Terms and Conditions

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Last Updated: October 2025.

The Rafiki mobile application, developed and managed by Germa Ltd, and serves as the operational platform for delivering E-Data SIM services. Leveraging backend infrastructure provided by Giga telecom, Rafiki aims to deliver a seamless, secure, and user-friendly experience. 

This privacy policy (the “Policy“) explains how the Rafiki mobile application collects, uses and discloses personal information through its websites, mobile applications, and other online products and services that link to this Policy, including any of the products and services detailed in the following paragraph (collectively, the “Services“) or when you otherwise interact with us.

The Services include providing: the Rafiki platforms (Web-Portal and Mobile application) for accessing e-data sim services, and other travel related services; which users can sign up for an account with.

If you accept or agree to this Policy on behalf of a company or other legal entity, you represent and warrant that you have the authority to bind that company or other legal entity to the Privacy Policy and, in such event, “you” and “your” will refer and apply to that company or other legal entity.

Collection of Information.

Information You Provide to Us.

We collect information you provide directly to us. For example, we collect information when you create a Rafiki Account, participate in any interactive features of the Services, fill out a form, participate in a contest or promotion, communicate with us via third party social media sites, request customer support, or otherwise communicate with us.

When You Sign Up or Register for a Rafiki Account or Services.

If you sign up for a Rafiki Account or other Services, we will collect basic information about you including your name, email address and telephone number. You may provide this information to us directly, or by signing in to your account/service with a third party, including without limitation, Google (see “Information We Collect from Other Sources” below). We will use the information that we collect about you to:

• Create and maintain your Rafiki Account;

• Allow you to log in to Rafiki;

• Contact you about your Rafiki Account and/or our Services (this may include marketing emails).

When You Provide Information to Build Your Profile.

Once you have created a Rafiki Account, we will ask you to provide additional information to allow you to make use of certain functions. We will ask you to provide a copy of an identification document, such as a passport, residency permit, visa or national identity card, as may be required by us in order to comply with our regulatory obligations and to verify your identity. 

Please note that if you choose to provide additional information about yourself to complete your “Profile“ or a survey, then the information we ask for may include your gender, date of birth, place of birth, addresses, nationality, and information about your travel experience, review of the Application, and other details or questions as may be required and the process may be amended by us from time to time.

It is optional for you to do so but for legal and regulatory reasons you may be unable to proceed to use certain features unless you provide further information.

We will use the information you provide in your Profile to:

• verify your identity and carry out checks that we are required to conduct by applicable laws and regulations, including without limitation, “know your customer” (KYC).

• contact you on matters related to your Rafiki Account, including to request any additional information or documentation;

• provide you with notices related to your Rafiki Account, general updates, market updates and other marketing materials, including about the Services offered by us, tailor the products and services offered through the application to you, including without limitation, to perform any suitability or appropriateness assessments for using our services and/or products, such as our high-leveraged e-data service packages. The client; maintain administrative records relating to our business; set up security measures to secure your account, including without limitation, to carry out two-factor authentication (“2FA”); and

• provide the Services.

You can update your Profile at any time by visiting the “Account” page in the Settings menu when logged into your Rafiki Account. We recommend that you update your Profile regularly, to ensure that the Rafiki functions offered to you are appropriate for your current circumstances. You further agree to update such information upon Rafiki’s request, if Rafiki considers the information provided as untrue, incorrect, incomplete and/or inconsistent with other information provided by you at any time. You acknowledge that we may rely upon such information and that you are responsible for any damages or losses which may result from any inaccuracies, including without limitation, the inappropriateness of our Services to your Profile. 

When You Contact Us.

If you contact us by telephone, email, or use another function offered by Rafiki, we will collect any information about the communication and any additional information that you choose to give us. We will use this information to review, investigate and respond to any comment or question that you may raise. Please note that we record and retain all communication with us and may use it in our dealings with you, including any dispute resolution or legal proceedings.

Information About Your Use of the Rafiki Services.

Usage and Automatically Collected Information.

When you access or use our Services, we automatically collect information about you including:

• Log Information: We collect log information about your use of the Services, including the type of browser you use, app version, access times, pages viewed, your IP address, any other network identifiers.

• Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, and unique device identifiers.

Information We Collect from Other Sources.

We may collect information about you from third parties, when you use or connect to Rafiki by or through a third-party platform, such as Google or another site, you allow us to access and/or collect certain information from your third-party platform profile/account as permitted by the terms of the agreement and your privacy settings with the third-party platform. We will share such information with the third-party platform for their use.

Unsolicited Information.

