- The BEMOBILE service is provided by NRG MEDIA Ltd, a company registered in Kenya, registered number P051678278D and having its registered address at LeMac Building on Church Road, PO Box 38532-00623 Nairobi Kenya.
- We are committed to protecting your privacy. All personal information collected by us is kept in the strictest confidence. We will not share, or sell any personal information to any third party unless;
- We are compelled or required to do so by law.
- Directed thus by the account user.
- Age Requirement – You must be at least 18 years of age to use BEMOBILE inclusive of the restricted services.
- Minor users of 13years and above can only access Bemobile if under the permission and supervision from their parents/guardians.
Information We Collect and Why
BEMOBILE must collect some information to operate, understand, support, and market our service. The information we collect will depend on how you use our service, and will be collected when you install, login, or use our services.
Information You Provide
- Your Account – To create a BEMOBILE account you provide your mobile phone number which will be used as the main account username. You also provide us with the names and phone numbers in your phone’s contacts, both those already using BEMOBILE and your other contacts, so our service can find any contacts you can call and message for free, and notify you of any new contacts joining BEMOBILE.
- You may also choose to supply your name, address and email address and a profile picture.
- If you use BEMOBILE virtual phone numbers, then you will provide a profile name for each virtual number, and optionally a profile picture.
- Payments – If you make payment to access paid services, we will ask for and retain certain information. This is so we can process your payment, process refunds, and meet our obligations to provide itemised billing and invoices:
- Credit/Debit card: Your card details will be collected by our third party payment provider. All card information is transmitted directly between your device and our payment provider using SSL secure encryption. In addition, we will collect the billing name and address of your card, and email address, to help decide if you are required to pay Value added tax and other tax obligations under the Kenyan regime, and to provide you with an invoice.
- Apple iTunes: Your payment is made direct with Apple iTunes over an encrypted connection. We receive an electronic receipt from your device on a successful payment that identifies your payment via unique tokens, and includes no personal data.
- Customer Support – If you contact our customer support you will provide us with information related to your use of our Services, including your account phone number and email address to help assist and communicate with you.
Information We Automatically Collect
- Calls – We do not store information on free online calls in the normal course of supplying our service to you.
- If you make calls to phone numbers, then we store the time, originating phone number, recipient phone number and duration of the calls to provide itemised billing and comply with regulations.
- Calls records (time, originating number, recipient number and duration) of received calls to BEMOBILE virtual numbers are also retained to provide itemised billing where charged, and comply with regulations.
- SMS and Chat Messages – We store your free chat messages you send and receive on our servers, so that if you reinstall the app or change phone, the app will pick up your chat messages again. You can delete chat messages within the app, and they will be deleted from our systems.
- We store your SMS messages to phone numbers on our servers, so that if you reinstall the app or change phone, the app will pick up your messages again. You can delete SMS messages within the app, and the message content will be deleted from our systems. We will retain the time, originating phone number, recipient phone number, and number of SMS parts to provide itemised billing and comply with regulations.
- SMS records (time, originating number, recipient number, and SMS parts) of SMS received to BEMOBILE virtual numbers are retained to comply with regulations.
- Device Information – When you install or use our service, or when you contact customer support via our app, we collect information on your device’s hardware model and operating system, the BEMOBILE app version, browser information, and your internet connection IP address.
- Service Usage Data – We collect service-related diagnostics and logs about your activity on our service, that includes app connection log files and crash reports, and website logs. This information is only held for a short time period for diagnosing issues.
- We also retain time and IP connection information on when you first registered with our service, and when you last connected.
- Like most websites, we also use Google Analytics to track user interaction. We use this data to determine the number of people using our website, to better understand how they find and use our web pages, and to see their journey through our website. Google Analytics records data such as your geographical location, device, internet browser and operating system, and your internet connection IP address. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website.
- Your web browser allows you to delete cookies and disable them in the future. Should you delete or disable cookies, you may find that some of our services are unavailable to you.
- Third-Party Service Providers – We partner with third-party service providers across the globe to help us deliver, understand, support, and market our service. For example, we work with companies to terminate and receive calls and SMS, provide virtual phone numbers, process payments, distribute our apps, provide our infrastructure, help us understand how our service is used, and communicate with you. We provide these third-party services only with the information absolutely necessary to deliver the part of the service they provide for us.
