Customer Communications, Offers and Feedback Terms and Privacy Notice

1. Acceptance of these terms

By replying YES, ticking an opt-in box, submitting your phone number, scanning a QR code, using a reward code, claiming an offer, giving feedback, or otherwise accepting these terms, you agree that the Merchant and Tappi may process your personal data in accordance with this policy.

Your consent is optional. You do not have to consent to receive promotional communications in order to make a purchase from the Merchant, unless a specific promotion, reward or customer benefit reasonably requires communication with you.

You may withdraw your consent at any time by replying STOP to a message, using any unsubscribe option provided, or contacting us through the details in this policy.

2. What communications you may receive

If you opt in, the Merchant and Tappi may contact you through SMS, WhatsApp, phone call, email, in-app message or any other communication channel linked to the contact details you provided.

The communications may include:

• feedback requests after a visit or purchase;
• review requests;
• customer satisfaction surveys;
• offers, discounts, rewards, vouchers, cashback, loyalty benefits or promotional campaigns;
• reminders about available, unused or expiring offers;
• product, service, branch or merchant updates;
• personalised suggestions based on your visits, purchases or feedback;
• customer support messages relating to feedback, rewards, offers or redemptions;
• administrative messages about your consent, preferences, data rights or these terms.

Some messages may be promotional in nature, even where they are described as offers, rewards, benefits or updates.

3. Service and transactional messages

Even if you opt out of promotional communications, the Merchant or Tappi may still send you non-promotional messages where allowed by law. These may include:

• messages needed to complete a transaction you requested;
• verification or fraud-prevention messages;
• redemption confirmations;
• customer support responses;
• legal, security or administrative notices;
• messages required to comply with applicable law.

We will not use an opt-out request to stop legally required or service-critical communications that are not promotional in nature.

4. Information we collect

Depending on how you interact with the Merchant and the Service, we may collect and process:

• your phone number;
• your name, where provided;
• your email address, where provided;
• the Merchant you visited;
• branch, outlet or location information;
• date and time of visit or transaction;
• receipt number, order number, bill number, till number or payment reference;
• transaction amount;
• items or services purchased, where the Merchant shares this information;
• offer, reward or voucher eligibility;
• offer messages sent to you;
• whether you opened, replied to, claimed, used, ignored or opted out of a message;
• feedback ratings, review responses, survey responses and comments;
• redemption history;
• communication channel, delivery status and message logs;
• device, browser, IP address, cookie or website analytics information where you interact with a Tappi or Merchant website;
• customer support messages or complaints;
• consent records, including date, time, source and wording accepted.

We may also receive information from the Merchant, payment providers, delivery providers, customer support tools, analytics providers, messaging providers or other service providers involved in providing the Service.

5. Purchase and item-level data

Where a Merchant shares receipt or basket data with Tappi, this may include the products or services you bought.

This data may be used to:

• send feedback requests linked to a specific visit or purchase;
• decide whether you qualify for an offer, reward or discount;
• personalise offers based on past purchases;
• understand customer preferences;
• help the Merchant improve products, services and customer experience;
• prevent misuse, duplicate redemptions or fraudulent claims;
• measure campaign, offer and customer satisfaction performance.

Some purchase data may reveal sensitive preferences or information, especially where the Merchant sells health, wellness, pharmacy, personal-care or similar products. Where sensitive personal data is involved, we will process it only where permitted by law, with appropriate safeguards, and only for the purposes described in this policy or otherwise disclosed to you.

6. How we use your information

The Merchant and Tappi may use your personal data to:

• record and manage your consent;
• send feedback requests, surveys and review requests;
• send offers, promotions, rewards, discounts and customer updates;
• personalise communications based on your visits, purchases, preferences or feedback;
• create customer segments for the Merchant;
• check whether you qualify for a reward, voucher, offer or benefit;
• create, verify and redeem offer or reward codes;
• prevent duplicate use, abuse, fraud or unauthorised redemptions;
• manage opt-outs, complaints and customer support requests;
• measure delivery, engagement, redemption and campaign performance;
• improve Merchant products, services and customer experience;
• improve, secure and maintain the Tappi platform;
• comply with legal, tax, accounting, regulatory or law-enforcement obligations;
• establish, exercise or defend legal claims.

