Privacy Policy
Effective Date: June 10, 2025
Platform: Jasiri (https://unlockwithjsr.com)
Operator: Safariblocks Ltd
1. Scope and Application
This Privacy Policy applies to all individuals globally who access or use the Jasiri platform and services, regardless of location. It explains how Jasiri collects, uses, stores, and shares your personal data and outlines your rights under applicable data protection laws.
2. Data We Collect
We collect personal data through forms, device inputs, and automated interactions. Categories include:
| Category | Examples |
|---|---|
| Personal Data | Full name, email, phone number, government-issued ID, address |
| Identity Data | Photos, KYC documents, face image, verification data |
| Asset Data | Receipts, IMEI/serial numbers, asset metadata, ownership info |
| Payment Data | Email, amount, transaction ID (card details handled securely by Paystack or Stripe) |
| Technical Data | IP address, device, browser, geolocation, OS, session duration |
| Usage Data | Page visits, actions taken, activity timestamps |
3. Legal Bases for Processing (as per GDPR, DPA, CCPA, and Kenya's Data Protection Act 2019)
We collect and process your data lawfully under:
- Your explicit consent
- Fulfillment of a contract (e.g. subscription)
- Legal obligations (e.g. financial audits, KYC regulations)
- Our legitimate interest (e.g. platform improvement, fraud prevention)
4. Purpose of Processing
We use your data to:
- Register and manage user accounts
- Verify identity and ownership of assets
- Issue asset titles and tokenized records
- Process secure payments and subscriptions
- Provide technical and customer support
- Analyze system performance and improve service delivery
- Comply with legal, financial, and tax obligations
5. Data Sharing and Disclosure
We only share your data with:
| Party Type | Reason |
|---|---|
| Payment Processors | Paystack (securely process payments and billing) |
| Communication Tools | Mailgun (for emails and notifications) |
| Verification Providers | (if applicable) to confirm identity, assets, or device ownership |
| Legal/Regulatory Entities | When required by law or to defend legal claims |
We do not sell or rent your personal data.
6. International Data Transfers
We may transfer your data to jurisdictions outside your country (e.g., U.S. or E.U.). When we do so, we ensure:
- Standard Contractual Clauses (SCCs) for EU data subjects
- Data protection equivalency for jurisdictions with adequacy decisions
- User consent and appropriate safeguards as required
7. Your Rights
Depending on your jurisdiction, you have the right to:
| Right | Jurisdictions Covered |
|---|---|
| Access your data | All |
| Request correction of inaccuracies | All |
| Delete your personal data ("Right to be Forgotten") | EU, Kenya, some U.S. states |
| Object to/restrict processing | EU, Kenya |
| Data portability | EU, Kenya |
| Withdraw consent | All |
| Lodge a complaint with authorities | EU (EDPB), Kenya (ODPC), U.S. (FTC/AG) |
📩 To exercise these rights, contact us at privacy@unlockwithjsr.com
8. Data Security
We employ technical and organizational security measures:
- HTTPS and encrypted transport (TLS 1.3)
- AES-256 encrypted storage for sensitive information
- Role-based admin access control
- Multi-factor authentication (MFA) for sensitive operations
- Regular vulnerability testing and security audits
9. Retention
We retain your data:
- For as long as necessary to provide services
- To comply with legal obligations (e.g. tax, compliance)
- Until you delete your account or request erasure
- Some anonymized or statistical data may be retained beyond deletion for analytical purposes.
10. Cookies and Tracking
No User Tracking Policy
Jasiri does not track users or use cookies for tracking purposes. We only use essential session cookies required for platform functionality and security.
11. California Consumer Privacy Act (CCPA) - California Addendum
For California residents: Under the California Consumer Privacy Act (CCPA), you have additional rights regarding your personal information.
California Rights
- Right to Know: Request disclosure of personal information collected, used, disclosed, or sold
- Right to Delete: Request deletion of personal information we have collected
- Right to Opt-Out: Opt-out of the sale of personal information (Note: We do not sell personal information)
- Right to Non-Discrimination: Not be discriminated against for exercising CCPA rights
Categories of Personal Information
We collect the categories of personal information listed in Section 2 above. We do not sell personal information to third parties.
How to Exercise Your Rights
California residents may exercise these rights by contacting us at celestino@unlockwithjsr.com with "California Privacy Request" in the subject line.
12. General Data Protection Regulation (GDPR) - European Union
For EU residents: Under the General Data Protection Regulation (GDPR), you have enhanced rights regarding your personal data.
GDPR Rights
- Right of Access (Article 15): Obtain confirmation and access to your personal data
- Right to Rectification (Article 16): Correct inaccurate personal data
- Right to Erasure (Article 17): "Right to be forgotten" - request deletion of personal data
- Right to Restrict Processing (Article 18): Limit how we process your data
- Right to Data Portability (Article 20): Receive your data in a structured, machine-readable format
- Right to Object (Article 21): Object to processing based on legitimate interests
- Right to Withdraw Consent: Withdraw consent for consent-based processing
Legal Basis for Processing
We process your data based on: (a) your consent, (b) performance of a contract, (c) compliance with legal obligations, or (d) our legitimate interests in providing and improving our services.
Data Protection Officer & Supervisory Authority
For GDPR-related inquiries, contact us at celestino@unlockwithjsr.com
You have the right to lodge a complaint with your local supervisory authority if you believe we have not addressed your concerns adequately.
13. Children's Privacy
Jasiri is not intended for children under 18. We do not knowingly collect personal data from minors. If you believe a minor has registered, email us at celestino@unlockwithjsr.com to delete the account.
14. Policy Updates
This Privacy Policy may be updated periodically. We will notify you of major changes via email or in-app notice.
15. Contact
For questions, data requests, or complaints:
Last updated: June 10, 2025