Privacy Policy

CareFund is a digital fundraising product and platform of WezaCare Solutions, a Kenyan non-profit company limited by guarantee. CareFund is not a separate legal person.

Purpose, controller and scope

Controller identity

WezaCare Solutions operates CareFund and is the controller where it determines why and how personal data is processed. A Beneficiary Organisation may be an independent or joint controller for data it determines to collect/use through its Campaigns. Paystack and other providers act according to their own legal roles and agreements.

Scope

This Policy covers carefund.ke, accounts, campaigns, donations, beneficiary dashboards, support, compliance/fraud review, communications, analytics and related offline interactions.

Law

Processing is governed principally by the Constitution of Kenya, Data Protection Act 2019 and applicable Regulations and ODPC guidance. GDPR standards are applied where GDPR applies or as a contractual benchmark; this does not falsely represent that every processing activity is subject to EU law.

Principles and accountability

Principles

CareFund applies lawfulness, fairness, transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity/confidentiality and accountability.

Privacy by design

New features, especially child-facing content, profiling, new payment integrations, biometrics, sensitive data or large-scale monitoring, require privacy review and where legally required a DPIA before launch.

Records

WezaCare maintains processing records, processor/vendor records, retention rules, breach records, data-subject request logs and appropriate evidence of consent where consent is relied upon.

Data collected

Donors

Name, contact details, account identifiers, donation history, campaign choices, public anonymity preference, communication preferences, device/log data, fraud/risk indicators and limited payment metadata. Full card credentials should remain with the PSP and must not be stored by CareFund unless specifically designed and compliant.

Beneficiaries

Organisation details, officials, directors/controllers, authorised users, IDs where necessary, contact details, tax/licence records, bank/PSP details, KYB evidence, campaign content, safeguarding information and audit/compliance records.

Campaign subjects

Names, stories, images, video, location at an appropriate level, needs, impact information and other data strictly necessary for the campaign. Sensitive data requires heightened necessity, lawful basis and safeguards.

Technical data

IP address, browser/device information, timestamps, authentication events, cookies/analytics choices, security logs and interaction data.

Lawful bases and purposes

Purposes

Account administration; beneficiary verification; campaign publication; donation facilitation; receipts/statements; fraud/AML/sanctions controls; safeguarding; customer support; security; legal compliance; audit; dispute handling; analytics; service improvement; and marketing where lawful.

Lawful bases

CareFund relies as appropriate on performance of contract, legal obligation, legitimate interests balanced against rights, consent, and other lawful bases available under Kenyan law. Sensitive personal data receives the additional conditions and safeguards required by law.

Consent

Consent must be specific, informed and demonstrable where relied upon and may be withdrawn prospectively. Withdrawal does not invalidate prior lawful processing and may not override legal retention duties.

Children and vulnerable persons

Best interests

Processing children’s data must be in the child’s best interests and limited to what is genuinely necessary. Fundraising convenience does not justify excessive exposure.

Parent or guardian authority

Where consent is the basis for processing a child’s data, CareFund requires verifiable parent/legal guardian consent consistent with Kenyan law and ODPC guidance. Beneficiaries must evidence authority and relationship.

Separation from case management

Child case-management, medical, safeguarding or social-work records must not be repurposed into fundraising content merely because WezaCare or a partner can access them. Fundraising requires a separate purpose assessment and appropriate lawful basis.

Publication safeguards

CareFund may require anonymisation, pseudonyms, obscured locations, image restrictions, removal of diagnoses or family details, and may refuse publication notwithstanding consent where exposure is not in the child’s best interests.

Removal and retention

Public child content should be removed or de-indexed when no longer necessary, subject to limited legal/audit retention. Internal evidence must be access-controlled.

Donor anonymity and transparency

Public anonymity

A Donor may be displayed as anonymous while CareFund and the PSP retain transaction/account information required for service, fraud prevention, accounting or law.

Beneficiary visibility

CareFund will define what donor information is shared with Beneficiary Organisations. Beneficiaries may use donor information only for disclosed purposes and must not sell, scrape or independently market to donors without an appropriate lawful basis.

Repeat donors

Registered donors may receive donation histories or statements. These records are account services and do not establish tax deductibility.

Payment data and Paystack

PSP processing

Payments are processed through Paystack or another authorised PSP. CareFund should minimise payment data received and use tokenisation/hosted fields or equivalent PSP controls where available.

