Vowel

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Privacy Policy

Effective Date: 

1. Who We Are

Vowel Holdings Limited is a legally registered company in Kenya, specializing in professional debt collection services. Our role is to act as an intermediary between creditors (those you owe money to) and debtors (those who owe it), ensuring debts are recovered efficiently and fairly.

2. What Information We Collect

To do our job, we need certain details about you. Here’s what we might collect:
  • Basic Details: Your full name, national ID number, passport number, or other identifiers. For example, if your creditor gives us your ID number to confirm you’re the right person, we’ll use that.
  • Contact Info: Mobile or landline numbers, email addresses, physical addresses (like your home or P.O. Box), or even next-of-kin details if provided and relevant. This helps us reach you about your debt.
  • Debt Details: Specifics about what you owe—loan amounts, account numbers, repayment history, interest rates, or default dates—usually handed to us by creditors or updated as we work with you.
  • Communications: Records of our interactions, like emails you send us, letters we exchange, SMS replies, or call logs. If we record calls (only where Kenyan law allows), we’ll let you know upfront.
  • Sensitive Info: Things like your job status, income level, or bank details, but only if you share them voluntarily (e.g., to set up a payment plan) or if they’re legally required for recovery.
  • Third-Party Data: Information from lawful sources, like credit scores from a credit bureau or court records if a case is involved.

How We Collect It

We gather this data in three main ways:
  • From You: When you answer our calls, reply to letters, negotiate payments, or dispute a debt. For instance, if you call us to correct your address, we’ll note it.
  • From Creditors: The people or companies you owe—like a bank or retailer—pass us your details when they hire us. This might include your loan contract or payment history.
  • From Others: We might use public records or licensed credit bureaus if it’s legal and necessary to find you or verify your debt.
We’re careful to collect only what’s essential for our work—nothing excessive or unrelated.

3. Why We Use Your Information

We process your data for clear, specific reasons tied to debt collection:
  • Debt Recovery: To track down what’s owed, negotiate with you, set up payment plans, or, if needed, support legal action (like filing a case under the Civil Procedure Act).
  • Communication: To send you letters, emails, SMS, or call you about your debt—whether it’s a reminder, a settlement offer, or a response to your questions.
  • Verification: To make sure we’ve got the right person and the right facts. For example, checking your ID against creditor records avoids mix-ups.
  • Legal Compliance: To meet Kenyan laws—like submitting reports to the ODPC, filing court documents, or keeping records for audits.
  • Business Protection: To prevent fraud (e.g., if someone pretends to be you) or enforce our rights, but only if it’s fair and doesn’t override your privacy.

What We Won’t Do

We don’t use your data for ads, sell it to marketers, or stray from debt collection unless you explicitly say it’s okay or a law requires it.

4. Legal Basis for Processing

We process personal data for the following lawful purposes:
  • Your Consent: If you agree—like saying yes to SMS reminders —we’ll respect that. You can always change your mind later.
  • Contracts: We process data to fulfill deals with creditors (e.g., their contract to collect your debt) or agreements with you (e.g., a payment schedule).
  • Legal Obligations: Laws like the Consumer Protection Act or court orders might require us to handle or share your data—for instance, reporting a default to regulators.
  • Legitimate Interests: We use data to run our business effectively, like confirming your identity or chasing a debt, but only if it’s reasonable and doesn’t unfairly harm you.

5. How We Keep Your Data Safe

We take serious steps to protect your information from risks like hacking, leaks, or loss:

  • Tech Tools: We use encryption (scrambling data so only we can read it), secure servers, and backups. At least one copy stays in Kenya, as required by law.

  • Access Limits: Only trained staff with a need-to-know can see your data, and they sign strict confidentiality agreements. For example, our IT team can’t peek at your file unless they’re fixing a system issue.
  • Monitoring: We run regular checks—think of them as “security health checks”—to spot weaknesses and fix them fast.
  • Physical Safety: Paper files (if any) are locked in secure cabinets, and our offices have controlled access.

6. Who We Share Your Data With

We don’t spread your info around carelessly. Sharing only happens with:
  • Creditors: The clients who hired us get updates, so they know how things are going.
  • Authorities: Courts, police, or the ODPC might need your data if there’s a legal order, investigation, or compliance check.
  • Support Teams: Trusted partners—like IT companies hosting our servers, lawyers filing claims, or call centers—help us work. They’re bound by contracts to keep your data secret and safe.

7. Your Rights

You’ve got power over your data. You have the following rights
  • Right to be Informed: To know how your data is being used (as outlined in this policy).
  • Right to Access: To request a copy of the personal data we hold about you.
  • Right to Rectification: To correct inaccurate or incomplete data.
  • Right to Erasure: To request deletion of your data where it is no longer necessary or was unlawfully processed.
  • Right to Object: To object to processing, including for direct marketing purposes.
  • Right to Data Portability: To receive your data in a structured, commonly used format.
  • Right to Restrict Processing: To limit how we use your data in certain circumstances.
  • Right to Withdraw Consent: To withdraw consent where it was the basis for processing.
To exercise these rights, contact us using the details in Section 12. We will respond within 30 days, as required by law, unless an extension is permitted.

How to Make It Happen

Contact us (Section 11) by phone, email, or letter. Tell us what you want (e.g., “I’d like to see my data” or “Stop calling me”). We’ll:
  • Reply within 30 days, sometimes sooner.
  • Ask for ID if we’re unsure it’s you (to keep your data safe).
  • Explain if we can’t fully comply (e.g., legal rules require keeping some records).
    No fee unless your request is super complex—then we’ll let you know why.

8. How Long We Keep Your Data

We don’t hoard your info—it’s kept only as long as necessary:
  • Debt Collection: Until the debt’s paid, settled, or our creditor’s contract ends.
  • Legal Needs: The Limitation of Actions Act says some debts can be chased for 6 years, so we might hold records that long—or longer if a court case drags on.
  • Compliance: We keep some data (e.g., payment logs) to prove we followed ODPC rules if asked.  

When it’s time, we delete it securely or remove details that identify you.

9. Our Debt Collection Promise

As a debt collection company, we adhere to fair practices:
  • We will not use abusive language, threats, or harassment to collect debts.
  • We will respect your privacy and not disclose your debt details to unauthorized third parties.
  • We will provide accurate information about your debt and allow you to dispute it if incorrect.
  • All communications will be conducted respectfully and within reasonable hours, as permitted by law.

10. If You’re Unhappy

We aim to get it right, but if we slip up:
  • Start With Us: Reach out (Section 11) with your issue—say, “You called too much” or “My data’s wrong.” We’ll investigate and fix it fast, usually within a week or two.
  • Escalate It: Still not happy? Contact the Office of the Data Protection Commissioner (ODPC)
We are committed to addressing your concerns promptly and fairly.

11. How to Reach Us

We’re here for you—questions, requests, or feedback? Contact our Data Protection Officer.
Call or write—we’ll respond quickly and clearly. 

12. Updates to This Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. The updated version will be posted on our website with the effective date. Significant changes will be communicated to you directly where required by law.

13. Our Commitment

Vowel Holdings Limited is registered with the Office of the Data Protection Commissioner and operates in full compliance with the Data Protection Act, 2019, its regulations, and other Kenyan laws governing debt collection.