NVRiche

Privacy Policy

How Nouveau Riche Holdings Ltd handles your personal data under the Data Protection Act, 2019.

Effective Date: 1 October 2026

Last Updated: October 2026

Entity: Nouveau Riche Holdings Limited ("NVRiche", "Company", "We", "Us", or "Our")

Registration Number: PVT-6Y1YPLA6

Registered Address: P.O. Box 3549-00605, Uthiru, Nairobi, Kenya

Website: nouveauriche.org

Contact Email: www@nouveauriche.org / nvricheltd@gmail.com

Data Protection Office Contact: www@nouveauriche.org

  1. Introduction & Regulatory Framework Nouveau Riche Holdings Limited is an ecosystem infrastructure company. We respect your privacy and are committed to protecting your personal data in accordance with Article 31 of the Constitution of Kenya 2010 and the Kenya Data Protection Act, 2019 (DPA).

Nouveau Riche Holdings Limited is registered as a Data Controller and Data Processor with the Office of the Data Protection Commissioner (ODPC), Kenya.

  1. Information We Collect We collect data necessary to provide ecosystem access, process transactions, facilitate talent/client matches, and maintain a safe community.

Registration & Profile Data: Full name, phone number (WhatsApp), email address, physical location, industry/occupation, skills, goals, national ID/Passport number (for verification/account opening where required), and profile picture.

Ecosystem Identifier: Member ID (NVR-[YEAR]-[SEQ]) issued upon complete registration.

Financial & Payment Data: M-Pesa transaction IDs, phone numbers, billing addresses, and payment receipts (handled securely via M-Pesa / licensed payment gateways; we do not store credit card CVVs or bank PINs).

Apprentice & Training Records (NVRiche Academy): Attendance, weekly mission deliverables, peer reviews, Month 3 assessment records, and mentor log notes.

Practitioner & Bidding Data: Professional credentials, verification documents, project proposals, blind bids, and client ratings.

Funding & Loan Requests: Project details, funding requirements, purpose, and financial notes.

Technical Data: IP addresses, browser types, device information, access timestamps, and cookie identifiers.

  1. Purpose & Legal Basis for Processing We process personal data under the following legal bases pursuant to the Kenya DPA:

Consent: Express consent provided during account creation or submission of forms.

Contractual Performance: Execution of terms, club agreements, apprenticeship agreements, or client desk interactions.

Legal Obligations: Statutory compliance, KRA tax reporting, and ODPC mandates.

Legitimate Interests: Platform security, fraud prevention, service improvement, and network analytics.

  1. Direct Marketing & Directory Opt-In Directory listings and contact sharing are strictly opt-in.

Members may opt out of promotional emails or WhatsApp updates at any time via portal settings or reply instructions.

  1. Data Sharing & Third-Party Processors We do not sell personal data. Data is shared strictly on a need-to-know basis with:

Licensed Payment & Escrow Partners: For transaction processing and escrow holding (e.g., M-Pesa / Daraja API, escrow partners).

Independent Regulated Financial Partners: Where loan/funding access is explicitly requested.

Service Clients & Practitioners: Contact details are shared only after mutual contract lock or explicit consent.

Legal & Regulatory Authorities: When required by Kenyan law or court order.

  1. International Data Transfers Where personal data is stored or processed outside Kenya, NVRiche ensures adequate safeguards, standard contractual clauses, or explicit consent in accordance with Section 48 of the Kenya DPA.

  2. Retention of Records Closed or inactive records are retained rather than deleted immediately for statutory compliance, legal defense, and audit trails. Personal data is held only as long as necessary for its specified purposes.

  3. Your Data Subject Rights Under the Kenya DPA, you have the right to:

Be informed of how your data is used.

Access your personal data in our custody.

Object to processing of all or part of your data.

Request correction or deletion of false or misleading data.

Withdraw consent at any time.

To exercise these rights, contact our Data Protection Office at www@nouveauriche.org. You also reserve the right to lodge a complaint with the Office of the Data Protection Commissioner (ODPC) Kenya.