Privacy Policy for Virtual KES Account Service


3rd December, 2025* 

This Privacy Policy explains how  NALA (referred to as "NALA", "we", "us", or "our") collects, uses, discloses, and protects your personal data when you use the Virtual KES Account service ("Service"). By accessing or using the Service, you agree to the collection and use of your data in accordance with this Privacy Policy and that of the Partner.

Please read this Privacy Policy carefully to understand how we handle your personal information. If you do not agree with any aspect of this Privacy Policy, you must discontinue use of the Service.

1. Information We Collect

To provide you with the Virtual KES Account service, we collect various types of personal data, including but not limited to:

  • Personal Identification Information: Full name, date of birth, contact information (email address, phone number), government-issued ID (e.g., national ID, passport), and residential address.

  • Account Information: Your account number, transaction history, account balances, and linked payment methods (bank account or credit card details).

  • Authentication Information: Any information used for identity verification (if applicable).

  • Transaction Data: Details of your transactions, including the amounts, currencies involved, recipient details, and any associated fees.

  • Device and Usage Data: Information about the device used to access the Service, such as IP addresses, device identifiers, browser type, operating system, and usage patterns.

2. How We Use Your Information

We use your personal data for the following purposes:

  • To Provide the Service: This includes creating and maintaining your Virtual KES Account, processing transactions, and providing other related services such as account management and balance updates.

  • Compliance with Legal Obligations: We process your data to comply with applicable laws and regulations, including Know-Your-Customer (KYC), Anti-Money Laundering (AML), and Counter-Terrorism Financing (CFT) requirements.

  • Security and Fraud Prevention: To monitor and prevent unauthorized access to your account, detect fraudulent activity, and safeguard the integrity of the Service.

  • Improvement of Service: To analyze user interactions, troubleshoot, and enhance the features, security, and functionality of the Service.

  • Communication: To send you notifications about your account, changes to the Service, updates to our Terms of Service or Privacy Policy, and other important communications related to the Service.

3. How We Share Your Information

We may share your personal information with the following parties:

  • Our Licensed Partner(s): We work with licensed institutions to manage and safeguard the funds in your Virtual KES Account. These Partners may have access to your account and transaction information for the purpose of fulfilling the Service.

  • Service Providers: We may share your data with third-party service providers who assist us in operating the Service, such as payment processors, fraud detection services, and customer support platforms.

  • Regulatory Authorities: We may disclose your personal information to government agencies, regulatory authorities, or law enforcement, when required by law or if we believe it is necessary to protect our rights or comply with legal obligations.

4. Data Security

We employ industry-standard security measures to protect your personal data from unauthorized access, loss, or alteration. These measures include encryption, firewalls, and secure server practices. However, no system can be 100% secure, and we cannot guarantee the absolute security of your data.

You are responsible for maintaining the confidentiality of your account credentials and any other security codes associated with your Virtual KES Account.

5. Your Rights

You have the following rights concerning your personal data:

  • Access: You may request a copy of the personal data we hold about you.

  • Correction: You may update or correct any inaccurate or incomplete information in your account.

  • Deletion: You may request the deletion of your personal data, subject to any legal obligations we may have to retain certain information.

  • Objection and Withdrawal of Consent: You may object to or withdraw consent for the processing of your personal data in certain cases, such as when we rely on consent as the basis for processing.

  • Data Portability: You may request a copy of your personal data in a structured, commonly used format for transfer to another service provider.

To exercise any of these rights, please contact us using the details provided in the Contact Information section.

6. Data Retention

We retain your personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy, or as required by law. If your account is closed or inactive for an extended period, we may be required to comply with applicable laws regarding dormant accounts and unclaimed funds.

7. International Transfers

Your personal data may be processed or stored outside your country of residence, including in countries with different data protection laws. We take steps to ensure that your data is protected in accordance with this Privacy Policy, regardless of where it is processed.

8. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any material changes by posting the updated Privacy Policy on our website or via in-app notification.

By continuing to use the Service after any changes to this Privacy Policy, you accept the updated terms.

9. Contact Us

If you have any questions or concerns about this Privacy Policy or how we handle your personal data, please contact us

This Privacy Policy is intended to comply with applicable data protection laws, including the Kenya Data Protection Act, and reflects the practices of NALA and its Partners in managing your personal data.

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In the United Kingdom, NALA Payments Ltd is a registered EMD agent of Modulr FS Limited, which is an Electronic Money Institution authorised by the Financial Conduct Authority with firm reference number 900573. Electronic Money products are not covered by the Financial Services Compensation Scheme (FSCS). Customer funds will be held in one or more segregated accounts and safeguarded in line with the Electronic Money Regulations 2011. For more information, please see Modulr’s UK Safeguarding Explanation here.

In the European Union, NALA Payments Netherlands B.V. is a partner of Modulr Finance B.V., a company registered in the Netherlands with company number 81852401, which is authorised and regulated by De Nederlandsche Bank (DNB) as an Electronic Money Institution (relationship number R182870) for the issuance of electronic money and payment services. Your account and related payment services are provided by Modulr Finance B.V. Your funds will be held in one or more segregated accounts and the full value safeguarded in line with the Financial Supervision Act.

In the United States, Nala Inc. partners with the financial services software company, Sila Inc. (“Sila”) and Priority Technology Holdings Inc. (“Priority Commerce”), either directly or through its subsidiary Finxera, Inc. (NMLS #1168701) and/or its authorized affiliates, contractors and partners (including but not limited to the following Banks: Wells Fargo, N.A., Comerica Bank, Axos Bank, and Western Alliance Bank) to offer you electronic fund transfers and provide you with an account. Nala Inc. is a financial technology company, not a bank.

Mufasa Payments LLC, a subsidiary of Nala Inc., partners with Lead Bank (NMLS #635532) to offer you electronic fund transfers and provide you with an account. Mufasa Payments LLC is a financial technology company, not a bank.

In certain states in the United States where it holds the necessary licenses, money transmission services may be provided by Nala Payments LLC (NMLS: 2530895), a subsidiary of Nala Inc., pursuant to its own state-issued money transmitter licenses and registration as a Money Services Business (MSB) with the United States Treasury Financial Crimes Enforcement Network (MSB: 31000335047569). In such cases, the partnership with Mufasa Payments LLC, Sila Inc. and Lead Bank N.A. may not be utilized or required. The availability of services and regulatory status may vary by geographic location and customer location.

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