Privacy Policy

1. Who We Are

SunKazi is a brand of Khakali Technologies SMC Ltd, a company incorporated in Uganda (registration number to be confirmed), with its principal place of business in Kampala, Uganda. In this policy, "SunKazi", "we", "us", and "our" refer to Khakali Technologies SMC Ltd.

We operate the SunKazi platform — a PAYGo solar equipment financing service for entrepreneurs in East Africa. You can contact our data team at privacy@sunkazi.com.

2. Data We Collect

We collect the following categories of personal data:

• Identity data: full name, national ID number (where required for KYC), date of birth.
• Contact data: mobile phone number, email address (optional), physical location / business address.
• Business data: type of business, business location, estimated income.
• Payment data: mobile money account number, transaction history. We do not store full mobile money PINs or passwords.
• Device and usage data: IP address, browser type, pages visited, timestamps — collected automatically when you use our web platform.
• Communications data: records of messages and interactions with our agents and support team.

3. How We Collect Your Data

We collect data:

• Directly from you when you register via USSD, our web platform, or through a SunKazi field agent.
• From our field agents who complete your onboarding assessment.
• Automatically via cookies and similar technologies when you visit our website (see Section 8).
• From mobile money operators to verify payment transactions.

4. Why We Use Your Data

Purpose	Legal basis
Register you on the SunKazi platform and verify your identity (KYC)	Contract performance
Deliver and install equipment at your premises	Contract performance
Process mobile money payments and maintain your payment record	Contract performance
Send payment reminders and account notifications via SMS	Contract performance / Legitimate interest
Provide customer support and after-sales service	Contract performance
Assess creditworthiness for PAYGo financing	Legitimate interest
Improve our platform and services	Legitimate interest
Comply with anti-money-laundering and KYC regulations	Legal obligation
Send marketing updates about new products (opt-in only)	Consent

5. Who We Share Your Data With

We share your personal data only with:

• Mobile money operators (MTN Mobile Money, Airtel Money) to process your payments.
• Field agents and distribution partners (e.g. Toto Safi in Rwanda) who onboard and service customers in your area — limited to the data they need to perform their role.
• Equipment suppliers (e.g. Omnivoltaic) for delivery and warranty purposes.
• Technology service providers who host and operate our platform infrastructure, under data processing agreements that require them to protect your data.
• Regulators and law enforcement where we are legally obliged to disclose.

We do not sell your personal data to third parties.

6. How Long We Keep Your Data

We retain your personal data for as long as your account is active and for a minimum of five (5) years after your final payment or account closure, to comply with financial record-keeping obligations under Ugandan law. Where data is no longer needed, we securely delete or anonymise it.

7. Your Rights

Under Uganda's Data Protection and Privacy Act 2019, and where applicable under the Rwanda Law No. 058/2021 on Personal Data Protection, you have the right to:

• Access the personal data we hold about you.
• Correct inaccurate or incomplete data.
• Delete your data (subject to our legal retention obligations).
• Restrict processing in certain circumstances.
• Object to processing based on legitimate interest.
• Withdraw consent at any time where processing is based on consent.
• Lodge a complaint with the Personal Data Protection Office (Uganda) or the Rwanda Utilities Regulatory Authority (RURA).

To exercise any of these rights, contact us at privacy@sunkazi.com.

8. Cookies

Our website uses cookies and similar technologies. We use:

• Essential cookies: required for the website to function (e.g. language preference, country selection). These cannot be disabled.
• Analytics cookies: to understand how visitors use our site. We use anonymised data only and you can opt out at any time.

When you first visit our site, we ask for your consent to non-essential cookies. You can change your preferences at any time by clicking "Cookie Settings" in the footer.

9. Data Security

We apply appropriate technical and organisational measures to protect your data, including encryption of data at rest and in transit, access controls, and regular security reviews. We require all third parties who process data on our behalf to apply equivalent standards.

10. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by SMS or by a prominent notice on our website. The "Last updated" date at the top of this page shows when the policy was last revised.

11. Contact Us

For any questions about this Privacy Policy or your personal data, contact:

Khakali Technologies SMC Ltd
Plot 10 Nizam Rd, Jinja, Uganda
Email: privacy@sunkazi.com