Role allocation

The production agreement and privacy notice must accurately state whether Paystack acts as processor, independent controller or in another role for each data flow. Contract wording must match the actual integration.

Fraud data

Risk signals may be shared with PSPs, banks, payment networks and competent authorities where necessary and lawful to prevent fraud, resolve disputes or comply with law.

Sharing and processors

Recipients

Data may be shared with Beneficiary Organisations, PSPs, hosting/cloud providers, email/SMS providers, analytics/security vendors, professional advisers, auditors, insurers, regulators, courts and law enforcement where lawful and necessary.

Processor contracts

Processors must be subject to written terms covering documented instructions, confidentiality, security, subprocessing, breach support, data-subject assistance, deletion/return and audit/assurance as required by law.

No sale

CareFund does not sell personal data as a commodity. Any materially different monetisation or advertising model requires prior legal/privacy review and notice.

International transfers

Transfer controls

Cross-border transfers must satisfy Kenyan transfer requirements and, where GDPR applies, applicable transfer mechanisms. CareFund will assess destination, recipient safeguards, contractual protections and necessity.

Cloud services

Use of global cloud, email, security or analytics services must be recorded in the vendor/data map with hosting locations and transfer safeguards.

Retention and deletion

Retention rule

Data is retained only for as long as necessary for the purpose collected, legal/accounting limitation periods, fraud/chargeback exposure, safeguarding, dispute resolution and regulatory duties.

Indicative periods

Account and donation records may be retained for statutory/accounting and dispute periods; KYB and compliance evidence for the period necessary to demonstrate due diligence; security logs for proportionate security periods; marketing data until opt-out plus suppression evidence; public campaign content only while justified.

Deletion

Deletion requests are honoured where applicable but may be refused or limited where retention is legally required, necessary for claims, fraud prevention, safeguarding or other lawful grounds. Public removal does not necessarily erase lawful internal records or backups immediately.

Security

Measures

Role-based access, least privilege, MFA for privileged accounts, encryption in transit and at rest where appropriate, secure development, vulnerability management, backups, logging, vendor due diligence, staff confidentiality and incident response.

User duties

Users must protect credentials, use approved devices/processes where required and promptly report suspected compromise.

No absolute guarantee

Reasonable security reduces risk but no system is guaranteed immune from attack; CareFund’s obligations remain those imposed by applicable law and contract.

Data breaches

Response

Suspected breaches are triaged immediately, contained, investigated, documented and remediated. The DPO/privacy lead assesses affected data, persons, likelihood/severity and notification duties.

Notification

ODPC and affected data subjects are notified within applicable statutory requirements where thresholds are met. Processors must notify WezaCare without undue delay under contract.

Evidence

Incident records must preserve chronology, decisions, notifications, remediation and lessons learned.

Data subject rights

Rights

Subject to law, individuals may request access, correction, deletion, restriction/objection, portability where applicable, withdrawal of consent and information concerning automated decisions.

Verification

CareFund may verify identity and authority before acting on a request and may refuse manifestly unfounded, excessive or legally restricted requests with reasons where required.

Complaints

Individuals may complain to WezaCare and retain the right to complain to the Office of the Data Protection Commissioner or another competent authority where applicable.

Automated risk and profiling

Risk tools

CareFund may use rules or automated signals to flag suspicious activity, but significant adverse decisions should receive human review where required by law and appropriate to risk.

No sensitive inference for fundraising

CareFund must not infer or exploit sensitive traits for targeting donors or exposing beneficiaries unless specifically lawful, necessary and approved.

Marketing and cookies

Marketing

Promotional communications require an appropriate lawful basis and an effective opt-out. Service, security and legal notices are not marketing.

Cookies

Non-essential cookies/trackers are deployed only with the consent or choice required by applicable law. A cookie notice should identify categories and controls.

Beneficiary obligations

Independent responsibility

Beneficiary Organisations are responsible for data they collect, upload, export or independently use and must comply with applicable data protection and safeguarding law.

Indemnity linkage

Privacy breaches caused by a Beneficiary’s unlawful content, instructions, disclosure or independent use may trigger its indemnity obligations under the Beneficiary Platform and SaaS Agreement and Terms.

Governance and contact

DPO/privacy lead

WezaCare shall designate responsibility for privacy governance, vendor review, DPIAs, rights requests, breach response, training and policy review.

Review

This Policy is reviewed at least annually and on material legal, platform or processing changes.

Contact

Current privacy contact details and ODPC registration particulars should be published on carefund.ke once confirmed.