PandaPanda Privacy Policy

Last Update: 12 May 2025

Welcome to PandaPanda! We value your privacy and are committed to protecting your personal information. This Privacy Policy explains how we collect, use, store, and protect your data when you use our investment app (the “App”) and related services.

1. Who We Are

SMART SAVE PANDAPANDA KENYA LIMITED (“we”, “us”, “our”) is the provider of this App. Our services allow users to invest into U.S. and Kenya stocks, cryptocurrency as well as other financial instruments, subject to Know Your Customer (KYC) and regulatory requirements. SMART SAVE PANDAPANDA KENYA LIMITED is the Data Controller of your personal data for the purposes of Kenya’s Data Protection Act, 2019, unless otherwise stated.

2. What Information We Collect

We may collect the following types of personal data:

• a) Personal Identification Information — Full name, date of birth, nationality and residency, identification documents (passport, national ID)
• b) Contact Information — Phone number, email address, residential address
• c) Financial & KYC Information — Source of funds, tax identification number, bank or mobile money account details, investment preferences, employment information
• d) Device and Usage Information — IP address, app usage logs, device identifiers, browser type
• e) Biometric Data — Facial recognition images via KYC provider

3. How We Collect Your Data

• Direct input during registration and app usage
• Document uploads
• Automated processes (cookies, telemetry)
• Third-party KYC providers (e.g. Sumsub)

4. How We Use Your Data

• Create and manage your account
• Comply with legal and regulatory obligations
• Prevent fraud
• Execute trades and transactions
• Provide customer support
• Improve app performance

5. Legal Basis for Processing

• Contractual necessity
• Legal obligation
• Legitimate interests
• Your consent

6. Automated Processing

PandaPanda may use automated decision-making systems for operational purposes without human intervention.

7. Data Breach Notification

If a breach poses a risk to your rights, we will notify you and the Office of the Data Protection Commissioner without undue delay.

8. Data Sharing

• Licensed brokerage partners
• Payment processors
• KYC providers
• Cloud providers
• Regulators when required

9. Data Transfers

We ensure appropriate safeguards for international data transfers.

10. Security Measures

• Encryption
• Multi-factor authentication
• Access controls
• Regular audits

11. Your Rights

• Access your data
• Correct inaccuracies
• Request deletion
• Restrict processing
• Withdraw consent

Contact: dpo@xxxxxxx.com

16. Contact Us