This Privacy Statement describes how Marble Capital Limited (“Marble Capital,” “we,” “our,” or “us”) protects the personal data it processes, why and how we collect and use your personal data, and how you can exercise your rights in relation to the processing of your personal data.

This Privacy Statement should be read together with the Terms and Conditions of Use for Marble Capital’s products and services. Where there is a conflict, this Privacy Statement will prevail.

DEFINITIONS

“Marble Capital,” “We,” “our,” “ours,” and “us”** means Marble Capital Limited, a financial institution registered under the laws of Kenya, Cap 486, and includes its successors, affiliates, and subsidiaries.
“Personal data” or “personal information” means information about you or information that identifies you as a unique individual, such as your name, physical address, contact details, and/or identification number.
“Processing” means handling, collecting, using, altering, storing, protecting, retrieving, disclosing, or destroying your personal information.
“Sensitive personal information” includes data revealing your race, health status, ethnic origin, beliefs, biometric data, marital status, family details, sex, or sexual orientation.

“You” means:

• A customer (including personal representatives and assigns) operating an account with us or using our products and services.
• Any agent, merchant, supplier, or service provider engaged with Marble Capital.
• Any visitor to Marble Capital premises or user of our digital platforms.

COLLECTION OF PERSONAL DATA
Marble Capital will only collect personal data necessary to achieve the purposes outlined in this Privacy Statement. We collect your personal information with your knowledge and consent, except where prior consent cannot be obtained for legitimate reasons and processing is permitted by law.

We collect your personal information when you:

• • Apply for, purchase, or use any of our products or services.
  • Contact us with queries, complaints, or feedback.
  • Visit our premises or use our digital platforms (website, mobile app, etc.).
  • Participate in surveys, promotions, or events sponsored by Marble Capital.
  • Engage with us as a supplier, agent, or partner.
  • Provide information as part of regulatory requirements (e.g., Know Your Customer (KYC) or Anti-Money Laundering (AML) checks).

We may also collect your information from:

• Credit reference bureaus, fraud prevention agencies, and government databases.
• Publicly available sources or third-party service providers.
• •  

WHAT INFORMATION IS COLLECTED?
We may collect the following types of personal information:
Identity information: Name, photograph, nationality, date of birth, gender, identification number, and signature.
Contact details: Address, phone number, email, and social media handles.
Financial information: Bank account details, income levels, and transaction history.
Employment details: Employer name, job title, and contract terms.
Biometric data: Fingerprints or voice recordings for authentication purposes.
Device information: IP address, device ID, and browsing history when you use our digital platforms.
Sensitive data: Health status, marital status, or family details, where necessary and with your consent.

USE OF PERSONAL DATA
We process your personal data for the following purposes:

• To verify your identity and comply with regulatory requirements (e.g., KYC, AML).
• To provide and improve our products and services.
• To communicate with you about your account, transactions, or inquiries.
• To prevent fraud, financial crime, and ensure the security of our systems.
• To conduct market research, surveys, and promotional activities (with your consent).
• To comply with legal obligations and respond to lawful requests from authorities.
• To facilitate corporate transactions, such as mergers or acquisitions.

SENSITIVE PERSONAL DATA
We may collect and process sensitive personal data (e.g., health status, biometric data) only where necessary and with your explicit consent, or where required by law.

TRANSFER OF PERSONAL DATA
Marble Capital may transfer your personal information to:
Affiliates and subsidiaries: For the purpose of providing our products and services.
Third-party service providers: Such as IT vendors, payment processors, or legal advisors, who are bound by confidentiality agreements.
Regulatory authorities: To comply with legal obligations or respond to lawful requests.

Cross-border transfers: Where personal data is transferred outside Kenya, we ensure adequate data protection safeguards are in place or obtain your consent.

LEGAL BASIS FOR PROCESSING
We process your personal data based on:

• Your consent.
• The performance of a contract with you.
• Compliance with legal obligations.
• Legitimate business interests, such as fraud prevention or improving our services.

DIRECT MARKETING
We may use your personal information to send you marketing communications about products or services that may interest you. You can opt out of receiving such communications at any time by contacting us or using the unsubscribe option in our messages.

RETENTION OF PERSONAL DATA
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by law. Typically, we retain data for up to seven (7) years after the end of your relationship with us, unless a longer retention period is mandated.

YOUR RIGHTS
You have the following rights regarding your personal data:
1. Access: Request a copy of the personal data we hold about you.
2. Rectification: Request correction of inaccurate or incomplete data.
3. Erasure: Request deletion of your personal data, where permissible.
4. Restriction: Request restriction of processing under certain conditions.
5. Objection: Object to the processing of your personal data for direct marketing or other purposes.
6. Portability: Request transfer of your data to another service provider in a machine-readable format.

To exercise these rights, please contact our Data Protection Officer (DPO) using the details below.

CONTACT US
If you have any questions, concerns, or requests regarding your personal data, please contact our Data Protection Officer:
Email: info@marblecapital.co.ke
Phone: +254 733 881166
Address: 2nd Floor, Maasai Mall – Ongata Rongai

AMENDMENTS TO THIS STATEMENT
Marble Capital reserves the right to amend this Privacy Statement from time to time. Any changes will be communicated through our website or other appropriate channels. Your continued use of our products and services constitutes your acceptance of the updated Privacy Statement.