Table of Content
Kamel is an African startup building essential infrastructure to enable social commerce across the Continent. We provide African entrepreneurs with all the tools they need to start, manage, and, grow a retail business of any size. Our mission is to democratise internet commerce in Africa by making it possible for anyone to sell online; From vendors & brands with products looking to grow their sales; To resellers with no products looking to earn from commissions. Kamel powers hundreds of businesses across the African continent and is trusted by entrepreneurs at various stages of growth.
Trust is the foundation of the Kamel platform and includes trusting us to do the right thing with your information. Three main values guide us as we develop our products and services. These values should help you better understand how we think about your information and privacy.
Your information belongs to you: We carefully analyze what types of information we need to provide our services, and we try to limit the information we collect to only what we really need. Where possible, we delete or anonymize this information when we no longer need it. When building and improving our products, our engineers work closely with our privacy and security teams to build with privacy in mind. In all of this work our guiding principle is that your information belongs to you, and we aim to only use your information to your benefit.
We protect your information from others: If a third party requests your personal information, we will refuse to share it unless you give us permission or we are legally required. When we are legally required to share your personal information, we will tell you in advance, unless we are legally forbidden.
We help merchants and partners meet their privacy obligations: We understand that many of the merchants and partners using Kamel do not have the benefit of having dedicated privacy personnel, and it is important to us to help them meet their privacy obligations. To do this, we try to build our products so they can easily be used in a privacy-friendly way.
Why we process your information
We generally process your information when we need to do so to fulfill a contractual obligation (for example, to process your subscription payments to use the Kamel platform), or where we or someone we work with needs to use your personal information for a reason related to their business (for example, to provide you with a service). Nigerian and European law calls these reasons “legitimate interests.” These “legitimate interests” include:
Prevent, detect and manage risk against fraud and illegal activities using internal and third party screening tools
answering questions or providing other types of support
helping merchants find and use apps through our app store
Provide you with the required services.
providing reporting and analytics
testing out features or additional services
assisting with marketing, advertising, or other communications
Improve features, website content and analyse data to develop products and services.
Address inappropriate use of our website
Verify your identity and the information you provide in line with Kamel's statutory obligations using internal and third party tools
Maintain up-to-date records
Resolve disputes that may arise, including investigations by law enforcement or regulatory bodies
Any other purpose that we disclose to you in the course of providing Kamel services to you
We only process personal information for these “legitimate interests” after considering the potential risks to your privacy—for example, by providing clear transparency into our privacy practices, offering you control over your personal information where appropriate, limiting the information we keep, limiting what we do with your information, who we send your information to, how long we keep your information, or the technical measures we use to protect your information.
One of the ways in which we are able to help merchants using Kamel is by using automated techniques in handling your data which in most cases requires little human intervention. When we use such automated techniques, we either: (1) still have a human being involved in the process (and so are not fully automated); or (2) use machine learning in ways that don’t have significant privacy implications (for example, automated report generation of your business and account reports ).
We may process your personal information where you have provided your consent. In particular, where we cannot rely on an alternative legal basis for processing, where your data is sourced and it already comes with consent or where we are required by law to ask for your consent in the context of some of our sales and marketing activities. At any time, you have a right to withdraw your consent by changing your communication choices, opting out from our communications or by contacting us.
Your rights over your information
We believe you should be able to access and control your personal information no matter where you live. Depending on how you use Kamel, you may have the right to request access to, correct, amend, delete, port to another service provider, restrict, or object to certain uses of your personal information (for example, direct marketing). We will not charge you more or provide you with a different level of service if you exercise any of these rights.
If you buy something from a Kamel-powered store and wish to exercise these rights over information about your purchase, you need to directly contact the merchant you interacted with. We are only a processor on their behalf, and cannot decide how to process their information. We will of course help our merchants to fulfill these requests by giving them the tools to do so and by answering their questions.
If you are a merchant, partner, Shop user, Kamel employee, or other individual that Kamel has a direct relationship with, please submit your data subject request through email (email@example.com). Please note that if you send us a request relating to your personal information, we have to make sure that it is you before we can respond. In order to do so, we may use a third party to collect and verify identification documents.
If you are not happy with our response to a request, you can contact us to resolve the issue. You also have the right to contact your local data protection or privacy authority at any time.
Finally, because there is no common understanding about what a “Do Not Track” signal is supposed to mean, we don’t respond to those signals in any particular way.
