Privacy Policy

Our philosophy and business ethic

ICTLife (also referred to as “us” or “we” in this document) is founded on the spirit of improving livelihoods through technology. We endeavor to create tools and platforms which enable prosperity through better commerce across Africa and beyond. The experience of our leadership team in building technology products at different companies over the years gives us the conviction that privacy is a fundamental human right and we therefore have made the choice to build products that respect and uphold this belief.

Through the ICTLife merchant platform, we would like to create a self-driving business platform that is based on trust, general observation of the law and regulation, as well as high regard and respect for the intellectual property and data privacy rights of our customers (also referred to as “you” in this document) and other users of our platforms. We welcome you to our community and we hope to work together to improve our livelihoods while building the foundation of a better future for all.

Within the context of this policy, the terms “App”, “Application” and “Platform” may be used interchangeably to mean the collective and interconnected group of ICTLife services including the ICTLife merchant web application and ICTLife mobile device applications.

Our values and approach to data privacy

While we are for-profit, we would like to earn our returns through firsthand delivery of utility to our customers. As such, we shun business practices that monetize customer data through hazy or unclear policy and unauthorized trade-offs with private customer data.

Whenever you provide sensitive information when using our products, we strive to ensure that we provide adequate mechanisms for you to maintain control of your personal data. The security of your data is a key pillar in our business and we put in the necessary efforts to ensure that all our customers are well protected and can utilize our products and services without worry.

We endeavor to uphold the following principles amongst others:

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Privacy by design
We think about your privacy from the start. Our product design and development processes incorporate preserving your privacy as one of the primary objectives.
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Transparency of purposes of data collection and processing
We always remain transparent about your data entrusted to us, without hidden agenda or unclear policy.
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Transparency about our business practices
We acknowledge that we cannot perfectly achieve all privacy desires and thus endeavor to be as open and clear as possible about the offerings and capabilities of our services and products.
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Minimal data collection and retention
We strive to collect, retain and process the minimum information about you that would be required to provide our services and products.
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Encryption by default
We deploy the same grade of encryption used by banks and other sensitive industries to protect your data when in transit between your devices and our infrastructure, by default. Whenever technically feasible, we also encrypt your data while stored on our infrastructure to mitigate against attacks that would result in unwanted exposure of sensitive data.
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Optimized security
We understand that coupling your privacy with industry recommended information security practices is a key necessity to best serve our customers, and we always endeavor to incorporate these practices into our organizational culture.
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Responsible protection of your data rights
We uphold your privacy as a fundamental right and we do not allow unauthorized access to your information shared with us.

Data categories we handle

A: Non-sensitive user data

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Network and related session information
This includes telecommunications network information such as your IP address, the browser and/or device you are using to access our server. The information is automatically available during normal usage of our services and we may utilize it to improve the user experience and observe usage patterns of our products.
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In-App activity metrics and analytics
To enable continuous improvement and observability of the user experience on the ICTLife platform, we may collect additional information regarding user activity and interaction within the product. We collect this data in a non-personalized manner such that it is not used to build user profiles based on their activity; we only utilize this data in aggregated formats for purposes of understanding general usage patterns and with the goal of continuous product improvement. This data is not shared with third parties and currently includes:
Page views
This enables us to track the services and sections of applications that users interact with and assists us to keep improving and customizing the platform towards a better user experience.
Page interaction duration
This is for purposes of continuously adapting our services and the user experience of our applications to changes in traffic based on user access patterns.
Application error and crash analytics

We may collect information about application crashes and other malfunctions for purposes of diagnosing possible causes of such malfunctions and as part of our goal to constantly improve the user experience with our products and services.

The crash analytics information is not personally identifiable, is only used for diagnostic purposes and is never shared with third parties.

B: Personal data and potentially sensitive information

Please note that we will never sell your personal data and sensitive information.

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Your phone number

The phone number is central to enabling communications with our users and managing their activities during their normal usage of ICTLife services. We collect your phone number during account setup for the purpose of verifying your account and also securely associating the resultant account activity with you.