7. Legal basis for processing

We process your personal data only where we have a lawful basis to do so.

Depending on the context, the lawful basis may include:

• your consent;
• performance of a contract or steps taken at your request;
• compliance with a legal obligation;
• legitimate interests of the Merchant or Tappi, provided those interests do not override your rights and freedoms;
• prevention of fraud, misuse or unlawful activity;
• another basis permitted under applicable law.

For promotional communications and commercial use of your personal data, we rely on your consent unless another lawful basis is clearly available under applicable law.

You may withdraw consent at any time. Withdrawal of consent does not affect processing that happened lawfully before your withdrawal.

8. Personalised offers and automated rules

The Service may use automated rules to decide whether a customer should receive a feedback request, offer, reward, reminder or customer update.

For example, the Service may identify that:

• you recently visited a Merchant;
• you gave positive or negative feedback;
• you bought a certain type of product;
• you have not visited for a period of time;
• you may qualify for a reward or discount;
• you have an unused or expiring offer.

These rules are used to make communications more relevant and to help Merchants manage customer engagement. They are not intended to make decisions that produce legal effects or similarly significant effects about you.

If you believe an offer, reward, redemption decision or communication was incorrect, you may contact us or the Merchant for review.

9. Feedback, ratings and reviews

If you submit feedback, a rating, survey response or review through the Service, the Merchant and Tappi may use it to:

• understand your experience;
• respond to complaints or service issues;
• improve customer service;
• identify branch, staff, product or service issues;
• measure customer satisfaction;
• request a public review where appropriate;
• generate aggregated insights for the Merchant.

We may share your feedback with the Merchant you visited. Where feedback relates to a staff member, outlet, order, product, complaint or incident, the Merchant may use it for internal service improvement and customer support.

We will not publish your private feedback publicly without your permission, unless it has been anonymised or aggregated so that it does not reasonably identify you.

10. Offers, rewards, vouchers and redemptions

Offers, rewards, discounts, cashback, vouchers or other benefits may be subject to additional terms stated in the message or provided by the Merchant.

Unless stated otherwise:

• offers are subject to availability;
• offers may expire;
• offers may be limited to specific branches, products, categories, dates, customers or purchase conditions;
• offers may be single-use;
• offers may not be transferable;
• offers may not be exchangeable for cash unless expressly stated;
• the Merchant may verify eligibility before accepting an offer;
• the Merchant may refuse redemption where fraud, misuse, duplication or system error is suspected;
• a reward or offer may be cancelled, corrected or withdrawn if issued by mistake.

The Merchant is responsible for honouring eligible offers it has approved, subject to the applicable offer terms.

Tappi provides the technology used to deliver, track, verify or support the offer, but Tappi is not the seller of the Merchant's products or services unless expressly stated.

11. Opting out

You may opt out of promotional communications at any time.

You can opt out by:

• replying STOP to a message;
• using an unsubscribe link or opt-out instruction provided in the message;
• contacting the Merchant;
• contacting Tappi using the details in this policy.

After you opt out, we will update our records and stop sending promotional communications to the relevant phone number or contact channel, except for service, transactional, security, legal or administrative messages that may still be permitted.

If you interact with multiple Merchants using Tappi, your opt-out may apply to the Merchant or sender ID shown in the message, unless the opt-out message or process states that it applies more broadly.

If you later reply YES, opt in again, claim an offer, or otherwise request promotional communications, we may treat that as new consent.

12. Sharing your information

We may share your personal data with:

• the Merchant you visited or interacted with;
• Tappi group companies, staff, contractors and authorised personnel;
• SMS, WhatsApp, email, voice or messaging providers;
• cloud hosting, database, storage and infrastructure providers;
• analytics, reporting and customer engagement providers;
• payment, settlement or reconciliation providers, where relevant;
• fraud-prevention, security and audit providers;
• customer support providers;
• professional advisers, including lawyers, auditors and accountants;
• regulators, law-enforcement agencies, courts or public authorities where required or permitted by law;
• another organisation involved in a merger, acquisition, financing, restructuring or sale of all or part of our business, subject to appropriate safeguards.

