PRIVACY POLICY

1. INTRODUCTION

Comsoft Suite Limited, ("Provider", "we", "our", "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our CS Suite System, online financial management platform (the "Service"). We comply with the Data Protection Act 2019 ("DPA") and, where applicable, the General Data Protection Regulation ("GDPR").

2. INFORMATION WE COLLECT

2.1. Personal Information You Provide. We may collect the following:
- Account Information: Name, email address, phone number, billing address, company name, and job title.
- Financial Data: Bank account details, transaction history, invoice data, and other financial records you choose to upload or link.

2.2. Information Collected Automatically. When you access the Service, we may collect certain information automatically, including your IP address, device type, browser type, and usage data (e.g., modules accessed, time spent on the system).

2.3. Information from Third Parties. If you connect your account to third-party financial institutions (e.g., your bank), we may receive information from those sources.

3. HOW WE USE YOUR INFORMATION

We use your information to:

· Provide and Maintain the Service: To process transactions, manage accounts, and provide customer support.

· Improve and Analyse the Service: To understand how users interact with the Platform and enhance user experience.

· Communicate with You: To send service updates, security alerts, and respond to your enquiries.

· Ensure Legal and Regulatory Compliance: To comply with DPA, TFA, and other applicable laws.

4. LEGAL BASIS FOR PROCESSING (under DPA & GDPR)

We process your personal information on one or more of the following lawful grounds: (a) with your consent; (b) to perform a contract with you; (c) to comply with a legal obligation; or (d) for our legitimate business interests, provided such interests are not overridden by your data protection rights.e use your information to:

5. DISCLOSURE OF YOUR INFORMATION

We do not sell your personal information. We may share your information with:

· Service Providers: Third-party vendors who help us operate the Service (e.g., cloud hosting, payment processing), under strict data protection agreements.

· Regulatory and Law Enforcement: When required to comply with a legal process or enforceable government request.

· Business Transfers: In connection with a merger, acquisition, or asset sale.

6. INTERNATIONAL DATA TRANSFERS

Your information may be transferred to, and processed in, countries other than Kenya. We will ensure that any such transfer is subject to appropriate safeguards, such as standard contractual clauses approved by the relevant authorities.

7. DATA SECURITY

We implement appropriate technical and organisational measures to protect your personal information, including encryption and access controls. However, no method of transmission over the Internet is 100% secure, and we cannot guarantee absolute security.

8. DATA RETENTION

We will retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. Financial transaction records are retained for the period required by Kenyan tax law.

9. YOUR RIGHTS (under DPA & GDPR)

Depending on your jurisdiction, you may have the following rights:

· Right of Access: to request a copy of your personal information.

· Right to Rectification: to correct inaccurate or incomplete information.

· Right to Erasure ("Right to be Forgotten"): to request deletion of your personal information, subject to legal retention obligations.

· Right to Object: to object to certain types of processing.

· Right to Lodge a Complaint: with the Kenyan Information Regulator (compliance@odpc.go.ke).

To exercise these rights, please contact us using the details in Section 12.

10. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar tracking technologies to track activity on our Service and hold certain information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent.

11. CHILDREN'S PRIVACY

Our Service is not intended for individuals under the age of 18. We do not knowingly collect personal information from minors.

12. CONTACT US

For any questions about this Privacy Policy or to exercise your data protection rights, please contact us at:

Email: support@comsoft.co.ke
Address:
College House, 4th Floor Room C24
P. O. Box 52838 - 00200
Nairobi, Kenya