Memsap (AMTL) (“we”, “us”, “our”) respects your privacy. This Privacy Policy explains how we collect, use, disclose, and protect personal information when you visit our websites (africore-os.com, or use our Services, including afriCore OS, Construction Technology Solutions, Cleaning & Housekeeping Technology, ICT consulting, and custom software development.
We comply with the Kenya Data Protection Act, 2019 (the “Act”). Please read this policy carefully.
In simple terms
This document explains what personal data we collect, why we collect it, and how we keep it safe – as required by Kenyan law.
1. Information We Collect
We collect different types of information depending on how you interact with us.
1.1 Information You Provide Directly
Category Examples
Account information Name, email address, phone number, business name, physical address, registration number (for SACCOs/companies)
Member / client data (entered by you into our systems) Names, national ID or membership numbers, savings/loan records (afriCore OS); project details, equipment lists (Construction); client names, job schedules (Cleaning)
Billing information Payment details, invoicing address
Communications Emails, support tickets, feedback sent to support@africore-os.com, info@africore-os.com, or info@africanmemsap.co.ke
1.2 Information Collected Automatically
When you visit our websites or use our Services, we may automatically collect:
• Technical data – IP address, browser type, device information, operating system
• Usage data – pages visited, features used, time stamps, clickstream data
• Cookies – small text files to improve user experience (see Section 8)
1.3 Information from Third Parties
If you connect third party services (e.g., payment gateways, SMS providers), we may receive limited information from them as necessary to provide the Service.
Simple terms
We collect what you give us (account details, member data), plus basic technical info like your IP address and how you use our platforms.
2. How We Use Your Information
We use your personal information only for legitimate business purposes:
Purpose Legal Basis (under DPA 2019)
To create and manage your account Contractual necessity
To provide our Services (afriCore OS, Construction, Cleaning tech) Contractual necessity
To generate reports (including SASRA templates) Contractual necessity / Legitimate interest
To process payments and billing Contractual necessity
To respond to support requests (via support@africore-os.com) Legitimate interest
To improve our platforms, fix bugs, and analyse usage Legitimate interest
To comply with legal obligations (court orders, regulatory requests) Legal obligation
To prevent fraud and enhance security Legitimate interest / Legal obligation
We do not sell your personal data to third parties.
Simple terms
We use your data to run the service, help you, improve our products, and follow the law – never to sell.
3. Legal Basis for Processing (Kenya DPA 2019)
Under the Data Protection Act, we rely on the following lawful bases:
• Consent – Where you have given clear consent (e.g., for marketing emails). You may withdraw consent at any time.
• Contract – Processing necessary for the contract we have with you (e.g., providing afriCore OS).
• Legal obligation – Compliance with Kenyan laws (e.g., tax records, court orders).
• Legitimate interests – Improving our services, security, and fraud prevention, provided your rights do not override those interests.
Simple terms
We only process your data when we have a valid legal reason – your consent, a contract, a legal duty, or a legitimate business interest.
4. Sharing Your Information
We may share your personal information only in the following circumstances:
4.1 Service Providers
We engage third party companies to help deliver our Services (e.g., cloud hosting, payment processing, email delivery). These providers are contractually bound to protect your data and may only use it for the specified purposes.
4.2 Legal Compliance
We may disclose your information if required by:
• A court order or search warrant from a Kenyan court
• A lawful request from a Kenyan government agency (e.g., DCI, SASRA, KRA)
• Applicable law or regulation
4.3 Business Transfers
If AMTL is involved in a merger, acquisition, or asset sale, your information may be transferred. We will notify you before any such transfer.
4.4 Protection of Rights
We may disclose information to enforce our Terms of Use, protect our rights, privacy, safety, or property, or that of our users.
We never sell your personal data to advertisers or marketers.
Simple terms
We share your data only with trusted partners who help us run the service, or when the law forces us. We never sell it.
5. Data Security
We implement reasonable technical and organisational measures to protect your personal information against accidental loss, unauthorised access, alteration, or disclosure. These include:
• Encryption of data in transit (TLS/SSL)
• Access controls and authentication
• Regular security assessments
• Employee training on data protection
However, no system is 100% secure. You acknowledge that you provide your information at your own risk.
