We at Standard Chartered Group believe in transparency and are committed to being transparent about how we will handle personal data.
This privacy policy relates to the collection, use and disclosure of personal data, including sensitive personal data, by any member of the Standard Chartered Group, that we may collect about your child and guardian by their use of SC Junior Mobile Application and financial education within the app (“App”) under the supervision of their parent, legal guardian or guardian (“you” and “your”). Information about how we collect, use and disclose your (i.e. the parent, legal guardian's or guardian) own personal data in connection with the App, your SCB accounts, the usage of SC Junior and other services we provide is covered under your existing privacy policy applicable to your SCB relationship and account(s) and not only limited to https://www.sc.com/en/privacy-policy/
The relevant data controllers for the personal data collected through the App shall SC JUNIOR and STANDARD CHARTERED BANK KENYA LIMITED incorporated in Kenya registration number C.11/89 and whose principal office in Kenya is at Standard Chartered Head Office Chiromo, 48 Westlands Road, P.O. Box 30003-00100, Nairobi (“SCB”, “we”, “us” and “our”) and our contact details are provided at the end of this policy. We are responsible for deciding the means and purposes for processing the personal data collected via the App.
The following terms take the meaning given to them in the Kenyan Data Protection Act, No. 24 of 2019 (the “DPA”) and the regulations made thereunder from time to time: “data controller”, “data processor”, “personal data”, “sensitive personal data”, “personal data breach”, and “data protection officer”.
This privacy policy was published on 1/12/2021 and takes effect from that date.
The table below sets out what we use your child's/guardian personal data for and our lawful basis for doing so in each case.
| Processing Purpose | Lawful Basis |
|---|---|
|
To create an account for you and your child/guardian and provide the App. To sync the data provided across the family account you have set up on SC Junior App. |
Performance of a contract |
|
To verify your child's/guardian identity if you (or your child/guardian) reach out for help or support when they use the App. To help gain a better understanding of support issue(s) and troubleshoot the issue(s) or provide technical details for bug fixes with our engineers. To understand how users interact with the App so we can further develop and improve its performance and the service we currently provide. To analyse and improve the App's performance across various devices. |
Legitimate interest |
|
To provide communications you may opt-in to, such as updates on your child's/guardian activity within the account or suggestions to you and other users of the App about features that may be of interest. Where applicable law requires us to do so, to obtain your/guardian (i.e. as parent, legal guardian or guardian) consent to the collection, use, disclosure and other processing of your child's/guardian personal data. |
Consent |
|
To provide communications about key updates to the terms and conditions, privacy policies or anything else where we have a legal or regulatory obligation to do so. For the prevention, detection, investigation and prosecution of crime in any jurisdiction (including without limitation, money laundering, terrorism, fraud and other financial crimes). To comply with local or foreign law, regulations, directives, judgments or court orders, government sanctions or embargoes, reporting requirements under financial transactions legislation, and demands of any authority, regulator, tribunal, enforcement agency, or exchange body. |
Legal obligations |
|
For the provision of training and education for your child/guardian on financial literacy skills under your supervision as their parent or legal guardian. |
Protect vital interests |
In accordance with the DPA, as we will be knowingly collecting personal data from children under 18 years of age when offering the App, we must obtain verifiable parental/legal guardian/guardian consent (“Consent”).
We believe that children should be able to use the Internet in a safe, productive and efficient manner and should be afforded the highest protection available with respect to their personal data. Accordingly, as part of the sign-up process, the App ensures that the individual registering for the account is a parent, legal guardian or guardian of the child that will use the App, and that the parent, legal guardian and guardian is over 18 years of age.
