Privacy Policy

1. Who We Are

This Privacy Policy applies to the membership portal, WhatsApp channel and related services operated by Elites Boda TransCoop Society Ltd ("Elites Boda", "we", "us"), a registered Transport Cooperative Society based in Kakamega, Kenya. The platform is technically operated on our behalf by MooreTech. References to "our services" include app.elitesboda.com, our WhatsApp Business account, and any linked payment or partner integrations described below.

2. Information We Collect

• Membership & identity data — full name, national ID number, phone number, email address, group affiliation, and next-of-kin details provided during registration.
• Financial & contribution data — M-Pesa transaction references, contribution amounts, and payment history, received via M-Pesa C2B callbacks when you pay into your account.
• Communications data — messages you send us and account/contribution summaries we send you over WhatsApp (via the Meta WhatsApp Business Platform) and email (via our transactional email provider).
• Account & usage data — login sessions, device/browser information, and activity logs used to secure and operate the portal.

3. How We Use Your Information

• To create and manage your membership account, savings and contribution records.
• To process and reconcile M-Pesa payments made to your account.
• To send you account statements, contribution confirmations, and service updates via WhatsApp, email or SMS.
• To facilitate the optional third-party services you opt into (see Section 4).
• To respond to support requests and investigate disputes or suspected fraud.
• To comply with legal, regulatory and cooperative-society reporting obligations.

4. Sharing With Partners

We only share the minimum data necessary, and only for services you have specifically requested:

• CIC Microinsurance Ltd — for members enrolled in Personal Accident (Jilinde) Cover.
• KCB Bancassurance & APA Insurance — for members enrolled in Last Expense / Funeral Cover.
• Social Health Authority (SHA) — for members using our SHA registration/payment facilitation.
• NTSA — where road-safety or licensing facilitation is requested.
• Safaricom (M-Pesa/Daraja) — to process and confirm contribution payments.
• Meta Platforms, Inc. — as the provider of the WhatsApp Business Platform used to message members.

We do not sell member data to third parties.

5. Data Retention & Security

We retain membership and contribution records for as long as your membership is active and thereafter as required by cooperative-society and financial record-keeping regulations. Access to the portal is protected by encrypted, httpOnly session credentials, and payment webhooks are authenticated with a shared secret. We restrict internal access to member data to authorised administrators only.

6. Your Rights

Under the Kenya Data Protection Act, 2019, you may request access to, correction of, or deletion of your personal data, and may object to certain uses of it. To exercise these rights, contact us using the details in Section 9.

7. Children's Privacy

Our services are intended for members aged 18 and above and are not directed at children. We do not knowingly collect personal data from children.

8. Changes to This Policy

We may update this Privacy Policy from time to time. The "Last updated" date above reflects the most recent revision. Continued use of our services after changes take effect constitutes acceptance of the updated policy.

9. Contact Us

For any privacy questions or requests, contact us at steve@elitesboda.com or +254 728 275 876, or write to us at Elites Boda TransCoop Society Ltd, Kakamega, Kenya.