HustleSasa

Privacy Policy

Introduction

In our mission to make commerce better for everyone at Hustle, we collect and use information about you, our

This Privacy Policy will help you better understand how we collect, use, and share your personal information. If we change our privacy practices, we may update this privacy policy. If any changes are significant, we will let you know (for example, through the Hustle admin or by email).

Our values

Trust is the foundation of the Hustle platform and includes trusting us to do the right thing with your information. Three main values guide us as we develop our products and services. These values should help you better understand how we think about your information and privacy.

  • Your information belongs to you
    We carefully analyze what types of information we need to provide our services, and we try to limit the information we collect to only what we really need. Where possible, we delete or anonymize this information when we no longer need it. When building and improving our products, our engineers work closely with our privacy and security teams to build with privacy in mind. In all of this work, our guiding principle is that your information belongs to you, and we aim to only use your information to your benefit.
  • We protect your information from others
    If a third party requests your personal information, we will refuse to share it unless you give us permission or we are legally required. When we are legally required to share your personal information, we will tell you in advance, unless we are legally forbidden.
  • We help merchants and partners meet their privacy obligations
    Many of the merchants and partners using Hustle do not have the benefit of a dedicated privacy team, and it is important to us to help them meet their privacy obligations. To do this, we try to build our products and services so they can easily be used in a privacy-friendly way. We also provide detailed FAQs, documentation, and whitepapers covering the most important privacy topics, and respond to privacy-related questions we receive.

Why we process your information

We generally process your information when we need to do so to fulfill a contractual obligation (for example, to process your subscription payments to use the Hustle platform), or when we or someone we work with needs to use your personal information for a reason related to their business (for example, to provide you with a service). European law calls these reasons “legitimate interests.” These “legitimate interests” include:

  • preventing risk and fraud
  • answering questions or providing other types of support
  • helping merchants find and use apps through our app store
  • providing and improving our products and services
  • providing reporting and analytics
  • testing out features or additional services
  • assisting with marketing, advertising, or other communications

We only process personal information for these “legitimate interests” after considering the potential risks to your privacy—for example, by providing clear transparency into our privacy practices, offering you control over your personal information where appropriate, limiting the information we keep, limiting what we do with your information, who we send your information to, how long we keep your information or the technical measures we use to protect your information.

One of the ways in which we are able to help merchants using Hustle is by using techniques like “machine learning” (European law refers to this as “automated decision-making”) to help us improve our services. When we use machine learning, we either: (1) still have a human being involved in the process (and so are not fully automated); or (2) use machine learning in ways that don’t have significant privacy implications (for example, reordering how apps might appear when you visit the app store).

Legal basis for the processing of personal data

We will only process your personal data where we have a legal basis to do so. The legal basis will depend on the purposes for which we have collected and use your personal data, typically among the following:

Consent: We rely on consent for targeted marketing communications either as HustleSasa or via the creators we work with. By purchasing a product or service from creators powered by HustleSasa, you are giving consent to receive targeted marketing communications. You can withdraw your consent at any time by notifying us at support@hustlesasa.com

Our Legitimate Business Interests: Where it is necessary for us to understand our buyers and creators, promote our services and operate effectively as a global e-commerce company, provided in each case that this is done in a legitimate way where they are not outweighed by your privacy and other rights.

Performance of a contract with you: This would also apply where we need to take steps prior to entering into a contract with you. For example, where you have purchased a product from a creator using HustleSasa and we need to provide your contact details and payment information in order to process your order and send the product/service to you.

Compliance with law: Where we are subject to a legal obligation and need to use your personal data in order to comply with that obligation.

Your rights over your information

We believe you should be able to access and control your personal information no matter where you live. Depending on how you use Hustle, you may have the right to request access to, correct, amend, delete, port to another service provider, restrict, or object to certain uses of your personal information (for example, direct marketing). We will not charge you more or provide you with a different level of service if you exercise any of these rights.

If you buy something from a Hustle-powered store and wish to exercise these rights over information about your purchase, you need to directly contact the merchant you interacted with. We are only a processor on their behalf, and cannot decide how to process their information. As such, we can only forward your request to them to allow them to respond. We will of course help our merchants to fulfill these requests by giving them the tools to do so and by answering their questions.

Please note that if you send us a request relating to your personal information, we have to make sure that it is you before we can respond. In order to do so, we may ask to see documentation verifying your identity, which we will discard after verification.

If you would like to designate an authorized agent to exercise your rights for you, please email us from the email address we have on file for you. If you email us from a different email address, we cannot determine if the request is coming from you and will not be able to accommodate your request. In your email, please include the name and email address of your authorized agent.

If you are not happy with our response to a request, you can contact us to resolve the issue. You also have the right to contact your local data protection or privacy authority at any time.

Finally, because there is no common understanding of what a “Do Not Track” signal is supposed to mean, we don’t respond to those signals in any particular way.

How long will we retain your personal data?

We will retain your personal data for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. After this period, it will be deleted or in some cases anonymized.

For example, where you have made a purchase through commerce sites powered by our platform, we will keep a record of your purchase for the necessary period for invoicing, tax, and warranty purposes if applicable. We may also keep a record of correspondence with you for as long as is appropriate to protect us in the event of a legal claim.

Where we send your information

We are a Kenyan company, but we work with and process data about individuals across the world. To operate our business, we may send your personal information outside of your state, province, or country, including to the United States. This data may be subject to the laws of the countries where we send it. When we send your information across borders, we take steps to protect your information, and we try to only send your information to countries that have strong data protection laws.

How we protect your information

Our teams work tirelessly to protect your information and to ensure the security and integrity of our platform. We also have independent auditors assess the security of our data storage and systems that process financial information. However, we all know that no method of transmission over the Internet, and method of electronic storage, can be 100% secure. This means we cannot guarantee the absolute security of your personal information. You can find more information about our Acceptable Use Policy at https://www.hustlesasa.com/aup.

How we use “cookies” and other tracking technologies

We use cookies and similar tracking technologies on our website and when providing our services. For more information about how we use these technologies, including a list of other companies that place cookies on our sites, a list of cookies that we place when we power a merchant’s store, and an explanation of how you can opt-out of certain types of cookies, please see our Cookie Policy.

How you can reach us

If you would like to ask about, make a request relating to, or complain about how we process your personal information, you can contact us by email at privacy [at] Hustle.com, or at one of the addresses below. If you would like to submit a legally binding request to demand someone else’s personal information (for example, if you have a subpoena or court order), please review our Guidelines for Legal Requests.

Hustle Inc.

ATTN: Chief Privacy Officer

P.O. Box 13722 – 00800

Nairobi, Kenya

support@hustlesasa.com