- Third-Parties – All personal information collected by us is kept in the strictest confidence. We will not share, or sell any personal information to any third party unless required to do so by law.
How We Use Information
BEMOBILE uses the information we collect to operate, understand, support, and market our service.
- Our Service – We use the information we collect to operate our service, provide reporting for financial accounting and taxation liabilities, analyse how our service is used, fix and improve our service, and provide customer support.
- Communications from BEMOBILE – We may use either in-app messaging or email (if provided) to advise you of our services, and inform you of updates to our policies and terms.
- If you have opted-in, we may also provide you with marketing for our services. You can change your marketing preferences in the customer area of our website, under the account settings.
- Your Calling and Messaging – When you call or message, you share your phone number (caller ID) or your BEMOBILE virtual number with the recipient(s). With chat and SMS messaging you will also share the content of your message with the recipient(s).
- Third-Party Service Providers - We partner with European GDPR and EU-US Privacy Shield compliant third-party service providers to help us deliver, understand, support, and market our service.
- Security – We may monitor accounts and usage for suspicious activity to provide security and safety on our service, and to prevent abuse, fraud, illegal usage, and breaches of our terms and conditions.
How Long We Keep Information
We store your information until it is not needed to provide you a service, or until your account is deleted. When information is deleted will depend on the type of information, why it has been collected and used, and any legal or operational retention requirements.
- We take all aspects of information security seriously. We store the minimum of data necessary to provide the service to you, while complying with our legal obligations. We apply access controls throughout all our systems, and use only trusted third party providers. To protect customer privacy, access to information by employees is restricted.
- Should we have a data breach or be made aware of such at one of our third party providers, we will notify this to the ICO within the prescribed timescales of the GDPR.
GDPR for European Region Users
- From May 2018 the General Data Protection Regulation (GDPR) will apply to all data we hold about our customers
- Your Rights
- Customers and subscribers have clear rights under GDPR:
- The right to be informed about the personal data that is being held and processed
- The right of access to personal data via a Subject Access Request
- The right to rectification of personal data if inaccurate, incomplete, or out of date
- The right to erasure of data where there is no lawful reason for its continued processing
- The right to restrict processing of data where information is inaccurate or there is an objection to the lawfulness of the processing
- The right to portability of personal data to reuse elsewhere
- The right to object if no legitimate reason exists for the processing of data
- The right to check or challenge automated decision making and profiling
- Please refer to the GDPR regulation or ico.org.uk for full details of these items and the conditions under which it may be appropriate to contact us or make an access request.
- Our Basis for Processing Information
- We collect, use, and share the information detailed above to:
- To provide our service under our Terms and Conditions.
- With your consent, which you can withdraw at any time.
- For our own legitimate interests, which is to provide a reliable, safe and secure, legal, telecoms service to our users and partners, unless those interests are overruled by your interests or fundamental rights and freedoms for data protection.
- To comply with our legal obligations;
- To protect yours or others vital interests
- Updating and Deleting Your Information
- We store your information until it is not needed to provide you a service, or until your account is deleted. When the information is deleted will depend on the type of information, why it has been collected and used, and any legal or operational retention requirements.
- You can delete SMS content and chat messages within the BEMOBILE app. The customer area of the BEMOBILE website also provides you a view of the personal information we store, and the ability to update some of this information.
- If you have any questions regarding your personal information, or would like to exercise any of your rights under GDPR, such as accessing, updating or deleting your data, then please
- contact us at firstname.lastname@example.org.
- For general enquiries, or to have your data updated or deleted, please contact our customer support team by email at email@example.com.
- The DPO
- NRG MEDIA LTD
- You also have the right to lodge a complaint with BEMOBILE’s lead supervisory authority, the Kenya’s data regulation office Office (https://www.odpc.go.ke/), or your local supervisory authority.
- BEMOBILE Holding Limited is registered with the office of the data protection Commissioner's Office Kenya as a data controller.
- Users Outside of the Kenyan Region
- If you have any enquiries, or to have your data updated or deleted, then please contact us at firstname.lastname@example.org, or in writing to:
- NRG MEDIA LTD, address