Data Privacy Policy


Topup Mama (Topup Mama, we, us) takes your privacy very seriously and is committed to protecting your personal data. This Privacy Policy tells you what data we collect from you, how we collect, use, share and protect it. It also informs you of your privacy rights and protections you have under the relevant data protection laws. 

Important information and who we are

Topup Mama is the data controller and responsible for protecting personal data you share with us. By using our services or sharing your personal data with us, you agree with the terms of this privacy policy. It is your responsibility to review it carefully and understand the privacy practices it outlines.

Contact details

Small 360 Inc.

Suite 206,

651N Broad Street.

Middle Town, New Castle,



11th floor, West Park Towers,

Mpesi Lane, Nairobi.


Third Floor, Purple Mall,

360-350 Ikorodu Raod,

Ikeja Lagos.


Personal data we collect

Personal data refers to any information that is related to an identified or identifiable natural person. This does not include anonymous or pseudonymous data. We may collect, process, use, transfer and store the following types of personal data:

Identity data: This includes identifiers such as your name, title, username on Topup Mama, social media usernames or profiles on online platforms, KRA pin, National ID number, date of birth. 

Contact data: This includes your phone number, email addresses, physical address and other types of digital contact information.

Transaction data: This includes information about payment to and by you for products and services on the Topup Mama. 

Financial data: This includes data on your mobile payments, debit or credit card details, bank account details and other information necessary for completing transactions on the platform or determining creditworthiness.

Profile data: This includes your user name, password, transaction history, services and goods purchased from us, your preferences, interests as well as feedback provided through surveys as well as any information we need to understand your behaviour when using our products and services.

Technical and usage data: This includes data on how you use our mobile and web platforms including but not limited to frequency of access, features used and duration of use. We also collect data on the type of device you use, the type and version of browser, types and versions of browser plug-ins, operating systems, timezone, location,  login data and your IP (Internet Protocol) address. Location data will include both the location from which you access our services and products as well as the location information you provide. 

Marketing data: This includes information on your preferences for receiving communications from us or our third party partners.

This is not an exhaustive list and only serves as an example of the types of data we collect from you. In the course of using our services you may provide data on other persons. In doing so, you agree that you have obtained the necessary consent from these persons. 

It is unlikely that we will collect your sensitive data(sexual orientation, biometric data, sex, marital status, ethnicity,  race, health status, conscience, belief, genetic data, real property details, family details). However, in the event that we need to for specialized services or by law, your consent will be explicitly requested and the data will be subject to a high degree of protection as prescribed by data protection laws. 

How we use your data

We will use your personal data in the following circumstances:

  1. Where we need to perform a contract, are about to enter into one or have entered into a contract with you
  2. To process your orders and payments on our platform 
  3. To communicate to you about services and products Topup Mama provides, ask for feedback notify you of changes to the terms of service and privacy policy
  4. To improve the functionality and usability of our services, analyze performance and fix errors.
  5. To comply with legal obligations
  6. where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and

User Generated Content: Topup Mama may offer publicly accessible blogs or community forums or other ways to permit you to submit ideas, photographs, user profiles, writings, music, video, audio recordings, computer graphics, pictures, data, questions, comments, suggestions or other content, including your personal data (collectively, “User Content”). We, or other third parties may reproduce, publish, distribute or otherwise use User Content online or offline in any media or format. You should be aware that any User Content you provide may be published, collected, and used by others who access it. We do not control who will have access to the information that you choose to make public, and cannot ensure that parties who have access to such publicly available information will respect your privacy or keep your personal data secure. We would encourage you to consider this when deciding which information you share in respect of User Content.  This Privacy Policy does not apply to any information that you disclose publicly, share with others or otherwise upload, whether through the Services or otherwise. We are not responsible for the accuracy, use or misuse of any User Content that you disclose or receive through the Services.

Third-party marketing: We will get your express consent before we share your personal data with any third party for marketing purposes either through agreement with you, your acceptance of our terms and conditions for use of our Services or otherwise by communicating with you. 

Disclosure of personal data

We may disclose your personal data to:

  • Other companies affiliated with us;
  • A third party who acquires or substantially acquires all of its assets, in which case the personal data shall be one of the acquired assets;
  • Our agents and service providers;
  • External third parties we have partnered with to offer services to you
  • Law enforcement and regulatory agencies in connection with any investigation to help prevent unlawful activity or as otherwise required by applicable law;
  • Business partners and platforms necessary to sharing communications and promotions that you consent to

Transferring data

We may transfer your Personal Data outside the jurisdiction where we collected it either for ease of delivery of Services, storage or other necessary form of processing. When such transfer is necessary and for your benefit, we ensure a similar degree of protection is afforded to it by requiring implementation of relevant safeguards by the recipient of the personal data as required by applicable laws. By accepting this Privacy Policy, you are providing us with your express consent to transfer your personal data as laid out above.

‍Retention of data

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes for which it was collected, and for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. Your personal data may be retained for a longer period where you have consented to the retention, there has been a complaint, there is a prospect of litigation with respect to your use of our Services or for historical and statistical purposes.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

  • be informed of the use to which your personal data is being put;
  • access your personal data;
  • object to the processing of your personal data;
  • request restriction of the processing of your personal data;
  • request for correction of false or misleading personal data;
  • request the transfer of your personal data;
  • request erasure of false or misleading personal data - we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request; and
  • withdraw consent at any time where we are relying on consent to process your personal data.‍‍

If you wish to exercise any of the rights set out above or make a complaint with respect to how we process your personal data, please contact us .We may request specific information from you to enable us to confirm your identity, grant you access to your personal data or exercise any of your other rights in relation to such data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We will endeavour to respond to your complaint or request within fourteen days of its receipt. You will not have to pay a fee to access your personal data, or to exercise any of your rights in relation to the data, or to make a complaint. However, we may apply a charge if your request is clearly unfounded, repetitive or excessive. We may also refuse to comply with your request where permitted or required to do so under the law.