Privacy Policy

1. Purpose of this Privacy Policy:

The following describes the information gathering and dissemination practices and policies of Mojagate Limited, trading as ‘How Low Enterprises’ (hereinafter HOW LOW), for the website www.howlow.co.ke and any other method of auction entry or engagement in relation to any Mojagate product or service, including via SMS, USSD, and Mobile Money.

2. Use of your information:

  1. 2.1. Your personal data (meaning any information about you from which you can be personally identified, such as your name, address, telephone number or email address, ID, KRA pin, etc; and hereinafter referred to in this Privacy Policy as "your information"), will be processed by HOW LOW to provide the full range of the services available to you, including ancillary services offered by Mojagate Limited and/or its partners and affiliates. Your information is collected when you open an account with us, which takes place when you engage us via SMS, USSD, Mobile Money, or via our website; or when you contact our Customer Service Department on +254 111 005 111 or email [email protected]
  2. 2.2. While the website, USSD menu, or SMS communication may from time to time contain links to websites operated by parties other than HOW LOW, HOW LOW is not responsible for the privacy practices or content of any such websites.
  3. 2.3. By using any of HOW LOW’s services, you acknowledge that you have read and agree to both the HOW LOW standard terms and conditions and this Privacy Policy and that, where you provide us with your information, including the submission of a query to us through our website, or where you only fully or partially complete an account registration, (including via SMS, USSD, and Mobile Money), you consent to the use by HOW LOW of your information for, inter alia, the purposes set out in paragraph 3 of this Privacy Policy.
  4. 2.4. If you do not wish to provide your information on the basis set out in this Privacy Policy, you should contact our customer service department. However, if you do not provide certain basic information, you may not be permitted to engage with How Low and/or make full use of all HOW LOW services.
  5. 2.5. HOW LOW offer bidders the opportunity to "opt out" from keeping them informed of future events, offers and promotions from HOW LOW by simply using USSD code *456*9*5#.

3. The type of information we collect and how we use it:

  1. 3.1. HOW LOW collects your information to:
  2. 3.1.1. Enable us to set up your account so that you can make full use of all the features of the services, including crediting your account with funds deposited, placing bids, engaging in relation to your bids, updates on auction results, etc.
  3. 3.1.2. Enable us to receive questions and comments from you through our Contact Us page, email or our Customer Service line, and for us to be able to respond appropriately;
  4. 3.1.3. Comply with relevant regulations regarding your registration;
  5. 3.1.4. Keep you informed of future events, offers and promotions from HOW LOW, via email, SMS, or any other relevant mode of communication if you do not explicitly "opt out” of our marketing campaigns using USSD *456*9*5#;
  6. 3.2. In addition to the broad purposes identified in paragraph 3.1 above, HOW LOW will use your information, including sharing your information with our third-party partners and subcontractors who process data (including, where appropriate, your information) on our behalf, for:
  7. 3.2.1. Setting up, operating and managing your account;
  8. 3.2.2. Providing any of the services which are requested of us, and for any proper purpose connected with such provision;
  9. 3.2.3. Verifying the accuracy of your information, including disclosure of such information to third parties (including financial institutions, age verification, and credit reporting agencies) in connection with such purposes (a record of the search will be retained and the third party may use the information to assist other companies for verification purposes);
  10. 3.2.4. Preparing statistics related to the use of the services by you and other customers and other business statistics at How Low’s discretion;
  11. 3.2.5. Preparing and displaying appropriate individualised and/or targeted marketing material and content;
  12. 3.2.6. Periodically sending account holders written communications to announce important service changes, technical issue updates, and changes to the Terms and Conditions (which includes this Privacy Policy);
  13. 3.2.7. Complying with our regulatory duties, obligations, and responsibilities to the Auctioneers Board;
  14. 3.2.8. Conforming to and complying with legal requirements and processes;
  15. 3.2.9. Investigating suspected unlawful, fraudulent, or other improper activity connected with the services; or reporting crimes or suspected crimes, including money laundering or any fraud; and
  16. 3.2.10. Any other purpose which is deemed necessary or beneficial for the performance of our contractual obligations to you or is deemed beneficial to you as a customer or How Low as a business, including but not limited to actively engaging you in customer surveys via telephone, SMS, email, or other mode of communication to improve our products and/or those of our partners and affiliates.
  17. 3.3. HOW LOW may from time to time send you unsolicited information regarding third- party commercial offers or advertisements once you have engaged us, or are registered as bidder, however you can opt out of this service by contacting customer service or using our USSD opt out service, USSD *456*9*5#.
  18. 3.4. HOW LOW may from time to time use your name, region or other personal information for advertising or promotional purposes, particularly if you are a successful bidder, as per the provisions related thereto in our terms and conditions.
  19. 3.5. We may transfer and/or assign your information if we transfer or sell our business or any part of it; including in the event of insolvency or bankruptcy.
  20. 3.6. If at any time you wish us to stop processing your information for the above purposes, then you must contact our Customer Service Team and we will take the appropriate steps to cease the processing of your information. Please note that this may mean that your account may have to be closed.

4. Updating your information:

You may update or delete your information at any time by contacting our Customer Service team. It is advised that if any details change from that when you first registered, you update your account accordingly to avoid a breach of the standard HOW LOW Terms and Conditions.

5. Cookies Policy

6. Contacting us:

If at any time you believe that HOW LOW has not adhered to the principles contained within this Privacy Policy, please notify us by contacting our Customer Service team on +254 111 005 111 or email [email protected] and we will use all commercially reasonable efforts to promptly determine and correct the problem.

© 2020-2022 How Low Enterprises Ltd. All rights reserved. Auctioneers licence no 006660 held by Mr George Gitonga Muchiri, Auctioneer, trading under the name Fantasy Auctioneers duly authorized and regulated by the Auctioneers Board of Kenya. Liquor Licence Number LID18904 held by Tipsy Corner LLP.