Privacy Policy

1. About Us

FX Nairobi is a forex bureau management SaaS platform operated by SomICT. We are committed to protecting the privacy and security of the personal data we process. This Privacy Policy explains what data we collect, why we collect it, how we use it, and your rights in relation to it.

If you have any questions about this policy, contact us at support@fxnairobi.com.

2. Data We Collect

We collect the following categories of personal data:

• Identity data: Full name, national ID number, passport number, and other KYC documents submitted for compliance purposes.
• Contact data: Email address and phone number used to create and manage your account.
• Transaction data: Currency exchange transactions, amounts, rates, timestamps, and associated customer records.
• Financial data: Wallet balances, drawdown history, and payment records related to your subscription.
• Technical data: IP address, browser type, device identifiers, and session activity logs collected automatically when you use the platform.
• KYC documents: Scanned ID documents and customer photographs required for Central Bank of Kenya (CBK) compliance.

3. Why We Collect It

We process your data for the following purposes:

• Account management: To create and maintain your organisation account and provide platform access to authorised staff.
• CBK compliance: To satisfy Know Your Customer (KYC) and Anti-Money Laundering (AML) requirements mandated by the Central Bank of Kenya.
• Service delivery: To process transactions, manage customer wallets, generate reports, and provide all platform features.
• Fraud prevention: To detect and prevent unauthorised access, fraudulent transactions, or misuse of the platform.
• Billing: To process subscription payments and manage your account status.
• Support: To respond to enquiries, resolve issues, and improve the platform.

4. How We Store Your Data

Your data is stored on secure, encrypted servers. We apply industry-standard security measures including encryption at rest and in transit (TLS/SSL), access controls, and regular security audits.

We do not sell, rent, or trade your personal data to third parties. Your data is never used for advertising purposes.

5. Data Retention

We retain your data for as long as your account is active or as required by law.

• Transaction records and KYC documents are retained for a minimum of 7 years in accordance with CBK regulatory requirements.
• Account data is retained while your account is active and for up to 2 years after account closure.
• Technical logs are retained for up to 90 days.

6. Your Rights

Subject to applicable law, you have the following rights in relation to your personal data:

• Access: You may request a copy of the personal data we hold about you.
• Correction: You may request that inaccurate or incomplete data be corrected.
• Deletion: You may request deletion of your personal data, subject to legal retention obligations (e.g. the 7-year CBK requirement).
• Restriction: You may request that we restrict processing of your data in certain circumstances.

To exercise any of these rights, contact us at support@fxnairobi.com. We will respond within 30 days.

7. Cookies

FX Nairobi uses session cookies only. These are strictly necessary cookies used to maintain your authenticated session while you use the platform. We do not use advertising cookies, tracking pixels, or third-party analytics cookies.

Session cookies are deleted when you close your browser or sign out of the platform.

8. Third-Party Service Providers

We share limited data with the following trusted service providers to operate the platform:

• Resend — used to send transactional emails (e.g. account verification, password reset). Only your email address is shared for this purpose.
• Let's Encrypt — provides SSL/TLS certificates to secure data in transit. No personal data is shared.

All third-party providers are bound by data processing agreements and are prohibited from using your data for any purpose other than delivering services to us.

9. Governing Law

This Privacy Policy is governed by the laws of Kenya, including the Data Protection Act, 2019. Any disputes shall be resolved in the courts of Nairobi, Kenya.

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by email or by displaying a notice in the platform. Continued use of FX Nairobi after changes take effect constitutes acceptance of the updated policy.

11. Contact

For privacy-related enquiries, contact us at: support@fxnairobi.com