Effective Date: July 14, 2026 | Last Reviewed: July 14, 2026
Pioneer House, Kenyatta Avenue, Nairobi, Kenya | support@ognimohub.com | +254 745 497444
This Privacy Policy explains how Ognimohub Agency (“Ognimohub,” “we,” “us,” or “our”) collects, uses, shares, and protects information when you use the Ognimohub User App, Agent App, Merchant App, and related services (the “Platform”). It is expressly incorporated by reference into our Terms of Service, and should be read alongside our AML/KYC Policy and Account Deletion Policy.
1. Introduction
Ognimohub is a pioneering IT, Digital Marketing, and FinTech Agency delivering a cross-platform Mobile Financial Services (MFS) solution across the User App, Agent App, and Merchant App. Because our services involve payments, remittances, and investment products, we collect and process more information than a typical consumer app — much of it required by law. This Policy is written to explain that processing in plain terms, and to set out the rights you have over your own data.
2. Definitions
Personal Data: any information relating to an identified or identifiable natural person, as defined under the Kenya Data Protection Act, 2019.
Processing: any operation performed on Personal Data, including collection, storage, use, disclosure, or deletion.
Data Controller: the entity that determines the purposes and means of processing Personal Data — in this case, Ognimohub Agency.
Data Processor: a third party that processes Personal Data on our behalf and under our instructions, such as a payment or verification vendor.
Sensitive Personal Data: data revealing an individual's race, health, biometric data, or other special categories recognized under applicable law, including government-issued identification and liveness/biometric verification data collected for KYC purposes.
3. Who We Are
Ognimohub Agency is the Data Controller responsible for your Personal Data under this Policy. We are based at Pioneer House, Kenyatta Avenue, Nairobi, Kenya, and can be reached at support@ognimohub.com or +254 745 497444. Our designated contact for data protection matters is described in Section 20.
4. Scope
This Policy applies to Personal Data we collect through the Ognimohub User App, Agent App, Merchant App, our website, and any customer support interaction, regardless of the device or channel used. It applies to Users, Agents, Merchants, and prospective customers who begin but do not complete onboarding.
5. Information We Collect
5.1 Information You Provide to Us
Personal Information: full legal name, date of birth, email address, residential address, phone number, and user IDs.
Identity and KYC Information: government-issued identification documents, selfie/liveness data, and, for Agents and Merchants, business registration documents, Tax Identification Number (TIN), and beneficial ownership details.
Financial Information: bank account and card details, wallet and transaction history, investment plan selections and activity, remittance sender/recipient details, and credit or risk profile data.
Files and Documents: uploaded in support of onboarding, KYC, dispute resolution, or Merchant Invoice records.
Messages: emails, SMS, WhatsApp, and in-app messages exchanged with our support team.
Optional Data: contacts, photos, and videos, where you choose to provide them for a specific feature.
5.2 Information Collected Automatically
Device and App Data: device model, operating system, IP address, crash logs, diagnostics, and performance metrics.
Application Activity: in-app interactions, feature usage, and search history.
Location Data: approximate or precise location, where required for Agent cash-in/cash-out verification, fraud prevention, or to apply jurisdiction-specific features.
5.3 Information From Third Parties
Identity verification vendors, who confirm the authenticity of submitted identification documents.
Payment Service Providers (PSPs) and banking partners, who share transaction confirmation data.
Credit reference bureaus or risk-scoring providers, where relevant to investment or credit-related features.
Publicly available sources, such as sanctions and watchlists, for compliance screening.
6. How We Use Your Information
To create, verify, and administer your Account and provide the Platform's features.
To verify your identity and satisfy AML/KYC and other regulatory obligations.
To process transactions, investment plans, remittances, and merchant payments.
To detect, investigate, and prevent fraud, money laundering, and other illicit activity.
To communicate with you about your Account, transactions, and support requests.
To improve the Platform's performance, security, and user experience.
To comply with applicable laws, regulatory requests, and court orders.
To send you service updates, and, where you have opted in, marketing communications.
7. Legal Basis for Processing
We process your Personal Data on the following bases under the Kenya Data Protection Act, 2019:
Contractual necessity: processing needed to perform our contract with you (the Terms of Service), such as executing a transaction you request.
Legal obligation: processing required to comply with AML/KYC, tax, and other regulatory requirements.
Legitimate interests: processing that supports operating and securing the Platform, such as fraud prevention and service improvement, balanced against your rights and interests.
Consent: processing that depends on your opt-in, such as marketing communications, which you may withdraw at any time.
8. Cookies and Tracking Technologies
8.1 Types of Cookies We Use
Strictly necessary cookies: required to keep you signed in and to secure your session.
Functional cookies: remember your preferences, such as language or display settings.
Analytics cookies: help us understand how the Platform is used, in aggregate, so we can improve it.
8.2 Managing Cookies
You can manage cookie preferences through your browser or device settings. Disabling strictly necessary cookies may prevent you from signing in or transacting on the Platform.
