1. Introduction
Rubiani Capital Limited is committed to protecting the privacy, confidentiality and security of investor information collected through the Rubiani ISPP platform.
This Privacy Policy explains how investor information is collected, used, stored, shared and protected in connection with the use of the platform.
By registering for and using the platform, the investor consents to the collection and processing of personal information in accordance with this policy and applicable laws of Kenya, including the Data Protection Act.
2. Information Collected
Rubiani Capital may collect and process the following categories of information:
Personal Information
This may include:
- Full names
- National identification details
- Passport details (where applicable)
- Date of birth
- Postal and physical address
- Phone number
- Email address
Financial Information
This may include:
- Bank details
- Contribution records
- Investment account details
- Transaction history
- Source of funds information
KYC and Compliance Information
This may include:
- Identification documents
- PIN certificates
- Proof of address
- Supporting compliance documentation
Platform Usage Information
This may include:
- Login records
- Account activity
- Device and browser information
- Session logs
- Service requests
3. Purpose of Data Collection
Investor information is collected and processed for purposes including:
- Investor registration and onboarding
- Identity verification and KYC compliance
- Account administration
- Investment processing and transaction management
- Reporting and statement generation
- Customer support and investor communication
- Fraud prevention and security monitoring
- Compliance with legal and regulatory obligations
Rubiani Capital shall only use personal data for lawful and legitimate business purposes.
4. Data Sharing and Disclosure
Investor information may be shared where necessary with:
- Licensed custodians
- Fund managers
- Product providers
- Payment processors
- Professional advisers
- Technology service providers
- Regulators and government authorities
Such sharing shall only occur where necessary for account administration, legal compliance, service delivery or regulatory obligations.
Rubiani Capital shall not sell investor personal information to third parties.
5. Data Storage and Protection
Rubiani Capital applies reasonable administrative, technical and operational safeguards to protect investor data against unauthorized access, loss, misuse, alteration or disclosure.
These protections include:
- Secure database controls
- Restricted staff access
- Password encryption
- SSL/TLS secure transmission
- Backup systems
- Activity logging
- Hosting security controls
While reasonable security measures are maintained, no electronic system can be guaranteed to be completely secure.
6. Data Retention
Investor information shall be retained for as long as necessary for:
- Account administration
- Regulatory compliance
- Legal obligations
- Tax requirements
- Internal record keeping
- Dispute resolution
Where no longer required, data may be archived, anonymized or securely deleted in accordance with internal retention policies and applicable law.
7. Investor Rights
Subject to applicable law, investors may request:
- Access to their personal information
- Correction of inaccurate information
- Updating of outdated records
- Clarification on how their data is being used
- Withdrawal of consent where legally permissible
Requests may be submitted through the official communication channels of Rubiani Capital.
Certain requests may be limited where retention or processing is required by law or regulatory obligation.
8. Cookies and Platform Monitoring
The platform may use cookies, session tools and system logs to improve functionality, maintain security and enhance user experience.
These tools may collect technical information related to platform usage and access patterns.
Use of the platform constitutes consent to such operational monitoring.
9. Third-Party Services
The platform may integrate with third-party financial institutions, custodians, payment systems or technology providers.
Where such integrations occur, the handling of investor information by those third parties may also be subject to their own privacy and data protection policies.
Rubiani Capital shall take reasonable steps to work with reputable and regulated service providers.
10. Policy Updates
Rubiani Capital may update this Privacy Policy from time to time to reflect operational changes, legal requirements or regulatory developments.
Updated policies may be published on the platform and shall take effect upon publication or notice.
11. Contact and Complaints
For questions, concerns or requests relating to personal data or this Privacy Policy, investors may contact Rubiani Capital through its official communication channels as published on the platform.
Rubiani Capital remains committed to handling investor data responsibly, lawfully and with due regard to confidentiality and investor protection.