We may also use your phone number to communicate account-related information to you thereafter. We will not share or disclose your phone number to third parties without your consent or for any purposes not outlined in this privacy policy and/or our terms and conditions.

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Location sharing information

When making certain interactions with our services, such as when creating a business profile, you may allow our application to read your device location information to provide location-aware information such as a business address or a delivery address of a related service or product.

The application will prompt you to grant, or deny, the permissions to use your current device location information to enable this functionality. Upon your acceptance and authorization, the application will read your device location information, securely upload it to our servers and utilize it for the purpose of that interaction.

You may also opt to use the application and related services without granting the permission to read your location data. Your location information will not be shared with any third parties without your explicit consent.

C: User-generated content

During normal usage of the ICTLife platform, the user may generate content such as when:

Creating a business account
Reacting to a review
Adding notes or images to a business profile.

You are advised to avoid including sensitive information such as your phone number, credit card information, private photos and other similarly sensitive or personal information since this content will be viewable by other users on the platform. We currently collect the following categories of user-generated content:

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Uploaded images

Users may upload image files to our servers through the platform, such as when creating a business profile, when reacting to an interaction thread such as a review, or as a complement to other content. Such images will be securely uploaded to our servers where they will be stored securely.

The images will be displayed within the context of the corresponding profile or transaction. Users may choose to delete such content through from the platform using the provided deletion feature.

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Submitted text
Users may submit text content, such as when creating a business description or profile. Such content will be securely uploaded to our servers where it will be stored securely. The content will be displayed within the context of the corresponding view, such as a business profile page. Users may choose to later update such content using provided editing functionality, or delete the content using the provided deletion feature.
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User profile images

Users on the ICTLife platform may choose to upload an image which will be used as their account profile image. The image will be securely uploaded to our servers, where it will be stored securely. The image will be displayed as part of the user profile listing and as part of associating the user with the content they contribute on the platform, for example the image may feature as a corresponding avatar for interactive communication threads.

Users may choose to delete such content using the provided deletion feature.

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Star-ratings and similar online expression mechanisms

When using the ICTLife platform, users may express their opinion, for example by making a star-rating when creating a review, or by reacting with a “like” to an existing review.

This information is securely communicated to our servers where it will be stored securely. The content will then be displayed within the context of a corresponding review or transaction as applicable.

All user-generated content submitted onto the ICTLife platform is subject to the provisions of our Terms and conditions and the ICTLife Community interaction policy.

Data handling

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Network and related session information

We do our best to be transparent in our data collection and use including the purposes for which we collect the information we hold about users on our platforms. As required and where applicable, we provision for the explicit authority by the user to grant us the necessary permission on their device to collect the data, such as through in-app prompts. We will not obtain information or data without your permission and we will endeavor to fully inform you and require your explicit permission, even in cases where data collection may happen in the background.

In circumstances where data needs to be transferred to our servers to provide the necessary services to our users, we will strive to protect the data using modern encryption protocols, such as TLSv2 in order to safeguard against possible exposure of the data in transit. We will also strive to implement the necessary safeguards for data stored on our systems, including encryption of data during transfer within and across our infrastructure as well as during long-term storage within our databases.

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On sharing of your data

We never sell or share your data with third parties outside the provisions of this privacy policy and the related terms and conditions of use of the ICTLife merchant platform. Under such circumstances where the data of our users may need to be handled by a third-party provider, for example to dispatch email or SMS communications, we will ensure we work only with service providers who observe similar or stricter levels of user data privacy and related practices.

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Location(s) where your data resides

ICTLife is a company incorporated and existing under the laws of Kenya. However we will primarily engage Amazon Web services Inc(AWS) as a hosting service provider, with the primary data processing and storage centres located within the European Economic area(EEA).

Your personal data stored with us may also be transferred to countries outside of the EU should we have the business need to change our cloud hosting providers, and only for purposes of providing the services required for the ICTLIfe merchant platform and related components to work.

