Privacy Policy

Last updated: January 2025

1. Introduction

Welcome to siscom.africa ("we", "us", "our"). respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our digital infrastructure investment platform.

2. Information We Collect

2.1 Personal Information

We collect personal information that you voluntarily provide to us when you:

  • Register for an account
  • Make an investment
  • Contact customer support
  • Subscribe to our newsletter
  • Complete KYC verification

2.2 Types of Personal Data

  • Identity Information: Name, date of birth, nationality, government ID
  • Contact Information: Email address, phone number, postal address
  • Financial Information: Bank account details, investment amounts, transaction history
  • Technical Information: IP address, browser type, device information, usage data
  • KYC Documents: ID copies, proof of address, financial statements

2.3 Automatically Collected Information

We automatically collect certain information when you visit our platform:

  • Log data (IP addresses, browser type, pages visited)
  • Device information (device type, operating system)
  • Usage analytics (time spent, features used)
  • Cookies and tracking technologies

3. How We Use Your Information

We use your information for the following purposes:

  • Account Management: Creating and managing your account
  • Investment Processing: Processing investments and distributing returns
  • KYC Compliance: Verifying your identity and meeting regulatory requirements
  • Customer Support: Responding to inquiries and providing assistance
  • Communication: Sending investment updates, newsletters, and important notices
  • Platform Improvement: Analyzing usage to improve our services
  • Security: Detecting and preventing fraud and security threats
  • Legal Compliance: Meeting legal and regulatory obligations

4. Legal Basis for Processing

We process your personal information based on:

  • Contractual Necessity: To fulfill our investment services contract
  • Legal Obligation: To comply with KYC, AML, and other regulatory requirements
  • Legitimate Interest: To operate and improve our platform
  • Consent: For marketing communications and cookies (where required)

5. Information Sharing and Disclosure

5.1 We May Share Information With:

  • Service Providers: Payment processors, KYC verification services, cloud storage providers
  • Financial Partners: Banks and financial institutions for payment processing
  • Legal Authorities: When required by law or to protect our rights
  • Business Transfers: In case of merger, acquisition, or sale of assets

5.2 We Do Not:

  • Sell personal information to third parties
  • Share information for marketing purposes without consent
  • Transfer data outside Kenya without appropriate safeguards

6. Data Security

We implement appropriate technical and organizational measures to protect your information:

  • Encryption: All data transmission is encrypted using SSL/TLS
  • Access Controls: Limited access to personal information on a need-to-know basis
  • Regular Audits: Security assessments and vulnerability testing
  • Secure Storage: Data stored in secure, access-controlled environments
  • Staff Training: Regular privacy and security training for all employees

7. Data Retention

We retain your personal information for as long as necessary to:

  • Provide our investment services
  • Comply with legal and regulatory requirements
  • Resolve disputes and enforce agreements

Specific Retention Periods:

  • Account information: Duration of account plus 7 years
  • Transaction records: 7 years after transaction
  • KYC documents: 5 years after account closure
  • Marketing data: Until consent is withdrawn

8. Your Rights

Under Kenyan data protection laws, you have the right to:

  • Access: Request copies of your personal information
  • Rectification: Request correction of inaccurate information
  • Erasure: Request deletion of your information (subject to legal requirements)
  • Restriction: Request limitation of processing
  • Portability: Request transfer of your data
  • Objection: Object to processing based on legitimate interests
  • Withdraw Consent: Withdraw consent for marketing communications

To exercise these rights, contact us at privacy@siscom.africa

9. Cookies and Tracking

9.1 Types of Cookies We Use:

  • Essential Cookies: Required for platform functionality
  • Performance Cookies: Help us understand platform usage
  • Functional Cookies: Remember your preferences
  • Marketing Cookies: Deliver relevant advertisements

9.2 Managing Cookies

You can control cookies through your browser settings. Disabling certain cookies may affect platform functionality.

10. International Transfers

Your information is primarily processed and stored in Kenya. If we transfer data internationally, we ensure appropriate safeguards are in place, including:

  • Adequacy decisions by relevant authorities
  • Standard contractual clauses
  • Binding corporate rules

11. Children's Privacy

Our platform is not intended for individuals under 18 years of age. We do not knowingly collect personal information from children under 18.

12. Changes to This Privacy Policy

We may update this Privacy Policy periodically. We will notify you of material changes by:

  • Posting the updated policy on our platform
  • Sending email notifications for significant changes
  • Updating the "Last updated" date

13. Contact Information

For privacy-related questions or concerns, contact us:

Data Protection Officer
Email: invest@siscom.africa
Phone: 0745 666 660

Complaints

If you believe we have not handled your personal information properly, you may lodge a complaint with the Office of the Data Protection Commissioner (Kenya).