Privacy Policy
Effective date: Jan 1st, 2020
Wana-anga Sacco Ltd (“us”, “we”, or “our”) operates the website and the
Wana-anga mobile application (hereinafter referred to as the “Service”).
This page informs you of our policies regarding the collection, use and disclosure of personal
data when you use our Service and the choices you have associated with that data.
We use your data to provide and improve the Service. By using the Service, you agree to the
collection and use of information in accordance with this policy. Unless otherwise defined in this
Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms
and Conditions.
• Service
Service means the website and the Wana-anga mobile application
operated by Wana-anga Sacco Ltd
• Personal Data
Personal Data means data about a living individual who can be identified from those data
(or from those and other information either in our possession or likely to come into our
• Usage Data
Usage Data is data collected automatically either generated by the use of the Service or
from the Service infrastructure itself (for example, the duration of a page visit).
• Cookies
Cookies are small files stored on your device (computer or mobile device).
• Data Controller
Data Controller means the natural or legal person who (either alone or jointly or in
common with other persons) determines the purposes for which and the manner in which
any personal information are, or are to be, processed.
For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.
• Data Processors (or Service Providers)
Data Processor (or Service Provider) means any natural or legal person who processes the
data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process your data more
• Data Subject (or User)
Data Subject is any living individual who is using our Service and is the subject of
Personal Data.
Information Collection and Use
We collect several different types of information for various purposes to provide and improve
our Service to you.
Types of Data Collected
Personal Data
While using our Service, we may ask you to provide us with certain personally identifiable
information that can be used to contact or identify you (“Personal Data”). Personally identifiable
information may include, but is not limited to:
• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Cookies and Usage Data
We may use your Personal Data to contact you with newsletters, marketing or promotional
materials and other information that may be of interest to you. You may opt out of receiving any,
or all, of these communications from us by following the unsubscribe link or the instructions
provided in any email we send.
Usage Data
We may also collect information that your browser sends whenever you visit our Service or
when you access the Service by or through a mobile device (“Usage Data”).
This Usage Data may include information such as your computer’s Internet Protocol address (e.g.
IP address), browser type, browser version, the pages of our Service that you visit, the time and
date of your visit, the time spent on those pages, unique device identifiers and other diagnostic
When you access the Service with a mobile device, this Usage Data may include information
such as the type of mobile device you use, your mobile device unique ID, the IP address of your
mobile device, your mobile operating system, the type of mobile Internet browser you use,
unique device identifiers and other diagnostic data.
Location Data
We may use and store information about your location if you give us permission to do so. We
use this data to provide features of our Service, to improve and customize our Service.
You can enable or disable location services when you use our Service at any time by way of your
device settings.
Tracking & Cookies Data
We use cookies and similar tracking technologies to track the activity on our Service and we
hold certain information.
Cookies are files with a small amount of data which may include an anonymous unique
identifier. Cookies are sent to your browser from a website and stored on your device. Other
tracking technologies are also used such as beacons, tags and scripts to collect and track
information and to improve and analyse our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent.
However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
• Session Cookies. We use Session Cookies to operate our Service.
• Preference Cookies. We use Preference Cookies to remember your preferences and
various settings.
• Security Cookies. We use Security Cookies for security purposes.
Use of Data
Wana-anga Sacco Ltd uses the collected data for various purposes:
• To provide and maintain our Service
• To notify you about changes to our Service
• To allow you to participate in interactive features of our Service when you choose to do
• To provide customer support
• To gather analysis or valuable information so that we can improve our Service
• To monitor the usage of our Service
• To detect, prevent and address technical issues
• To provide you with news, special offers and general information about other goods,
services and events which we offer that are similar to those that you have already
purchased or inquired about unless you have opted not to receive such information
Legal Basis for Processing Personal Data under the General
Data Protection Regulation (GDPR)
If you are from the European Economic Area (EEA), Wana-anga Sacco Ltd legal basis for
collecting and using the personal information described in this Privacy Policy depends on the
Personal Data we collect and the specific context in which we collect it.
Wana-anga Sacco Ltd may process your Personal Data because:
• We need to perform a contract with you
• You have given us permission to do so
• The processing is in our legitimate interests and it is not overridden by your rights
• To comply with the law
Retention of Data
Wana-anga Sacco Ltd will retain your Personal Data only for as long as is necessary for the
purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent
necessary to comply with our legal obligations (for example, if we are required to retain your
data to comply with applicable laws), resolve disputes and enforce our legal agreements and
Wana-anga Sacco Ltd will also retain Usage Data for internal analysis purposes. Usage Data is
generally retained for a shorter period of time, except when this data is used to strengthen the
security or to improve the functionality of our Service, or we are legally obligated to retain this
data for longer periods.
Transfer of Data
Your information, including Personal Data, may be transferred to us and maintained on our
computers located outside of your state, province, country or other governmental jurisdiction
where the data protection laws may differ from those of your jurisdiction.
If you are located outside KENYA and choose to provide information to us, please note that we
transfer the data, including Personal Data, to KENYA and process it there.
Your consent to this Privacy Policy followed by your submission of such information represents
your agreement to that transfer.
