Privacy Policy

1. Introduction

Welcome to Budj, a product of Fusion Labs Limited ("we," "us," or "our"). We are committed to protecting your personal data and respecting your privacy.

This Privacy Policy explains how we collect, use, store, and share your personal data when you use the Budj mobile application ("App"), our website, and related services (collectively, the "Services").

By accessing or using Budj, you consent to the practices described in this policy.

2. Who We Are

Fusion Labs Limited is the data controller responsible for your personal data.

• Registered Office: Nairobi, Kenya
• Contact Email: support@budj.app

3. The Data We Collect

We collect different types of data to provide our cashback and loyalty services effectively.

A. Data You Provide to Us

• Identity Data: Name, username, date of birth (for age verification).
• Contact Data: Phone number (required for M-Pesa integration) and email address.
• Profile Data: Preferences, feedback, and survey responses.

B. Data We Collect Automatically

• Transaction Data: Details about payments made to merchants via the App (M-Pesa Transaction IDs, amounts, time, and date) to calculate cashback.
• Location Data: Your GPS location to show you nearby exclusive merchant offers and verify eligibility for location-based rewards.
• Usage Data: How you interact with the App, including buttons clicked, time spent, and features used.
• Device Data: IP address, device type, operating system, and unique device identifiers.

C. Data from Third Parties

• Payment Providers: We receive transaction confirmation details from Safaricom (M-Pesa) to verify payments and process cashback.

4. How We Use Your Data

We only use your data when the law allows us to. Specifically, we use it for:

1. Service Delivery: To process transactions, verify purchases, and credit cashback/loyalty points to your wallet.
2. Personalization: To tailor offers, discounts, and merchant recommendations based on your spending habits (e.g., offering higher cashback for frequent purchases).
3. Communication: To send you transactional messages (OTP, receipts) and marketing updates (only if you have opted in).
4. Security & Fraud Prevention: To detect and prevent fraudulent cashback claims, money laundering, or unauthorized access.
5. Platform Improvement: Analyzing usage trends to improve App performance and user experience.

5. Sharing Your Data with Merchants

We value your trust. We have a strict tiered approach to sharing data with our Partner Merchants:

A. Aggregated Insights (Default)

When you shop at a merchant, we share anonymized, aggregated data with them (e.g., "50 users visited this week"). This data does not identify you personally.

B. Personal Data (Opt-In Only)

We DO NOT share your name, phone number, or contact details with merchants for their own marketing purposes unless:

1. You explicitly opt-in to receive offers from that specific merchant.
2. You join a specific Merchant's Loyalty Program within the Budj App.

By joining a Merchant's Loyalty Program, you consent to sharing your transaction history with that specific merchant to allow them to provide tiered rewards.

6. Other Data Disclosures

We may share your data with:

• Service Providers: Third parties who provide IT, cloud hosting (e.g., AWS/Google Cloud), and SMS services to help us run the App.
• Payment Processors: Safaricom (M-Pesa) and banking partners to facilitate transactions.
• Legal Authorities: If required by law, a court order, or to protect the rights and safety of Fusion Labs Limited, our users, or the public.

7. Data Security

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way.

• All data is encrypted in transit (using SSL/TLS) and at rest.
• We strictly control access to your personal data to employees and contractors who have a business need to know.
• We utilize the secure M-Pesa Daraja API for all payment processing.

8. Data Retention

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

• Transaction records: Retained for [e.g., 7 years] as required by Kenyan tax and financial laws.
• Account data: Retained until you delete your account, plus a grace period for recovery.

9. Your Rights

Under the Data Protection Act, 2019, you have the right to:

• Access: Request a copy of the personal data we hold about you.
• Correction: Request us to correct any inaccurate or incomplete data.
• Erasure (Right to be Forgotten): Request us to delete your personal data where there is no good reason for us to continue processing it.
• Object/Restrict Processing: Object to the processing of your data for marketing purposes.
• Data Portability: Request the transfer of your data to you or a third party.

To exercise any of these rights, please contact us at support@budj.app.

10. Location Services

Budj uses location services to provide "Radius Exclusivity" and show nearby deals. You can toggle location services on/off in your device settings. However, disabling location may prevent you from seeing location-specific cashback offers.

11. Children's Privacy

Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that a child has provided us with personal data, we will take steps to delete such information.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any significant changes via an in-app notification or SMS. Your continued use of the App after the changes constitutes acceptance of the new policy.

13. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact our Data Protection Officer at:

Fusion Labs Limited

• Email: support@budj.app
• Phone: +254 722 419 102