9. How We Share Your Information
Ognimohub does not sell, rent, or share your Personal Data with third parties for their own commercial or marketing purposes. We do share information, on a need-to-know basis and under appropriate confidentiality and data protection terms, with:
Payment Service Providers (PSPs) and banking partners, to process payments and transfers.
Licensed remittance partners, to complete cross-border transfers.
Identity verification vendors, to complete KYC checks.
Cloud hosting and infrastructure providers, to operate the Platform securely.
Regulators, law enforcement, and financial intelligence units, where required by law or a valid legal process.
Professional advisers and auditors, bound by confidentiality obligations.
A successor entity, in the event of a merger, acquisition, or sale of all or part of our business, subject to equivalent privacy protections.
10. International Data Transfers
Where we or our service providers process data outside Kenya — for example, using cloud infrastructure hosted abroad — we take steps to ensure the data receives a level of protection consistent with this Policy and the Kenya Data Protection Act, 2019, including through contractual safeguards (such as standard contractual clauses) with the recipient, and by limiting transfers to jurisdictions or entities with adequate data protection standards.
11. Data Retention
We retain Personal Data for as long as your Account is active, and afterward for as long as necessary to meet legal, regulatory, and accounting obligations. Retention periods vary by data category:
KYC and identity records: retained for a minimum of five (5) to seven (7) years following Account closure or the date of the relevant transaction, in line with our AML/KYC Policy.
Transaction and financial records: retained for a minimum of five (5) to seven (7) years, consistent with applicable financial services and tax law.
Customer support communications: retained for up to three (3) years, or longer where relevant to an open dispute or compliance matter.
Marketing preferences and optional profile data: deleted or anonymized within ninety (90) days of Account closure, or upon withdrawal of consent.
Further detail on retention after Account closure is set out in our Account Deletion Policy.
12. Data Security
We employ industry-standard technical and organizational safeguards to protect your Personal Data against unauthorized access, disclosure, alteration, and destruction, including:
Encryption of data in transit using TLS/SSL, and encryption of sensitive data at rest.
Role-based access controls, limiting internal access to Personal Data on a need-to-know basis.
Regular security testing and monitoring of our systems.
Mandatory data protection and security training for employees and contractors who handle Personal Data.
12.1 Data Breach Notification
In the event of a data breach likely to result in a risk to your rights and freedoms, Ognimohub will notify the Office of the Data Protection Commissioner (ODPC) and affected individuals without undue delay, in accordance with the Kenya Data Protection Act, 2019.
13. Automated Decision-Making and Profiling
Ognimohub may use automated tools — including risk-scoring and fraud-detection models — to assess transactions, flag suspicious activity, or determine eligibility for certain investment or credit-related features. Where an automated decision produces a legal or similarly significant effect on you (such as a declined transaction or Account restriction), you may request human review by contacting support@ognimohub.com.
14. Your Rights
Subject to applicable law, you have the right to:
Access: request a copy of the Personal Data we hold about you.
Correction: request correction of inaccurate or incomplete data.
Deletion: request deletion of your data, as set out in our Account Deletion Policy.
Objection and restriction: object to, or request restriction of, certain processing, including direct marketing.
Portability: request a portable copy of data you provided to us, in a structured, commonly used format.
Withdraw consent: withdraw consent, where processing is based on consent, without affecting processing carried out before withdrawal.
To exercise any of these rights, contact support@ognimohub.com. We will respond within the timeframes required by applicable law (generally within thirty (30) days), and we may need to verify your identity before actioning a request. We do not charge a fee for a reasonable first request.
15. Marketing Communications
Where you have opted in, we may send you promotional messages about new features, investment products, or offers. You may opt out at any time via in-app settings, by replying “STOP” to SMS messages, or by contacting support@ognimohub.com. Opting out of marketing does not affect service or transactional communications, which are necessary for operating your Account.
16. Children's Privacy
The Platform is not directed at children, and we do not knowingly collect Personal Data from anyone under the age of majority under applicable law. If we learn that we have collected data from a child without appropriate consent, we will take steps to delete it promptly.
17. Third-Party Links and Services
The Platform may contain links to third-party websites or services, including merchant storefronts and remittance partner portals. We are not responsible for the privacy practices of those third parties, and encourage you to review their privacy policies before providing them with your data.
18. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. Material changes will be communicated in-app or by email, and the “Last Reviewed” date at the top of this Policy will be updated accordingly. Continued use of the Platform after a change takes effect constitutes acceptance of the revised Policy.
19. Complaints
If you believe we have not handled your Personal Data in accordance with this Policy or applicable law, you may contact us first at support@ognimohub.com so we can attempt to resolve the matter. You also have the right to lodge a complaint directly with the Office of the Data Protection Commissioner (ODPC), Kenya.
20. Contact Us
For questions, concerns, or requests relating to this Privacy Policy, contact us at support@ognimohub.com, +254 745 497444, or Pioneer House, Kenyatta Avenue, Nairobi, Kenya.