All such transfers of personal data will be made in accordance with applicable laws and we will do our best to maintain the privacy of all your data that we hold.

Platform activity tracking and profiling

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Diagnostic and Analytics activity tracking

We may collect user activity on our applications as outlined under the non-sensitive data we collect. We will only use this data to improve the user experience and derive usage metrics of the platform in a non-personal way. We will not track or profile personal user activity on our platform without your consent.

The metrics we collect in such exercises are only used to inform our internal product usage analytics and related improvement procedures and are never shared with third-parties.

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Our usage of cookies and other session tracking technology

To improve the user experience of our products and services, we sometimes make use of small and usually temporary files (commonly referred to as cookies) stored on your computer, or similar information tracking technology. Please see our full cookie notice here.

Data protection mechanisms we deploy

Technological measures

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Multi-Factor Authentication

Whenever possible, we deploy two or more factors of authentication in your use of our services to give you added security. For example,we require QR Code login to protect your account information from the mobile to the web.

This ensures that someone must additionally have your phone and PIN number when logging into the web to view your transactions.

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Encryption of your data in transit

We protect your data while in transit from your devices to our servers by deploying the same grade of encryption used by sensitive industries such as banking.

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Encryption of your data in storage

We encrypt the data we need to store within our infrastructure to ensure that such data cannot be viewed in the unfortunate event that it ended up in the hands of rogue actors.

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Secure software development

We emphasize information security in our software development process, including counter-checking of our application code by several software developers and teams other than those who originally wrote the application, amongst other internal security protocols.

Organizational measures

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Our general organizational philosophy

Including our internal leadership, the management and internal culture, we have always been keen on respecting and upholding the data privacy and intellectual property rights of all users and parties on our platforms. We always take these matters as a serious responsibility and core to our work as a business and technology provider.

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We do not sell your data

We do not sell your data to third parties, or otherwise use your information for reasons outside the provisions of this privacy policy and our terms and conditions.

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We believe in and uphold your right to awareness and notification

We will notify you of changes and updates to our policies through our website and relevant channels (such as in-App notifications) for your feedback and response. Whenever we make such updates, we will be guided by the principle that users have a fundamental right to privacy and control of their data.

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Access restriction

Access to our internal systems is restricted to authorized staff and on a legitimate need to know basis. We limit such access and it is only granted for the purpose of providing the relevant ICTLife services.

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Strict internal controls and protocols

We maintain strict internal information security procedures and controls to ensure your data remains safe and secure

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Third party access agreements

We do not grant third party access to our systems, except for the purpose of providing the relevant ICTLife service or product. Any access we grant to third parties requires that they sign a data processing agreement which contains the relevant provisions to uphold our data security and privacy protocols.

Our compliance with data privacy laws and regulations

The legal basis for processing your data

To improve the user experience of our products and services, we sometimes make use of small and usually temporary files (commonly referred to as cookies) stored on your computer, or similar information tracking technology. Please see our full cookie notice here.

We process your personal information to operate, provide, and improve the services that we offer our users and customers. We may process your personal data in order to:

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Allow you to use ICTLife services and to provide you with related services.

This may include further customization and/or personalization of your experience with our services on an on-going basis and also depending on your choices and interaction patterns as you use the services over time;

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Provide, troubleshoot, develop and improve ICTLife Services.

We use your personal information to provide functionality, analyse performance, fix errors, and improve the usability and effectiveness of our services.

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Communicate with you and meet your requests.

We use your personal information to communicate with you in relation to our services through different communication channels (e.g. by phone, email, sms, chat). Where such communication is channeled through a third party service provider, we will endeavor to work with providers who uphold data privacy regulations to best protect the privacy of your data.

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Comply with the current laws and regulations and our Terms and Conditions of Service.

