ILO FLOW Mobile — Privacy Policy
ILO FLOW Mobile ("the app") is a financial reasoning and accounting learning app published by Finotech Solutions LLP ("Finotech", "we", "us", "our"), Mwembe Tayari, Mombasa County, Kenya. Finotech is the data controller for the personal data described in this policy.
This policy explains what personal data we collect when you use the app, why we collect it, how we protect it, and the choices and rights you have. If you have any questions, contact us at finotechsolutionsllp@gmail.com or +254 713 883 912.
1. Information we collect
Account information. When you create an account, we collect your username, email address and password, and, if you choose, a display name. We use your email address to help you recover your account. We never store your password in readable form; it is protected using industry-standard one-way hashing.
Preferences. Your language, chosen mentor, and in-app settings such as sound, animation, motion and notification preferences.
Learning progress. The lessons and scenarios you complete, the answers you choose, your results and scores, and the areas where you may need more practice. The app does not collect free text you type within lessons.
App and device information. A random identifier created by the app when it is first installed, your device platform and the app version. This identifier is not a hardware identifier or an advertising ID; it is used only to keep you signed in and to keep your progress in sync.
Purchase information. If you subscribe, we receive details of the transaction from Google Play, such as the product purchased, price, currency, transaction reference and subscription period. Payments are processed by Google Play. We never receive or store your card or other payment details.
Security logs. Like most online services, our servers automatically record limited technical information about requests made to them, such as IP address, date and time, and app or browser type. We use this information only to keep the service secure, prevent abuse and fix problems.
We do not collect your location, contacts, photos, files, microphone or camera data, and the app does not use an advertising ID.
2. How we use your information
We use your information to:
- create and manage your account;
- provide lessons and keep your progress in sync between your device and our servers;
- send you a password-reset code when you request one (this is the only email the app sends);
- provide and verify subscriptions you purchase;
- protect the app and its users against fraud, abuse and security threats; and
- meet our legal, tax and accounting obligations.
We do not sell your personal data, we do not show ads in the app, and we do not use your data for advertising or marketing profiles.
3. Legal basis for processing
We process your personal data in accordance with Kenya's Data Protection Act, 2019, on the following grounds: to perform our agreement with you (providing the app and your account); to comply with our legal obligations (for example, keeping purchase records); and for our legitimate interests in keeping the service secure and reliable.
4. Who we share information with
We share personal data only with trusted service providers that process it on our behalf and under our instructions, and only as far as needed to run the app:
- Cloud hosting and database providers, which store and process app data for us;
- An email delivery provider, which sends password-reset emails and receives only your email address and the reset code;
- RevenueCat, which manages subscriptions and receives a pseudonymous identifier and your purchase events — never your name or email address; and
- Google Play, which distributes the app and processes payments under Google's own privacy policy.
These providers are required to protect your data and may not use it for their own purposes. You can request the current list of our service providers by contacting us. We may also disclose information where the law requires it or in response to a lawful request from a public authority.
5. International data transfers
Our servers and databases are located outside Kenya, in the United States. When we transfer your data there, we do so in line with the Data Protection Act, 2019, and protect it with appropriate safeguards, including encryption in transit and strict access controls.
6. Information stored on your device
So that the app can work offline, it keeps a local copy of your progress and lesson content on your device and stores your sign-in credentials in the device's secure storage. Uninstalling the app removes this data from your device.
7. How long we keep your information
- Account information, preferences and learning progress: until you delete your account.
- Security logs: up to 30 days.
- Purchase records: after you delete your account, kept only in anonymised form, for as long as required for refunds, chargebacks, and tax and accounting purposes.
8. Deleting your account
You can delete your account at any time in the app under You → Delete account. If you no longer have access to the app, follow the instructions at ilo-flow.com/delete-account.
When you delete your account, we permanently delete your email address, display name, password, sign-in sessions and learning progress, we remove the identifiers from your device records, and we replace your username with an anonymous value. Purchase records are kept only in anonymised form, as described in section 7.
9. Your rights
Under the Data Protection Act, 2019, you have the right to be informed about how your data is used; to access your personal data; to have inaccurate data corrected; to have your data deleted; to object to or restrict certain processing; and to receive a copy of your data in a portable format. To exercise any of these rights, contact us at finotechsolutionsllp@gmail.com. We may need to verify your identity before acting on a request, and we will respond within 30 days. You also have the right to lodge a complaint with the Office of the Data Protection Commissioner of Kenya.
10. Children
The app is not intended for children under 13, and we do not knowingly collect their personal data. Users under 18 should use the app with the consent of a parent or guardian. If you believe a child has given us personal data without appropriate consent, please contact us and we will delete it.
11. Security
We use appropriate technical and organisational measures to protect your personal data, including encryption in transit, one-way hashing of passwords and access credentials, restricted access to our systems, and regular security updates. No system is completely secure, but we work continuously to protect your data. If a data breach affects you, we will notify you and the relevant authorities as required by law.
12. Changes to this policy
We may update this policy from time to time. We will post the updated version on this page and change the effective date above. If we make significant changes, we will also let you know in the app.
13. Contact us
Finotech Solutions LLP — partners CPA Juma Abdulrahman Bakari, CPA Meshack Mwendwa Benard and CPA Yusuf Kuto Hamad
Office: Mwembe Tayari, Mombasa County, Kenya
Postal address: P.O. Box 84791–80100, Mombasa, Kenya
Email: finotechsolutionsllp@gmail.com
Telephone: +254 713 883 912