ETNet Wallet · Privacy Policy

1. Scope of this Policy

This Privacy Policy applies to the "ETNet Wallet" mobile application (Android package name com.etnet.wallet, and the iOS client). The App is designed for real-estate marketing professionals ("Marketers") and provides customer management, commission tracking and commission withdrawal features.

This Policy does not cover third-party websites or services that you may access via links from the App. The privacy practices of such third parties are governed by their own policies.

2. Information We Collect and Use

We collect only the information that is necessary to provide the App's features.

2.1 Registration and Sign-in

To create an account and sign in, we collect:

• Name – to identify you and display your profile;
• Phone number – used as your login account, and to receive SMS verification codes for registration and password recovery;
• Login password – stored in encrypted form and used for authentication;
• Identity type – e.g. "company employee" or "external partner", used for business routing.

2.2 Profile Information

You may maintain the following in "My Profile" (optional, does not affect core features):

• Name (editable);
• Region (county / sub-county level).

2.3 Commission Withdrawal

To settle commissions to your mobile-money account, we collect your M-Pesa phone number, which is verified by an SMS code before being linked. This number is used solely for commission payouts and is not used for any other commercial purpose.

2.4 Business Features (Customer and Building Management)

As a Marketer you may enter customer and building information. This data is entered by you, and you are responsible for it:

• Customer information – customer name, phone number, address, remark, selected package, region, associated building, whether the customer is a returning one, and customer type;
• Building information – building name, building code, region, and location text.

Before entering information about any third party (e.g. a customer), please ensure you have obtained their lawful consent and that the use is consistent with the App's business purpose.

2.5 Device and Operational Information

To support in-app updates and normal operation, we read a limited set of technical parameters:

• CPU architecture (ABI) – used only to select the matching installation package during updates; not used to identify or track you;
• App version and network status – used for version detection and basic operation.

We do not collect IMEI, Android ID, OAID, IDFA, advertising identifiers, MAC address, or device serial numbers, and we do not collect your contacts, photo gallery, photos, SMS contents, or browsing history.

2.6 Customer Support and In-App Messages

Messages you submit via "Customer Service Message", together with our communication records, are stored on our servers to handle your inquiries, complaints and suggestions.

2.7 Summary

3. Device Permissions We Request

To deliver the features above, we may request the following device permissions. You can disable any of them at any time in your system settings; the related features will then be unavailable, but other features remain unaffected.

Note: The App also declares visibility queries for tel: (one-tap call to customer service) and text-processing capabilities. These are system-level redirects and do not read your contacts or call logs.

4. Third-Party Services

To provide map and location features, we have integrated the following third-party services. These services may process your information in accordance with their own privacy policies, which we encourage you to review:

We do not integrate any push, analytics, advertising, third-party sign-in, or instant-messaging SDKs.

5. How We Share, Transfer and Disclose Information

5.1 Sharing

We may share necessary information in the following situations:

• Mobile-money provider – when you initiate a commission withdrawal, your M-Pesa phone number and the withdrawal amount are submitted to the relevant payment provider to complete the payout;
• Map provider (Google) – as described in Section 4;
• Any other sharing carried out with your explicit consent.

We do not sell your personal information to any unrelated third party.

5.2 Transfer

We will not transfer your personal information to third parties. In the event of a merger, acquisition or asset transfer that requires the transfer of information, we will require the recipient to remain bound by this Policy; if the recipient changes the purpose of use, it must obtain your consent again.

5.3 Public Disclosure

We will only publicly disclose your personal information with your consent, or where required to do so by law.

5.4 Legal Requirements

To comply with applicable laws, respond to lawful requests from competent authorities, or protect the lawful rights and interests of us and our users, we may be required to disclose your information.

6. How We Store and Protect Information

6.1 Storage Location

Your personal information is stored on our own servers. Where cross-border transmission is involved (for example, map data processed by Google), we handle it in accordance with applicable laws.

6.2 Security Measures

• Data in transit is encrypted via HTTPS, and API access is authenticated with tokens;
• Login passwords are stored in encrypted form, never in plain text;
• We maintain internal access controls so that only authorised personnel may access information within the necessary scope;
• On your device, login state is stored in the App's private storage area and is automatically cleared upon sign-out.

6.3 Security Incident Response

If a personal-data security incident occurs, we will promptly activate our response plan and, within the statutory time limit, notify you of the incident, our response measures, and steps you can take to protect yourself.

7. Your Rights

You have the following rights regarding your personal information:

• Access – you can view your information in "My Profile" and "My Agreements" within the App;
• Correct and update – you can edit your name, region and M-Pesa phone number;
• Delete – you can contact customer service to request deletion of information that is no longer needed (except where retention is required by law);
• Withdraw consent – you can withdraw a previous consent by uninstalling the App or by disabling the relevant device permissions;
• Account deletion – you can request account deletion; afterwards we will process or delete your information in accordance with the law;
• Data portability – where eligible, you may request a copy of your personal information.

To exercise any of these rights, please contact us using the details in Section 12. After verifying your identity, we will respond to your request within 15 business days.

8. Children's Privacy

The App is intended for adult real-estate marketing professionals and is not directed at children. If you are a minor, please read this Policy and use the App under the supervision of a parent or guardian, and submit personal information only with the guardian's consent.

If we become aware that we have collected personal information from a child without prior parental consent, we will delete that information as soon as possible.

9. Data Retention

We retain your personal information only for as long as is necessary to provide the services. Once the retention period expires, the information will be deleted or anonymised, unless a longer retention period is required by law.

10. Your Rights Under Kenyan Law Kenya · ODPC

The App is intended for users in Kenya. The processing of your personal data is governed by the Data Protection Act, 2019 of Kenya and the regulations issued by the Office of the Data Protection Commissioner (ODPC). In addition to the rights listed in Section 7, you have the right to:

• Be informed of the use of your personal data;
• Object to the processing of your personal data;
• Lodge a complaint with the ODPC if you believe your rights have been infringed.

Office of the Data Protection Commissioner (ODPC): www.odpc.go.ke

11. Changes to This Policy

We may update this Policy from time to time to reflect changes in our business, technology, or legal requirements. For material changes (such as material changes to the types of information collected, the purposes of use, or third-party sharing), we will notify you through in-app prompts or other prominent means. If you do not agree with the revised Policy, you may stop using the App; continued use constitutes acceptance of the revised Policy.

12. Contact Us

We will generally respond to verified requests within 15 business days.