We also abide by the principles of data minimisation and do not collect more personal data than is necessary from any individual in order to participate in an activity. In addition:
In order to improve the content and format of the App and the quality of our services in general, we may utilise cookies and similar tracking technologies and work with third parties to capture and analyse App usage and activity information. This includes how often the App is used, the events that occur within the App, movements on the App, aggregated usage, performance data, device location, the type of device used, and from where the App was downloaded. This is to enable us to measure user preferences, analyse trends, administer the App, and to gather demographic information about our user base as a whole. We do not link the information to any personal data within the App. To choose what cookies you want to accept select Manage cookies. To accept all cookies for the best possible experience select Accept all. If you'd like to learn more about how we use cookies and to manage your selection visit our Cookie Policy.
You, as the parent, legal guardian and guardian of the child using the App, has the choice of providing, editing or removing certain information about your child, as well as choices about how we contact you about your child's/guardian usage of the App.
You may also control the receipt of certain types of communications from us in your account and the App settings.
We do not process any of your child's/guardian personal data for marketing purposes.
To facilitate our global operations, you acknowledge and agree that we may transfer, store and process your child's/guardian personal data outside of your country of residence. Where we do so, we ensure that the appropriate safeguards are in place, and that there are commensurate data protection laws in the jurisdiction to which your child's/guardian personal data is being transferred.
The security of your child's/guardian personal data is important to us. We have technical and organisational security measures in place to safeguard your child's/guardian personal data. When using external service providers, we require that they adhere to security standards mandated by us. We may do this through contractual provisions, including any approved by a privacy regulator, and oversight of the service provider. Regardless of where personal data is transferred, we take all steps reasonably necessary to ensure that personal data is kept securely.
You should be aware that the Internet is not a secure form of communication and you must not send us (and should ensure that your child does not send us) any personal data over the Internet as this carries with it risks including the risk of access and interference by unauthorised third parties. Information passing over the Internet may be transmitted internationally (even when sender and recipient are located in the same country) via countries with weaker privacy and data protection laws than in your country of residence.
We retain your child's personal data in line with our legal and regulatory obligations and only for lawful business and operational purposes.
The DPA governs the processing of personal data and provides for the data subject's rights. You will have the following rights with regards to your child's personal data:
You have the right to be informed of the use(s) to which your child's/guardian personal data is to be put.
Subject to any applicable law, regulations and/or banking industry guidelines, you have the right to request a copy of the personal data processed in relation to your child/guardian. We may be allowed by law to charge a fee for this.
You may request at any time that we correct your child's/guardian personal data at your branch or through your relationship manager.
In some circumstances, you have the right to ask us to delete your child's/guardian personal data without undue delay, for example if we no longer have the authority to retain it or a valid reason to process it.
In some circumstances you may have the right to object to how we process your child's/guardian personal data or to withdraw your consent to the processing of your child's/guardian personal data. If you have any concerns about how we process your child's/guardian personal data, please discuss this at your branch or with your Relationship Manager. We may not be able to offer you the App if you do not want us to process the personal data we consider necessary to provide and operate the App.
In some circumstances you may have the right to restrict how your child's/guardian personal data is processed.
In some circumstances you may have the right to request the personal data given to us in a machine-readable format.
We may amend or update this privacy policy from time to time. Whenever this privacy policy is updated, the new policy shall be displayed on the App. Any continued use of the SC Junior App after notification of the changes in the privacy policy shall constitute your acceptance of these changes.
General Enquiries
If you have any questions about this privacy policy or our treatment of your child's personal data, please email us at scjunior.privacy@sc.com
By clicking below, I, being the parent/legal guardian/guardian of the child whose personal information is being processed by SCB in connection with the SC Junior App, acknowledge and consent to the collection, use, storage, disclosure, transfer and any other lawful processing of my child's/guardian personal data and use of cookies by SCB for the purposes set out above.
I further confirm that I have provided my child's/guardian information to SCB voluntarily and the information is accurate.
Your privacy is important, and that's why we want to tell you how we will handle information about you when you use the SC Junior App.
We have already informed your parent/legal guardian/guardian about your rights concerning the App in a more detailed privacy statement: see https://www.sc.com/ke/website-privacy-statement/ and they have agreed to this (or, if you are aged 18 or over, you confirm that you agree the processing of your personal data as set out in that more detailed privacy statement).