In certain cases, we have a legal obligation to collect and process your personal information. For instance, we collect from merchants information regarding their place of establishment and confirm receiving account and billing information for identity verification and possibly other purposes such as fraud prevention.

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Fulfill other purposes, for which we seek your consent.

We may also seek your consent to process your personal information for a specific purpose that we communicate to you. When you consent to our processing of your personal information for a specified purpose, you may withdraw your consent at any time and we will stop processing of your data for that purpose.

Your rights with respect to your data

You can choose not to provide certain information but then you might not be able to take advantage of many ICTLife Services where they require such unavailed information.

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Access to your information

You can access your information including your name, address and profile information

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Amendment and update of your information

You can add or update certain information on your profile under the relevant account settings section of the ICTLife service or platform. When you update such information, we may keep a copy of the previous version for our records.

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Optional data processing

You can opt out of certain other types of data processing by updating your account settings on the applicable ICTLife Service or application.

For example, if you do not want to receive notifications, emails or other communications from us, please adjust your preferences under the account settings. If you do not want to receive in-app notifications from us, please adjust your notification settings within the application or on your device.

Please note that we may mark some options as required to meet and maintain the required minimum service level, such as important notifications.

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Consent to data processing

When you consent to our processing of your personal information for a specified purpose, you may withdraw your consent at any time and we will stop any further processing of your data for that purpose.

Additionally, subject to applicable law, you have the right to:

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Request for information we hold about you

You may request information about the purpose of the processing; the categories of personal data we process; what third parties may receive the data from us; what the source of the information was (if you didn’t provide it directly to us); and how long we may retain such information.

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Access and update your information

We provide mechanisms within the service or platform to enable you to update and make corrections to your information as necessary. You may also contact us should you need to make amendments on your information where a provision for you to do this is not available or enabled on the platform.

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Request for erasure of your information

Subject to certain exceptions, and as provided in the terms and conditions and our other policies:

- We may stop processing your data upon your request, for example if such data was submitted to us through an act of impersonation or identity theft.

- In some cases, such as for statistical analyses purposes, we may anonymize the data that you instruct us to erase, such that it can no longer be used to personally identify you.

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Request a copy of your personal information

Whenever technically feasible, we will — upon your request — provide your personal data to you or transmit it directly to another controller of your choice within 30 days.

If access cannot be provided within a reasonable time frame, we will provide you with a date when the information will be provided.

If for some reason your access to such information is denied, ICTLife will provide an explanation as to why access has been denied.

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Opt out of data processing

You can opt out of certain types of data processing by updating your preferences under the relevant settings on the service or platform.

For example, you may opt out of specific communication categories where applicable, such as only receiving specific newsletter categories.

Please note that we may require certain categories of data processing to remain enabled to maintain the minimum level of service for the platform, for example important communications about your account status cannot be disabled.

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Restrict the processing of your information

You may request that we restrict the processing of your personal data in certain instances, for example, you may opt out of receiving email communications of certain categories if we provide categorised newsletter mailing lists.

To exercise any of these rights, you can use the provided mechanism within the relevant product (commonly under your “profile” or “settings”) or you can contact us at the address noted in the “How to contact us” section below, attaching a copy of an identity document and the address to which our response should be sent.

Retention periods

We will retain your personal data, for as long as it is needed to fulfill the purposes specified in this Privacy Policy, as may be required by applicable law (such as for tax and accounting purposes), or as otherwise communicated to you.

When we no longer have ongoing legal, regulatory or legitimate business need to process your personal data, we will either delete or anonymize it as soon as technically feasible.

How to contact us

For any queries, requests and feedback related to these terms and conditions, please send us an email addressed to, or contact us by postal mail sent to the ICTLife address below:

The Management,
Ideas Come To Life Ltd, Block A-7, Rehema Place,
Junction of Ngong Rd and Ring Road Kilimani,
Nairobi, Kenya
P.O. BOX 13908-00800 Westlands, Nairobi, Kenya
Last Modified: 29th October, 2020
Effective: 15th November, 2020