This notice applies to all our products and services. Our terms and conditions will specify which of our businesses is providing the relevant product or service to you.

You have a number of rights in relation to your information, including the right to object to processing of your personal information for direct marketing or where the legal basis for our use of your data is not a legitimate business interest or the performance of a task is not in the public interest.

If you have any questions about how your information is gathered, stored, shared or used, please contact our Data Protection Officer at

Who we are

Throughout this document, "we", "us", "our" and "ours" refers to Papayarails. The Website is owned and operated by Papaya Kenya Ltd ("Papayarails").

Who/what does the policy apply to

We handle data in our own right and also for and on behalf of our customers and users.

Our policy does not apply to information we collect about businesses or companies, however it does apply to information about the people in those businesses or companies which we store.

The policy applies to all forms of information, physical and digital, whether collected or stored electronically or in hardcopy.

If, at any time, you provide data or other information about someone other than yourself, you warrant that you have that person's consent to provide such information for the purpose specified.

Papayarails is not available to minors (persons under the age of 18 years).

The information we collect about you

There are a number of reasons for collecting information about you. For instance, we need to know how to get in touch with you, we need to be certain of your identity and we need to understand your business circumstances combined with economic rationale for conducting transactions. We need this information so that we can offer you products and services and give you the best possible customer experience. The information we collect falls into various categories.

  • Personal information: We may collect personal details such as your name, location, date of birth, photograph, passport, driver’s license, and other information (such as your log on identity, addresses, cookie identifiers, security details to protect identity, nationality, email address, work and personal phone numbers) that allows us to identify who you are.
  • Contact information: We may collect information such as your email address, mobile and/or landline telephone number, third-party usernames, residential and business address, and other information that allows us to contact you.
  • Financial information: We may collect financial information related to you about payments you make and receive, such as the date, amount, currency and the details of the payee or payer, and other information that allows us to transact with you and/or provide you with our services.
  • Information you send us: We may collect any personal correspondence that you send us, or that is sent to us by others (such as credit reference or fraud prevention agencies) about your activities, including activities with our third-party partners.
  • Sensitive categories of data: We may hold information about you which includes sensitive personal data, such as criminal conviction information. We will only hold this data when we need to for the purposes of the product or services we provide to you or where we have a legal obligation to do so. Examples of when we use this type of data include:
    • If you have criminal convictions, we may process this information in the context of compliance with our anti-money laundering and counter terrorist financing obligations.
    • Information which you have consented to us using.
    • Your agreement to allow us to contact you through certain channels to offer you relevant products and services.
    • Information from online activities. We collect information about your internet activity using technology known as cookies, which can often be controlled through internet browsers. For detailed information on the cookies we use and the purposes for which we use them, see our Cookie Policy, which is available on our website.

    • Information about your internet browser settings or otherwise Internet Protocol (IP) and other relevant information to help us identify your geographic location when providing you with our services.
    • Other personal information.
    • Information in relation to data access, correction, restriction, deletion, porting requests and complaints.
    • Sometimes we may collect and use your information even though you are not a customer of ours. For example, you may be a recipient, guarantor, director, or representative of one of our customers, or you may be in the process of making an application for a Papayarails product or service. In other cases, your own circumstances may have a material impact on the ability of our customer to perform their obligations to us, and we will need to consider these. If so, we will apply the principles outlined in this Data Privacy Notice when dealing with your information.

Who we share your information with

The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance, or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found at Office of the Data Protection Commissioner (ODPC).

When and how we collect information about you

As you use our services, apply for products, make inquiries, execute transactions, and engage with us, information is gathered about you. We may also collect information about you from other businesses and other parties, for example, when you are named in an application, from identification verification companies, and from sources where you have chosen to make your information publicly available, such as electoral registers, social media sites.

When we collect information about you:

  • When you use our website and online services provided by us (including mobile applications) and visit our offices.
  • When you or others give us information verbally or in writing. This information may be on application forms, online application forms, in records of your transactions with us, or if you make a complaint.
  • When you use our products or services, including making transactions on your account, we gather details about who you get money from, who you pay money to, how much the payments are for, and when the payments are made.
  • From information publicly available about you – for example, in trade directories, online forums, websites, Facebook, Twitter, YouTube, or other social media.

When you make information about yourself publicly available on your social media accounts or where you choose to make information available to us through your social media account, and where it is appropriate for us to use it, this information can help enable us to do things like:

  • Improve our service: For example, identifying common service issues.
  • Personalize your online experience with us: Including through games, videos, or apps.
  • Contact you through the social media services: And enable you to share your experience and content via social media services. For a description of how social media services and other third-party platforms, plug-ins, integrations, or applications use your information, please refer to their respective privacy policies and terms of use, which may permit you to modify your privacy settings.
  • From your online activities with third parties: Where you have given us your consent (for example, by consenting to our use of certain cookies or other location tracking technologies).
  • From identification verification companies, credit reference agencies, credit registration agencies, fraud prevention agencies, or public agencies: Such as property registration authorities, the Companies Registration Office, or court registries.

Please note: If you apply for or hold a financial product in joint names or a business account, you should only give personal information about someone else (for example, a joint applicant, guarantor, dependant, fellow director) with their permission.