact details

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

2. What we use personal information for

Enquiries

We use your personal information to deal with any issue or complaint you’ve raised (which we refer to as an “enquiry”). This might include contacting you for more information or to tell you the outcome of your enquiry. Typical enquiries include:

  • Requests for access to personal information; to challenge the accuracy of personal data; or to request the erasure of personal information
  • Support requests for our consumer products
  • Complaints of any nature
  • General enquiries

Identity verification

When you contact us, we may need to verify your identity to ensure we do not provide personal information to unauthorised parties.

 

Example: Identity verification

If someone contacts us and asks us for a copy of your credit report, we’ll check it’s you (or someone authorised by you) asking for it. We may ask for evidence of identity, such as copies of your driver’s license or a bank statement.

It’s important to do this because the information in your credit report is valuable and could be used to impersonate you if it were to fall into the wrong hands.

Feedback

We may ask you to provide us with feedback or to leave a review about the service you received. Your feedback helps us improve our services.

Products and services

We use aggregated statistics about enquiries, requests and complaints to help manage our services and identify potential problems. Some enquiries lead to changes to the personal information we use in our products and services.

Constant improvement

We use information from complaints and requests to help understand what went wrong, fix any problems, and improve how we deal with similar issues.

Legal and regulatory purposes

We may use personal information for legal and regulatory purposes. This might include responding to complaints or enquiries from you or a regulator about how we’ve handled your enquiry or used your personal information.

3. Kinds of personal information we use and where we get it

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

Type of Information

Description

Source

Basic contact information:

Name, email address and phone number.

You provide this information when you make an enquiry or when we subsequently request it.

Your enquiry:

Any enquiry you make.

Proof of identity or authority and other supporting documentation:

If you enquire on someone else’s behalf, we may ask for proof of authority, such as a power of attorney. Sometimes we may require additional supporting documentation.

Information gathered in dealing with your enquiry:

Dealing with an enquiry involves investigating the circumstances. This type of information depends on the enquiry.

Internal records and external organisations, such as clients and suppliers.

Our response and other correspondence:

Our response, along with other correspondence relating to your enquiry.

We produce these ourselves.

Website usage:

If you access or submit information through our website, we record information, such as IP address, operating system and browser type.

We gather this through the website.

You’re free to choose whether you give us your personal information. However, if you don’t provide the information we need, this may limit our ability to help.

4. How long we keep personal information

We keep your personal information during the enquiry and for an additional period after completion. That period depends on purposes, such as:

  • Showing we have processes to deal with enquiries and are doing so fairly under our regulatory requirements
  • Responding to you or a regulator to show we dealt with an enquiry properly
  • Defending legal claims or regulatory action that might arise because of the enquiry

5. Our legal basis for handling personal information

Legitimate interests

The Data Protection Act No. 24 of 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.

 

Interest

Explanation

Security

To keep your personal information secure.

Reputation and service improvement

To manage enquiries quickly and efficiently to build our business reputation.

6. Who we share personal information with

Service providers

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

Data suppliers and other third parties

If your enquiry is about data supplied to us by third parties, we might provide them with your personal information to help manage your enquiry. For example, if you dispute the accuracy of an entry on your credit file, we may contact the provider of that information to check its validity.

These service providers can’t use your information for their purposes or on behalf of other organisations unless you agree otherwise.

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 in Kenya.

8. Your rights concerning your personal information

To enquire about exercising these rights, please contact the TransUnion Contact Centre on: +254 768262495, +254 768617074, +254 768253748¬, +254 706565285

Access: You have a right to find out whether we hold personal information about you and what personal information we hold about you. Please contact us via info@transunion.com or DPO_KE@transunion.com for inquiries on how to access your information

Correction/Destruction/Deletion: If the information we hold about you is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained unlawfully, you have a right to ask us to correct it or delete it.

Objection to processing your personal information: You may object on reasonable grounds relating to processing your personal information as provided in terms of Sec.36 of the Data Protection Act No. 24 of 2019 unless legislation provides for such processing.

Objection to direct marketing: You may object to us using your personal information for direct marketing. If you do, we will stop using it for those purposes.

9. Whom can you complain to if you’re unhappy about the use of your personal information?

We try to ensure we deliver the best levels of customer service, but if you’re not happy, you should contact us so we can investigate your concerns. You may do so using these details:

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

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

You have the right to complain to the Information Regulator:

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