If you provide us with personal information that we have not requested, then we will endeavour to only retain the information that we are entitled or required to hold because of the products and services we provide. However, if this additional information is surplus to our requirements but is provided to us in a manner where it is combined with information that we are either required or entitled to retain then you acknowledge that this unsolicited information may be held by us in the same manner as the balance of your personal information.

Use of Information.

We use the information we collect to provide, maintain, and improve the Services, such as to administer, verify and maintain your account, to provide the Services you request and customise your experience with us. We also use the information we collect to:

• carry out our obligations owed to you; comply with our regulatory and other legal obligations; terms of reference about Rafik services.

• compile statistical analysis of the pages of our platform and websites; monitor and analyse our business; investigate and to manage enquiries, disputes and legal proceedings; participate in crime prevention, legal and regulatory compliance and to assist regulatory, cybercrime, data and information protection agencies and police with their enquiries and enforcement, even if not compelled to do so; and

• develop and to market other products and services.

Sharing of Information.

We will not share the personal information we hold about you except in the following circumstances:

• in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of Rafiki by another company.

• disclosure in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.

• if we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property, and safety of Rafiki or others

Advertising and Analytics Services Provided by Others.

We may allow others to provide analytics services and serve advertisements about our products and services on our behalf across the web and in mobile applications. This may involve cookies and other technologies to collect information about your use of the Services. This information may be used by Rafiki to, among other things, analyse and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services, and better understand your online activity in connection with the Services. Please refer to our Cookie Policy for more information about the cookies involved and the process of consenting or refusing cookies.

Your Choices and Rights.

You may have certain rights and protections under the law regarding the processing of your personal data. For example, you may also have the right to object to, or request that we restrict, certain processing and in some circumstances to obtain a copy of the personal information in machine readable format. There are limits to such rights where they apply and in certain circumstances we may not be required or able to meet your request, or we may only meet your request in part.

Data Subject Requests: You may have the right to access personal data we hold about you and to ask that your personal data be updated, corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you may reach us by email at contact@rafiki.store. If you wish to delete or deactivate your account, please note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.

Questions or Complaints: If you are interested in exercising any of these rights (or confirming if they apply to our processing of your personal data), you can contact us. Any such request should be submitted in writing to: contact@rafiki.store. If you have a concern about our processing of personal data that we are not able to resolve, you may have the right to lodge a complaint with the relevant data protection supervisory authority. As noted above, even where such rights apply, they are subject to limits. This means that, in certain circumstances, we may not be required or able to meet your request, or we may only meet your request in part.

Promotional Communications.

You may opt out of receiving promotional emails from Rafiki by sending an email to contact@rafiki.store. If you opt out, we may still send you non-promotional emails, such as service messages about your Rafiki Account or our ongoing business relationship.

Mobile Push Notifications/Alerts.

With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

Retention of Personal Information.

We store the information we collect on you for as long as is necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations. The period for which we will retain personal information will vary depending on the purposes that it was collected for, as well as the requirements of any applicable law or regulation. 

If you have a Rafiki Account, we will store your personal information for as long as you maintain that account, and after you cease holding an account, for as long as we are required to by laws and regulations that are applicable to us.

Security and Integrity of Information.

We protect your personal information by using data security technology and using tools such as firewalls and data encryption. We also require that you use a personal username and password every time you access your account online. As set out in the relevant Rafiki’s terms and conditions, terms of business and/or terms of use, you must not share your password with anyone else. We recommend that you do not re-use a password previously used by you for other platforms/services.

We restrict access to personal information at our offices so that only officers and/or employees with a legitimate business purpose can access it.

Minors.

Rafiki is not available for users under the age of 16. We do not knowingly collect personal information from or about Minors. If you are a Minor, you should not download or use any of our services nor provide any personal information to us.

If we become aware that a Minor has shared any information with us, we will delete such information. If you have any reason to believe that a Minor has shared any information with us, please contact us at contact@rafiki.store.

Changes to this Privacy Policy.

The Policy will be reviewed and updated from time to time to take account of changes to our operations or practices and, further, to make sure it remains appropriate in light of any changes in law, technology and the business environment. Any personal information held will be governed by our most current Policy. Please refer back to the Policy on a regular basis.

Links.

The Site may include links to other websites on the internet. We are not responsible for the content of these sites or for any other privacy practices on these internet sites. You should read the terms of use and the privacy statements of any such websites. Our terms of use and our Privacy Policy apply only to information collected by us in accordance with this Policy.

Contact Us.

Should you have any questions regarding the Policy, please contact us by sending an email at: contact@rafiki.store and please include your full name, and email address so we are able to handle your query properly. We may require that you provide additional information to verify your identity before allowing you to exercise certain rights outlined above.