Service Provider Privacy Policy | Nusuria Technologies

1. Introduction

Nusuria Technologies ("Company", "we", "us", or "our") operates as a technology-enabled facilitation platform. This Privacy Policy explains how we collect, use, and protect personal data when you use our mobile application branded as imergency-provider ("imergency"), web systems, artificial intelligence, panic button widget, related digital services, or associated technologies (collectively, the "Platform").

This Policy is issued in accordance with the Kenya Data Protection Act, 2019, and applies to all users of the Platform.

2. Data We Collect

To facilitate emergency and non-emergency services, we collect the following:

Identification Data: Legal/Business names, individual names, ID or passport images & numbers, professional titles, driver's license images & numbers, insurance certificate images & numbers, place of business photographs, proof of business documents, and passport-size photos.
Contact Information: Primary and secondary phone numbers, as well as email addresses.
Service Data: Service categories and areas of operation.
Usage Data: Performance metrics, response times, and Customer ratings.
Location Data: Precise real-time geolocation used to identify and route the nearest Service Provider to a Customer's location for all requested services.

3. How We Use Your Data

Service Facilitation: Connecting Customers with Service Providers.
Platform Integrity: Monitoring performance to ensure prompt and professional responses.
Safety: Protecting Customers and the public in urgent, time-sensitive situations.

Vital Interests & Emergency Override

Pursuant to Section 30 of the Kenya Data Protection Act, we may process your personal data, including location data, without a contemporaneous request or explicit consent where we reasonably believe such processing is necessary to protect your vital interests or the life of another person. This may include circumstances such as medical incapacitation, kidnapping, imminent danger, or other emergencies.

4. Data Sharing and Disclosure

Between Users: Service Provider information is shared with Customers to facilitate service delivery.
Data Masking: Sensitive identifiers are partially masked to protect user privacy.
Legal Compliance: Data may be shared to comply with Kenyan laws, regulations, and licensing requirements.
Verification & Compliance: Where required, we may securely share limited and relevant personal data with trusted third-party verification, background screening, compliance, or security partners strictly for these purposes. All third parties are subject to appropriate confidentiality, data protection, and security obligations.
Law Enforcement & Public Safety: We may share your information with the National Police Service, emergency security responders, emergency rescue service providers, or other relevant government agencies to: (a) protect life in an emergency context; (b) comply with the Data Protection Act (Section 35) and the Criminal Procedure Code; or (c) meet national security or public order requirements.

5. Data Protection Obligations

Provider Responsibility: Service Providers must use Customer data solely for service delivery and are prohibited from unauthorized storage or misuse.
Strict Confidentiality: Unauthorized sharing of data may result in immediate suspension or permanent removal from the Platform.

6. International Data Transfers & Cross-Border Processing

6.1 Data Residency and Hosting: The Service Provider acknowledges that Nusuria Technologies utilizes secure cloud-based infrastructure to host the Platform. Consequently, personal data collected in the Service Provider's home country may be transferred to, stored, and processed in a country other than the one in which it was initially collected (e.g., on servers located in South Africa, Europe, or the United States).

6.2 Standard of Protection: Where personal data is transferred across international borders, we ensure that the recipient country or the specific third-party processor provides an "adequate level of protection" substantially similar to the data protection laws of the Republic of Kenya.

6.3 Safeguards: To facilitate these transfers, we employ appropriate legal safeguards, including:

Standard Contractual Clauses (SCCs): Binding agreements with cloud providers that mandate strict data security.
Data Localization Compliance: In jurisdictions where local law requires specific data sets to remain within national borders, we shall utilize regional "data zones" to ensure compliance.

6.4 Consent to Transfer: By using the Platform and accepting these Terms, the Service Provider expressly consents to the transfer of their personal data outside of their home jurisdiction for the purposes of service facilitation, system maintenance, and security.

7. Service Provider Data & Authorized Users

Where a Service Provider is a company, organization, or other legal entity, any personal data (including phone numbers, email addresses, or identification details) provided during onboarding or account administration may relate to an authorized employee, agent, or representative acting on behalf of the Service Provider.

Such data is collected and processed solely for purposes of account creation, verification, communication, compliance, and platform operations. The platform account, associated service history, and operational data are owned and controlled by the Service Provider entity, and not by any individual personnel.

The Service Provider is responsible for ensuring that it has obtained all necessary consents and authorizations from its personnel whose personal data is provided to us and for notifying us of any changes to authorized users or contact details.

8. Data Security & Breach Notification

In the event of a security breach that compromises the confidentiality, integrity, or availability of your personal data, we will take immediate steps to contain the breach. We will notify the relevant Data Protection Regulatory Authority (such as the ODPC in Kenya) within the legally mandated timeframe (typically 72 hours). We will also notify affected users without undue delay if the breach is likely to result in a high risk to their rights and freedoms, providing guidance on steps they can take to protect themselves.

9. Your Rights

Under the laws of the Republic of Kenya, you have the right to:

Access the personal data we hold about you.
Correct inaccurate or misleading information provided during onboarding.
Request deletion of your data, subject to legal retention requirements.

10. Security & Limitation of Liability

We implement technical measures to protect your data; however, we are not liable for indirect or consequential damages arising from third-party actions. Service Providers agree to indemnify us against liabilities arising from their own negligence regarding data handling.

11. Updates & Amendments

We may update this Privacy Policy from time to time to reflect legal, operational, or technological changes. Updated versions will be made available within the app and on our official website, with the effective date clearly indicated. Continued use of the Platform constitutes your acceptance of the updated policy.

12. Contact

For questions, concerns, or data-related requests, please contact us through the support details provided within the Platform.