1. Scope and Applicability
This Policy applies to all users interacting with the SplitFair ecosystem, including Brands, Creators, Agencies, Collaborators, and Platform Administrators. It conforms to international data protection standards and regional African privacy legislation, including the Uganda Data Protection and Privacy Act (2019), Kenya Data Protection Act (2019), and Nigeria Data Protection Act (2023).
2. Information We Collect
Identity and KYB/KYC Information
- Basic profile details: Legal entity name, registration numbers, representative names, email addresses.
- Didit Verification data: Government-issued identification, corporate registration certificates, and beneficial ownership records.
Financial and Escrow Records
- Transaction histories, contract milestone timestamps, double-entry ledger allocation proofs, and payout logs.
- Payment routing metadata: Mobile money MSISDN prefixes (MTN MoMo, Airtel Money) and bank settlement identifiers. (SplitFair does not store raw credit card credentials).
3. Legal Bases for Processing
| Processing Activity | Legal Basis |
|---|---|
| Account Registration & Didit KYB | Compliance with Anti-Money Laundering (AML) laws |
| Escrow Custody & Split Allocations | Performance of a contract |
| 72-Hour Fraud Hold Checks | Legitimate security interest (fraud prevention) |
| Dispute Resolution Arbitration | Contractual necessity |
4. Data Retention & Archival
To comply with regional financial and auditing obligations, escrow transaction ledgers and contract proofs are archived securely for seven (7) years. Deliverable files and temporary download grants expire automatically according to contract configurations.
5. Data Protection Officer Contact
To exercise your statutory rights (access, rectification, erasure, objection), please contact our Data Protection Officer at privacy@splitfair.africa.
Need formal compliance documentation?
Our legal and security engineering team can assist with vendor questionnaires.