Information we collect
As part of our operations, Kamel collects and processes certain types of information (such as name, telephone numbers, address etc.) of individuals that makes them easily identifiable. These individuals include current, past and prospective employees, merchants, suppliers/vendors, customers of merchants, Users and other individuals whom Kamel communicates or deals with, jointly and/or severally.
Kamel is firmly committed to complying with applicable data protection laws, regulations, rules and principles to ensure security of Personal Information handled by the Company.
To gain full access to our website and services, you must register for a Kamel account. When you register for an account, we collect Personal Information which you voluntarily provide to us. Personal Information refers to information relating to an identified person or information that can be used to identify you, (e.g. email address, bank details, name, telephone number). It may also include anonymous information that may be linked to you specifically, (e.g. IP address).
We may retrieve additional Personal Information about you from third parties and other identification/verification services such as your financial institution and payment processor. With your consent, we may also collect additional Personal Information in other ways including emails, surveys, and other forms of communication. Once you begin using our services through your Kamel account we will keep records of your transactions and collect information of your other activities related to our services. We will not share or disclose your Personal Information with a third party without your consent except as may be required for the purpose of providing you with our services or under applicable legislation.
In providing you with the services, we may rely on third-party servers located in foreign jurisdictions from time to time, which as a result, may require the transfer or maintenance of your personally identifiable information on computers or servers in foreign jurisdictions. We will endeavour to ensure that such foreign jurisdictions have data protection legislation that is no less than the existing data protection regulations in force in Nigeria and your personally identifiable information is treated in a safe and secure manner.
Information that we collect from Vendors using our app
Account Access Information.
When you sign up or log-in to our Service, we verify your phone number by sending you a code via SMS or calling you. You can also add a PIN to enable two-step verification and an email address that can be used to reset that PIN.
Kamel collects upon request your contact list using contact upload which contains name and phone numbers in your device address book on a regular basis which are saved as either your customers or suppliers on the app.
Images, Videos and other Media Information
Kamel collects upon request your images and video using media upload which contains data from your device gallery. The media files you upload will be displayed on the app, on your online store, and other areas you may choose to display them through our systems.
When you contact us for customer support or otherwise communicate with us, you may provide us with information related to your use of our Services, including copies of your messages, any other information you deem helpful in order for us to understand and resolve your query, and how to contact you (e.g., an email address). For example, you may send us an email with information relating to app performance or other issues. We also collect information on how you use our customer support features (e.g., the searches you make on our Help Center) and any feedback you give us on the customer support experience.
Information that we collect from Kamel powered e-commerce stores
When a customers checkout on a merchant’s website that is powered by Kamel, we do collect and store their email address, mobile phone number, and billing and shipping address. We do not however collect and store card or banking information in whatsoever form.
Purpose Limitation & Data Collection Minimisation
Kamel collects Personal Information only for identification purposes and for which consent has been obtained. Such Personal Information cannot be reused for another purpose that is incompatible with the original purpose, except consent is obtained for such purposes.
Kamel limits Personal Information collection and usage to data that is relevant, adequate, and absolutely necessary for carrying out the purpose for which the data is processed.
Kamel will evaluate whether and to what extent the processing of Personal Information is necessary and where the purpose allows, anonymized data will be used.
How We Protect your Information
Our teams work tirelessly to protect your information, and to ensure the security and integrity of our platform. We also have independent auditors assess the security of our data storage and systems that process financial information. However, we all know that no method of transmission over the Internet, and method of electronic storage, can be 100% secure. This means we cannot guarantee the absolute security of your personal information.
Kamel is nevertheless committed to managing your Personal Information in line with global industry best practices. We protect your Personal Information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration, we also use industry recommended security protocols to safeguard your Personal Information. Other security safeguards include but are not limited to data encryption, firewalls, and physical access controls to our building and files and only granting access to Personal Information to only employees who require it to fulfil their job responsibilities. Any Personal Information processing undertaken by an employee who has not been authorized to carry such out as part of their legitimate duties is unauthorized.
Employees may have access to Personal Information only as is appropriate for the type and scope of the task in question and are forbidden to use Personal Information for their own private or commercial purposes or to disclose them to unauthorized persons, or to make them available in any other way.
How we share the Personal Information you provide
Kamel does not sell, trade or rent personal information to anyone. However, to enable us render our services to you on our website and mobile app, we may share your information with trusted third parties, such third parties include social media platforms, e-commerce marketplaces, financial institutions, payment processors verification services, sanctions screening and identity verification services as well as any third parties that you have directly authorized to receive your Personal Information. Your Personal Information may be stored in locations outside the direct control of Kamel, for instance, on servers or databases co-located with hosting providers.