If you discover a security breach involving your data, notify us immediately at info@africanmemsap.co.ke).
Simple terms
We use strong security, but no one can guarantee perfection. Tell us right away if you spot a problem.
6. Data Retention
We retain your personal information only as long as necessary for the purposes set out in this Privacy Policy, or as required by Kenyan law.
Type of data Retention period
Account information For as long as your account is active, plus up to 7 years after closure for legal/tax purposes
Transactional data (savings, loans, payments) As required by SASRA, KRA, or other regulators (typically 7 years)
Usage logs Up to 12 months
Support tickets 3 years after resolution
After retention expires, we securely delete or anonymise your data.
Simple terms
| We keep your data while you use our service, and afterwards only as long as the law requires (e.g., for tax or SASRA audits).
7. Your Rights (Under Kenya Data Protection Act)
You have the following rights regarding your personal information:
Right What it means
Right to access Request a copy of the personal data we hold about you
Right to rectification Correct inaccurate or incomplete data
Right to erasure (right to be forgotten) Request deletion of your data, subject to legal retention obligations
Right to restrict processing Limit how we use your data in certain circumstances
Right to data portability Receive your data in a structured, machine readable format
Right to object Object to processing based on legitimate interests or direct marketing
Right to withdraw consent Withdraw any consent you previously gave (e.g., marketing)
Right to lodge a complaint Complain to the Office of the Data Protection Commissioner (ODPC) of Kenya
To exercise any of these rights, contact us at privacy@africanmemsap.co.ke or write to:
African Memsap Technology Limited
City House Fontanella, Box 43366, Mombasa, Kenya
We will respond within 30 days as required by law.
Simple terms
You have legal rights over your data – to see it, fix it, delete it, or complain. Just ask us.
8. Cookies & Tracking Technologies
Our websites use cookies to:
• Remember your login status and preferences
• Analyse site traffic and usage (e.g., Google Analytics)
• Improve performance and user experience
You can control or disable cookies through your browser settings. However, disabling cookies may affect the functionality of our Services.
We do not use cookies for cross site tracking or advertising.
Types of cookies we use:
Type Purpose
Essential Required for login and core features
Functional Remember preferences (e.g., language)
Analytics Anonymous usage statistics
Simple terms
| We use basic cookies to make the site work and understand how people use it. You can turn them off in your browser, but some features may break.
9. International Data Transfers
We primarily store and process your data on servers located in Kenya. However, some third party service providers (e.g., cloud hosting, payment processors) may operate outside Kenya. When we transfer data outside Kenya, we ensure appropriate safeguards are in place, such as:
• Standard contractual clauses approved by the ODPC
• Adequacy decisions (if any)
• Binding corporate rules
By using our Services, you acknowledge that your information may be transferred to countries with different data protection laws. We remain responsible for your data under Kenyan law.
Simple terms
| Your data stays in Kenya when possible. If it must go elsewhere (e.g., for hosting), we use legal safeguards.
10. Children’s Privacy
Our Services are not intended for individuals under 13 years of age. We do not knowingly collect personal information from children. If you believe a child has provided us with personal data, please contact us immediately so we can delete it.
11. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of material changes by:
• Posting the updated policy on our websites
• Sending an email to the address associated with your account (if you have one)
The “Effective Date” at the top of this policy will indicate when it was last revised. Your continued use of our Services after the changes means you accept the updated policy.
Simple terms
| We will tell you if we make big changes – by email or on our website. Keep using the service means you agree.
12. Contact Information
If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us:
Data Protection Officer (DPO)
African Memsap Technology Limited
City House Fontanella, Box 43366, Mombasa, Kenya
Email contacts:
• Privacy & data rights: privacy@africanmemsap.co.ke
• General inquiries / info: info@africore-os.com (CC to info@africanmemsap.co.ke)
• Support: support@africore-os.com
• Security issues: security@africore-os.com
Phone: [Insert Phone Number]
You also have the right to lodge a complaint with the Office of the Data Protection Commissioner (ODPC) of Kenya:
ODPC Kenya
P.O. Box 30909 – 00100, Nairobi, Kenya
Email: info@odpc.go.ke
Website: www.odpc.go.ke
Acknowledgment
By using our websites or Services, you acknowledge that you have read and understood this Privacy Policy and agree to its terms.