We do not sell your personal data.

We do not share your personal data with third parties for their independent marketing unless you have consented or the sharing is otherwise permitted by law.

13. Merchant responsibility

The Merchant is responsible for the products, services, prices, staff conduct, branch operations, offer fulfilment and customer experience at its business.

Where a Merchant provides your personal data to Tappi, the Merchant is responsible for ensuring that it has a lawful basis to collect and share that data with Tappi.

Tappi is responsible for operating the technology platform, maintaining consent and messaging records, supporting delivery and redemption workflows, and applying reasonable safeguards to the personal data it processes.

Depending on the specific activity, Tappi may act as a processor on behalf of a Merchant, an independent controller for its own platform operations, or both.

14. Data retention

We keep personal data only for as long as reasonably necessary for the purposes described in this policy.

Retention periods may depend on:

• the type of data;
• the purpose for which it was collected;
• legal, tax, accounting or regulatory requirements;
• fraud-prevention and dispute-resolution needs;
• whether you remain opted in;
• whether there is an active complaint, investigation, claim or audit;
• whether the data has been anonymised or aggregated.

We may retain opt-out records so that we can respect your request not to receive promotional messages.

Where data is no longer needed, we will delete, anonymise, pseudonymise or securely archive it in accordance with applicable law and our retention practices.

15. Security

We use reasonable technical and organisational measures to protect personal data against unauthorised access, loss, misuse, alteration or disclosure.

These measures may include:

• access controls;
• authentication controls;
• encryption where appropriate;
• logging and monitoring;
• staff access restrictions;
• secure hosting;
• backup and recovery controls;
• vendor due diligence;
• internal policies and procedures.

No system is completely secure. If we become aware of a data incident that requires notification under applicable law, we will take appropriate steps to investigate, mitigate and notify affected parties or regulators where required.

16. International transfers

Some of our service providers may process or store personal data outside Kenya.

Where personal data is transferred outside Kenya, we will take steps required by applicable law to protect the data. These may include contracts, safeguards, consent where required, or other lawful transfer mechanisms.

17. Cookies and website analytics

Where you visit a Tappi or Merchant webpage linked to this policy, cookies, pixels, tags or similar technologies may be used to:

• operate the website;
• remember preferences;
• measure traffic and usage;
• understand campaign performance;
• improve user experience;
• support advertising or remarketing where permitted.

Where required, we will request your consent before using non-essential cookies or similar technologies.

You can manage cookies through your browser settings or any cookie controls provided on the website.

18. Children

The Service is not intended for children.

We do not knowingly collect or use children's personal data for promotional communications. If you believe a child's personal data has been provided to us without appropriate consent, please contact us so that we can review and take appropriate action.

19. Your rights

Subject to applicable law, you may have the right to:

• be informed about how your personal data is used;
• access personal data held about you;
• correct inaccurate, outdated, incomplete or misleading personal data;
• request deletion of personal data where retention is no longer authorised;
• object to processing of your personal data;
• restrict processing of your personal data;
• withdraw consent at any time;
• request data portability where applicable;
• complain to the Office of the Data Protection Commissioner or another applicable regulator.

To exercise your rights, contact us using the details below.

We may need to verify your identity before acting on a request. This helps protect your personal data from unauthorised access.

20. Complaints

If you have a complaint about a message, offer, reward, feedback request or use of your personal data, you may contact the Merchant or Tappi.

We will review complaints and respond within a reasonable time, subject to applicable law.

You may also lodge a complaint with the Office of the Data Protection Commissioner in Kenya or another competent authority where applicable.

21. Changes to this policy

We may update this policy from time to time.

The latest version will be posted on our website or made available through the relevant communication link.

Where changes are material, we may notify you through the Service, the website, SMS, WhatsApp, email or another appropriate channel.

Your continued use of the Service or continued participation in communications after an update means the updated policy applies, where permitted by law.

Where fresh consent is required by law, we will request it.

22. Contact details

For questions, complaints, opt-outs or data rights requests, contact:

Tappi

Email: [email protected]

Call/WhatsApp: +254715412061

You may also contact the Merchant directly using the contact details provided by the Merchant.