Wana-anga Sacco Ltd will take all the steps reasonably necessary to ensure that your data is
treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data
will take place to an organisation or a country unless there are adequate controls in place
including the security of your data and other personal information.
Disclosure of Data
Business Transaction
If Wana-anga Sacco Ltd is involved in a merger, acquisition or asset sale, your Personal Data
may be transferred. We will provide notice before your Personal Data is transferred and becomes
subject to a different Privacy Policy.
Disclosure for Law Enforcement
Under certain circumstances, Wana-anga Sacco Ltd may be required to disclose your Personal
Data if required to do so by law or in response to valid requests by public authorities (e.g. a court
or a government agency).
Legal Requirements
Wana-anga Sacco Ltd may disclose your Personal Data in the good faith belief that such action is
necessary to:
• To comply with a legal obligation
• To protect and defend the rights or property of Wana-anga Sacco Ltd
• To prevent or investigate possible wrongdoing in connection with the Service
• To protect the personal safety of users of the Service or the public
• To protect against legal liability
Security of Data
The security of your data is important to us but remember that no method of transmission over
the Internet or method of electronic storage is 100% secure. While we strive to use commercially
acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Our Policy on “Do Not Track” Signals under the California
Online Protection Act (CalOPPA)
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web
browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web
Your Data Protection Rights under the General Data
Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection
rights. Wana-anga Sacco Ltd aims to take reasonable steps to allow you to correct, amend, delete
or limit the use of your Personal Data.
If you wish to be informed about what Personal Data we hold about you and if you want it to be
removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
• The right to access, update or delete the information we have on you. Whenever
made possible, you can access, update or request deletion of your Personal Data directly
within your account settings section. If you are unable to perform these actions yourself,
please contact us to assist you.
• The right of rectification. You have the right to have your information rectified if that
information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your Personal
• The right of restriction. You have the right to request that we restrict the processing of
your personal information.
• The right to data portability. You have the right to be provided with a copy of the
information we have on you in a structured, machine-readable and commonly used
• The right to withdraw consent. You also have the right to withdraw your consent at any
time where Wana-anga Sacco Ltd relied on your consent to process your personal
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of
your Personal Data. For more information, please contact your local data protection authority in
the European Economic Area (EEA).
Service Providers
We may employ third party companies and individuals to facilitate our Service (“Service
Providers”), provide the Service on our behalf, perform Service-related services or assist us in
analysing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf
and are obligated not to disclose or use it for any other purpose.
We may use third-party Service Providers to monitor and analyse the use of our Service.
• Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports
website traffic. Google uses the data collected to track and monitor the use of our
Service. This data is shared with other Google services. Google may use the collected
data to contextualise and personalise the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy
& Terms web page:
Behavioral Remarketing
Wana-anga Sacco Ltd uses remarketing services to advertise on third party websites to you after
you visited our Service. We and our third-party vendors use cookies to inform, optimise and
serve ads based on your past visits to our Service.
• Google AdWords
Google AdWords remarketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customise the Google
Display Network ads by visiting the Google Ads Settings
Google also recommends installing the Google Analytics Opt-out Browser Add-on – – for your web browser. Google Analytics Opt-
out Browser Add-on provides visitors with the ability to prevent their data from being
collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy
& Terms web page:
• X (Formerly Twitter)
Twitter remarketing service is provided by Twitter Inc.
You can opt-out from Twitter’s interest-based ads by following their
You can learn more about the privacy practices and policies of Twitter by visiting their
Privacy Policy page:
• Facebook
Facebook remarketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this
To opt-out from Facebook’s interest-based ads, follow these instructions from
Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising
established by the Digital Advertising Alliance. You can also opt-out from Facebook and
other participating companies through the Digital Advertising Alliance in the
USA, the Digital Advertising Alliance of Canada in
Canada or the European Interactive Digital Advertising Alliance
in Europe, or opt-out using your mobile device
For more information on the privacy practices of Facebook, please visit Facebook’s Data
• AdRoll
AdRoll remarketing service is provided by Semantic Sugar, Inc.
You can opt-out of AdRoll remarketing by visiting this AdRoll Advertising Preferences
web page:
For more information on the privacy practices of AdRoll, please visit the AdRoll Privacy
Policy web page:
Links to Other Sites
Our Service may contain links to other sites that are not operated by us. If you click a third party
link, you will be directed to that third party’s site. We strongly advise you to review the Privacy
Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or
practices of any third party sites or services.
Children’s Privacy
Our Service does not address anyone under the age of 18 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of
18. If you are a parent or guardian and you are aware that your Child has provided us with
Personal Data, please contact us. If we become aware that we have collected Personal Data from
children without verification of parental consent, we take steps to remove that information from
our servers.
Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by
posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our Service, prior to the change
becoming effective and update the “effective date” at the top of this Privacy Policy. Changes to this
Privacy Policy are effective when they are posted on this page.
Contact Us
If you have any questions about this Privacy Policy, please contact us:
• By email:
• By visiting this page on our website:
• By phone number: +254712710117
• By mail: P.O Box 34680-00100 Nairobi Kenya