This policy explains what personal data the Rembo Classic mobile app collects, why we collect it, how we protect it, and the choices you have. It applies to the Rembo Classic Android app and the services it connects to.
1. Who we are
Data controller: Remboc Classic Saving and Credit Co-operative Society (the “Sacco”)
- Postal address: P.O. Box 482 – 0242, Kitengela, Kenya
- Mobile: 0115 118 735
- Email: remboclassicsaccos@gmail.com
Technology provider (data processor): Trimline Systems & Solutions, Kijabe Street, Norfolk Towers 1st Floor, P.O. Box 35351 – 00100, Nairobi, Kenya — info@trimline.co.ke, 0710 563 359. Trimline hosts and supports the app and the Sacco’s core systems on the Sacco’s instructions.
The Sacco is the data controller for the purposes of the Kenya Data Protection Act, 2019. Trimline processes your data only on the Sacco’s documented instructions.
2. Information we collect
Information you give us
- Identity: member number, full name, national ID / passport number (as held in your Sacco records), date of birth.
- Contact: mobile phone number, email address (if you have provided one).
- Credentials: the password you set in the app and, on first use, your security questions. Passwords are stored in encrypted form by the Sacco’s core banking system; we never store them in readable form.
- Support information: anything you send us when you contact us about a problem.
Information created while you use the app
- Transactions you make through the app (amounts, the account or vehicle paid, date/time and reference), payment templates you save, and your app subscription status.
- Your account balances, statements, share/savings/deposit details, loan details and repayment schedules, and the vehicles linked to your account.
- One-time passwords (OTP) sent to your phone number to confirm your identity.
- Technical records: sign-in times and request logs kept by our servers for security and troubleshooting.
What we do not collect. The app does not access your location, contacts, SMS or call logs, photos, camera, microphone, files or calendar. The Android app requests a single permission — internet access, so it can reach the Sacco’s systems.
3. Why we use your data
- to verify your identity and sign you in (including the OTP sent by SMS);
- to show you your balances, statements, loans, vehicles and payment history;
- to receive, post and confirm the payments you make, and to keep receipts;
- to run your app subscription and notify you about it;
- to send you service messages (payment confirmations, OTPs, subscription notices) by SMS;
- to keep the service secure, prevent fraud, and meet our legal and regulatory obligations (including Sacco and anti-money-laundering requirements);
- to provide support when you contact us.
We do not use your data for advertising, and the app contains no advertising or third-party analytics/tracking software.
4. Sharing
We do not sell your personal data. We share it only with:
- Trimline Systems & Solutions, who host, support and maintain the app and the Sacco’s core systems on the Sacco’s behalf;
- SMS gateway providers, so the OTP and service messages can reach your phone;
- Microsoft Dynamics 365 Business Central / the Sacco’s core banking system, which holds the Sacco’s member accounting records;
- Regulators, auditors or courts, where the law requires it.
Anyone processing data for us is required to protect it and to use it only for the purposes above.
5. Where your data is kept
Your data is stored on servers operated for the Sacco in Kenya. Where a service provider processes data outside Kenya, we ensure appropriate safeguards are in place as required by the Data Protection Act, 2019.
The app also keeps a small amount of information on your phone — your sign-in preference, cached balances/statements and your saved payment templates — so the app opens quickly and works when the network is poor. This local copy is not shared with anyone, is replaced whenever you next sign in online, and is removed when you sign out or uninstall the app.
6. How long we keep it
- Member, transaction, loan and subscription records: for as long as you are a member and afterwards for the period required by law (financial records are normally kept for at least seven years).
- OTPs: they expire shortly after they are issued.
- Technical/security logs: kept for a limited period for security and troubleshooting, then deleted or anonymised.
7. Security
We protect your data with, among other measures: HTTPS/TLS encryption for all data in transit between the app and our servers; encrypted storage of your password; access limited to authorised Sacco and Trimline staff who need it; and audit records of the transactions processed. No system is completely secure — please keep your password private, never share your OTP, and tell us immediately if you suspect someone has accessed your account.
8. Your rights
Under the Data Protection Act, 2019 you may ask for a copy of the data we hold about you, have it corrected, ask us to delete data we no longer have a lawful reason to keep, object to or restrict certain processing, withdraw consent where we relied on it, and complain to the Office of the Data Protection Commissioner (www.odpc.go.ke).
Contact the Sacco at remboclassicsaccos@gmail.com or 0115 118 735 to exercise any of these rights. We will respond within the time allowed by law. Some requests may be limited by our legal duties to keep Sacco records.
9. Children
The app is for Sacco members and is not intended for anyone under 18. We do not knowingly collect data from children.
10. Changes to this policy
If we change how we handle your data we will update this page and, where the change is significant, notify you in the app or by SMS. The effective date at the top shows when the current version took effect.