Last updated: 6/20/2025
Hi! We’ve created this Privacy Policy (the “Policy”) to describe your privacy rights regarding how we collect, use, process, disclose and protect your information; including any nonpublic, personal information (Personal Data).
This Policy applies to the Personal Data collected by Wavvy Pay Ltd when you use our website, mobile application, social media platforms, tools and any other platform belonging to Wavvy Pay Ltd (collectively, the “Services”) or otherwise interact with us as described below. We may update this Policy from time to time and at our sole discretion. Where updates are made to the Policy, we will notify you of same by revising the date at the top of this Policy, and in some cases, provide you with additional notice ( by adding a statement to the homepages of our website or mobile application; or by sending you an email notification).
We encourage you to review the Policy whenever you interact with us to stay informed about our information privacy practices as well as ways in which you can protect your privacy. By accessing or choosing to use any of our platforms, you agree to be bound by this Policy.
You accept this Policy when you give consent upon access to our platforms, or use our services, technologies, features, content or function offered on our website, mobile applications, digital platforms, social media, amongst other platforms which may be contemplated to be used by Wavvy Pay Ltd.
You may be asked to provide your Personal Data, anytime you contact us or interact/access any of Wavvy Pay Ltd’s platforms, and we shall use your Personal Data in accordance with this Policy, relevant laws, regulations and implementation framework.
We collect Personal Data you provide to us when you apply for a Wavvy Wallet account or when you communicate with us about your Wavvy Wallet account. The types of Personal and Technical Data we may collect include, but not limited to:
REQUIRED: Your name, address, phone number, email address, date of birth and gender, username and password,type of mobile device you use, device ID, device operating system, and information about the SIM card used by the device.
NON-REQUIRED: Bank account information, SMS logs, contact lists, and next of kin details, device name, unique device identifiers (for example, your Device’s IMEI or serial number, the type of browser you use, mobile network information, or your Device’s location and time zone setting (Device Information)).
As you use your Wavvy Wallet account to track financial transactions, we collect Personal Data in connection with each transaction, including but not limited to transaction time, Kshs amount and MPESA merchant/user details. We may also collect photos, memos or other information that you attach to your transactions.
We may also use GPS technology or other location services to determine your current location when performing financial transactions.
We may collect Personal Data you provide to us, such as your name, email address, and any other information you choose to share. For example, we may collect such information if you request an invite to join Wavvy Wallet. If you choose to enable access to your contacts via our mobile application, we may upload your contact data to our servers so we can show you which of your contacts are also registered on the Wavvy Wallet platform.
Additionally, we collect information about your app usage—such as tagging activity, budgeting interactions, and savings behaviors—which may be used to display anonymized data on community leaderboards as part of our gamification features.
You may also be asked to join a trial or subscribe to our premium service. In such cases, we will collect payment information, including transaction details necessary to process and manage your subscription securely only on wavvywallet.com.
When you access or use our Services, we automatically collect Personal Data and other information about you as follows:
We may use your information, including Personal Data as follow
Wavvy Pay Ltd is based in Kenya and the Personal Data we collect is governed by Kenya’s Data Protection Act 2019 and the Constitution of Kenya, 2010. By accessing or using the Services or otherwise providing your Personal Data to us, you consent to the processing and transfer of your Personal Data in and outside Kenya.
We will only use your Personal Data if we have a proper reason for doing so. We consider the lawful basis for using your Personal Data as set out in Kenya’s Data Protection Act. This include:
We may disclose any information we collect about current and former customers, including Personal Data, to affiliates and non-affiliated third parties as follows:
The data that we collect from you may be transferred to, and stored at, a destination outside your country of origin or residence (as applicable). It may also be processed by staff operating outside your country of origin or residence (as applicable), who work for us or for one of our suppliers. These staff members may be engaged in the fulfilment of your requests on the Service Sites. Data stored outside Kenya may be subject to the laws of the country in which it is stored. By submitting your personal data, you agree to the collection, transfer, storing or processing of your personal data in the manner set out above. We will take all steps reasonably necessary to ensure that your data is treated, stored and processed securely and in accordance with this Privacy Policy.
Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Service Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to Our Service Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
We will hold your Personal Data on Wavvy Pay Ltd’s systems in line with our Retention Schedule to fulfil the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements.
We implement and maintain appropriate safeguards to protect personal data, taking into account in particular the risks to you, presented by unauthorised or unlawful processing or accidental loss, destruction of, or damage to their personal data.
Safeguarding will include the use of encryption and pseudonymisation where appropriate. It also includes protecting the confidentiality (i.e. that only those who need to know and are authorised to use personal data have access to it), integrity and availability of the personal data. We regularly evaluate and test the effectiveness of those safeguards to ensure the security of our processing of personal data.
You are entitled to:
We will request for your consent prior to using your personal information for marketing purposes. You shall be entitled to prevent such usage by informing us, within 10 days of being informed of the proposed use, that you do not wish to disclose such information. You can also exercise the right at any time by contacting us at support@wavvy.africa
As a Data Subject you have the right not to be subject to decisions based solely on automated Processing, including Profiling; it is based on your explicit Consent and is subject to safeguards; or is authorised by law and is also subject to safeguards;
You have the rights set out in Section 26 of the Data Protection Act.
Any changes we may make to this Policy in the future will be posted on this page and, where appropriate, notified to you when you next start the App or log onto one of the Service Sites. The new policy may be displayed on-screen and you may be required to read and accept them to continue your use of the App or the Services. In any event, by continuing to use the App or any Services after the posting of any changes, you confirm your continuing acceptance of this Privacy Policy together with such changes, and your consent to the policy set out therein.
The data collected is voluntary and not mandatory or pursuant to any law in Kenya.
Questions, comments and requests regarding this policy are welcomed and should be addressed to support@wavvy.africa