Privacy Policy

1. Introduction

Harrington Financial Advisory ("Harrington", "we", "us", or "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy outlines how we collect, use, and safeguard your information in compliance with the Kenya Data Protection Act, 2019 and other applicable laws of Kenya.

2. What Data We Collect

We may collect and process the following categories of personal data:

• Identity & Contact Data: Full name, email address, phone number, and WhatsApp number.
• Financial Inputs: Information you provide through our calculators (e.g., current age, retirement goals, income levels, corporate employee counts).
• Payment Data: M-Pesa phone numbers and transaction references when you make premium payments through the Daraja API. Note: We do not store your M-Pesa PIN.
• Technical Data: IP address, browser type, and interactions with our website for analytics purposes.

3. Why We Collect It

Your data is collected strictly for the following purposes:

• To provide personalized financial planning and generate custom proposals or illustrations.
• To facilitate seamless communication regarding your inquiries.
• To process premium payments securely via M-Pesa.
• To improve our platform, products, and overall user experience.

4. How We Use It (Including WhatsApp & Communications)

When you submit a lead capture form or book a consultation, you may opt-in to receive communications via WhatsApp. We utilize the WhatsApp Business API to send you:

• Automated follow-ups and educational financial nurture sequences.
• PDF guides, proposals, and meeting confirmations.
• Direct messages from our senior advisors.

We do not sell, rent, or lease your personal data or WhatsApp numbers to any third parties. Your data is only shared with our regulated underwriting partner, ICEA LION, when explicitly required to process a policy or quotation on your behalf.

5. M-Pesa Payment Data Handling

Payments made on our platform are processed securely via the Safaricom M-Pesa Daraja API. We temporarily store transaction IDs and payment statuses to verify your premium deposits. All transactions are encrypted, and we do not have access to your mobile money PIN or underlying bank accounts.

6. Data Retention Period

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements under Kenyan Law. Unengaged lead data will be anonymized or securely deleted after a period of 24 months.

7. Your User Rights

Under the Kenya Data Protection Act, 2019, you have the right to:

• Request access to the personal data we hold about you.
• Request correction of incomplete or inaccurate data.
• Opt-Out: You may opt-out of WhatsApp communications at any time by replying "STOP" to our messages.
• Deletion: Request the erasure of your personal data where there is no good reason for us continuing to process it.

8. Contact Us

If you have any questions about this Privacy Policy or wish to exercise your data protection rights, please contact us at:

Email: hello@harrington.co.ke

9. Governing Law

This Privacy Policy shall be governed by and construed in accordance with the laws of the Republic of Kenya.