Transfer of Information
Transfer of Personal Information to Foreign Country: Where Personal Information is to be transferred to a country outside of our local market (Nigeria), Kamel shall put adequate measures in place to ensure the security of such Personal Information. In particular, Kamel shall, among other things, confirm whether the country is on the National Information Technology Development Agency (“NITDA”) White List of Countries with adequate data protection laws.
Transfer of Personal Information out of Nigeria would be in accordance with the provisions of the Nigeria Data Protection Regulation. Kamel will therefore only transfer Personal Information out of Nigeria on one of the following conditions:
The consent of the Data Subject has been obtained;
The transfer is necessary for the performance of a contract between Kamel and the Data Subject or implementation of pre-contractual measures taken at the Data Subject’s request;
The transfer is necessary to conclude a contract between Kamel and a third party in the interest of the Data Subject;
The transfer is necessary for reason of public interest;
The transfer is for the establishment, exercise or defense of legal claims;
The transfer is necessary in order to protect the vital interests of the Data Subjects or other persons, where the Data Subject is physically or legally incapable of giving consent.
Kamel will take all necessary steps to ensure that Personal Information is transmitted in a safe and secure manner. Details of the protection given when your Personal Information is transferred outside Nigeria shall be provided to you upon request.
Grounds for processing of personal information
Processing of Personal Information by Kamel shall be lawful if at least one of the following applies:
The Data Subject has given consent to the processing of his/her Personal Information for one or more specific purposes;
The processing is necessary for the performance of a contract to which the Data Subject is party or in order to take steps at the request of the Data Subject prior to entering into a contract;
Processing is necessary for compliance with a legal obligation to which Kamel is subject;
Processing is necessary in order to protect the vital interests of the Data Subject or of another natural person; and
Processing is necessary for the performance of a task carried out in the public interest or in exercise of official public mandate vested in Kamel.
Choices and Rights
Individuals who have Personal Information held by Kamel are entitled to reach out to Kamel to exercise the following rights:
Right to request for and access their Personal Information collected and stored. Where data is held electronically in a structured form, such as in a Database, the Data Subject has a right to receive that data in a common electronic format
Right to information on their personal information collected and stored;
Right to objection or request for restriction;
Right to object to automated decision making;
Right to request rectification and modification of Personal Information which Kamel keeps;
Right to request for deletion of their data;
Right to request the movement of data from Kamel to a third party; this is the right to the portability of data;
Right to object to, and to request that Kamel restricts the processing of their information
Your request will be reviewed by Kamel's Data Protection Officer and carried out except as restricted by law or Kamel's statutory obligations. You may decline to provide your personal Information when it is requested by Kamel, however, certain services or all the services may be unavailable to you. You may review your account settings and update your Personal Information directly or by contacting us.
The Data that We Retain and Your Rights to Deletion
We will retain your information for as long as your account is active or as needed to provide our services to you, comply with our legal and statutory obligations or verify your information with a financial institution.
Kamel is statutorily obligated to retain the data you provide us with in order to process transactions, ensure settlements, make refunds, identify fraud and in compliance with laws and regulatory guidelines applicable to us, our banking providers and card processors.
Therefore, even after closing your Kamel account, we will retain certain Personal Information and transaction data to comply with these obligations. All Personal Information shall be destroyed by Kamel where possible upon request or by using the clear data button with the app. For all Personal Data and records obtained, used and stored by Kamel, we shall perform periodical reviews of the data retained to confirm the accuracy, purpose, validity and requirement to retain.
The length of storage of Personal Information shall, amongst other things, be determined by:
The contract terms agreed between Kamel and the Data Subject or as long as it is needed for the purpose for which it was obtained; or
Whether the transaction or relationship has statutory implication or a required retention period; or
Whether there is an express request for deletion of Personal Data by the Data Subject, provided that such request will only be treated where the Data Subject is not under any investigation which may require Kamel to retain such Personal Data or there is no subsisting contractual arrangement with the Data Subject that would require the processing of the Personal Data; or
Whether Kamel has another lawful basis for retaining that information beyond the period for which it is necessary to serve the original purpose.
How you can reach us
ATTN: Head of Privacy
No 39, 6th Avenue Gwarinpa
Updates, Modifications & Amendments