Privacy policy
This Privacy Policy explains how Mogo Auto Limited of company registration number PVT-AJUR7BX, (the “Company”, “we”, “us”), as the personal data controller processes information about you during the recruitment process when you apply for a vacancy at the Company. You will also find information about your rights regarding the personal data you provide to us. If you have any questions regarding this Privacy Policy, contact us at +254 768 469 112 or write to our data protection officer at [email protected].
The Company is a part of Eleving Group – group of companies directly or indirectly controlled by Eleving Group, incorporated in Luxembourg.
What personal data we process and why?
1. Assessment of your application
When you apply for a position at the Company, we may process different types of personal data for multiple purposes. In some cases, when the particular position requires it, we may ask for additional information.
During the recruitment process, we process your personal data to evaluate your application and suitability for a particular position. For this purpose, we process the following data:
- your full name;
- contact details, including without limitation, your postal and physical address, telephone number and email address;
- other personal data in your curriculum vitae (“CV”), application or cover letter;
- information on your skills, experience, qualification and other information you have made publicly available on social networking sites including LinkedIn; and
- salary expectations or requirements;
- any other information you have added to the application, practical task and provided to us during the job interview or when you communicate with us.
- For purposes of entering into an employment contract, we may require a copy of your National Identity Card (ID) or other identification documents. This is used for identity verification to confirm that you are the person you claim to be.
2. Proof of conduct
As a general requirement, we need to ascertain that an applicant has good reputation and no criminal background. Therefore, we may require you to provide a Certificate of Good Conduct, which will include your name, personal ID number, address and other information which may be contained in such document. We will process this information based on our legitimate interests to ascertain that the recruited employee has good standing to protect our business interests and assets.
3. Conducting background checks and assessment of your professional reputation
Based on our legitimate interests to verify and check the information you have provided, we may process your national ID and/or educational certificates to carry out:
- Background checks and collection of references – to facilitate the processing of equivalent record checks to confirm your previous employment (contact your past employers to confirm dates of employment, job title, reason for leaving. Your current employer will not be contacted unless you explicitly allow us to do that;
- Education verification - we may contact your educational institutions to verify your attendance dates and degree(s) earned;
- Statutory Remittance Compliance – we will verify your compliance with statutory obligations, including but not limited to the Higher Education Loans Board (HELB), where applicable
To complete these checks, we may obtain your data from government portals or relevant public authorities.
Certain laws and regulations, which are applicable to us, stipulate that certain positions (for example, board members, risk managers, money laundering and anti-terrorist and anti-proliferation financing specialists) may not be held by persons with previous criminal convictions. Thus, if you apply to such position, we may ask you to provide details of your criminal conviction record and carry out an in-depth assessment of your professional reputation. During such assessment we may process information, which reveals:
- whether your act or omission has led to the declaration of bankruptcy or revocation of the license of another institution due to a decision of a financial supervisory authority; or
- whether you have been convicted of a criminal offense and your criminal record has not been deleted from the Criminal Registry; or
- whether you are covered by a legal or court order prohibiting you from doing business, holding a certain position, operating in a certain field of activity or doing certain business.
We will process this information to exercise our rights as an employer in the field of employment as well as based on our legitimate interests to ensure the requirements for specific positions as set in the applicable laws and to ensure the protection of the company's interests and activities. We may obtain the information from the documents and information submitted by you, as well as by carrying out our assessment of your professional reputation, including using publicly available data and other sources of information.
4. Protecting our interests and legal rights
In case we need to enforce or defend our legal rights or take part in any other legal process, we may process your name, surname, contact details and other personal data we may have collected about you during the recruitment process. We will process this information based on our legitimate interests to protect our rights, resolve disputes, prevent illegal activities such as fraud or abuse and protect our legal interests.
Who can receive your personal data?
If reasonably necessary, during the recruitment process we may share your data with other legal entities, which are a part of Eleving Group, for example, if these entities provide assistance in the recruitment process or if the position is managed by a team member of another Eleving Group entity.
If you have submitted a general application to any open vacancy, your data may be used in other recruitment processes of that Eleving Group company, who has an open vacancy most suitable for you.
Your personal data may be shared with third parties who provide services during the recruitment process (for example, hosting and data storing services, HR tools, legal, IT and other advisors, when reasonably required). These service providers may only receive the minimum required amount of personal data and only when necessary. We will share your personal data only with such service providers who have undertaken to comply with confidentially requirements as well as obligations set out in applicable data protection laws and our cooperation agreements.
If any of the service providers are located outside Kenya or there are other legitimate reasons, we may need to transfer data outside Kenya. In such case, the personal data will be transferred in compliance with the requirements of the Data Protection Act No. 24 of 2019.
If there are any complaints about the recruitment process or we need to protect our legal rights, we may also share information with the relevant public authorities. We may need to share your information if we are required to do so in accordance with the applicable laws or we have received such request from a public authority.
4. How long do we keep your personal data?
If you have indicated that you are interested in other suitable vacancies or submitted a general application, then we will retain your personal data for two (2) years. After this period, we will erase or anonymize your data and use it only for statistical purposes.
If you have indicated that you are not interested in other suitable positions, or you have revoked your consent, we will erase or anonymize your personal data four (4) months after the end of the particular recruitment process.
This retention period is based on our legitimate interests to maintain records necessary for resolving disputes or defending against potential legal claims related to the recruitment process.
We may continue to store copies of your personal data when reasonably necessary to comply with our legal obligations, to resolve disputes between us and/or to protect our legal interests.
5. Your rights
As a data subject you have certain rights in relation to the processing of your personal data.
You have the right to request access to your personal data. If you believe that the data, we have on you is outdated, incorrect or incomplete, you have the right to correct or amend it.
You also have the right to data portability and receive your data for transmission to another controller. Under certain circumstances, you have the right to request restriction of processing.
If we process your personal data based on our legitimate interests, you have the right to object to such processing. If we receive such objection, we will no longer process your personal data, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.
You have the right to withdraw your consent for the processing of your data, which is based on consent. Revoking of consent will not affect the lawfulness of processing based on consent before its withdrawal.
Where we process your personal data based on consent (such as retaining your data for future suitable vacancies), you are under no obligation to provide such consent, and the withdrawal of consent will not affect your application for the current role. If you withdraw your consent for the current role to which you applied to, we will remove your application from the pool of candidates and stop processing of your personal data. Please note that we may retain your information for 4 (four) months after the revoking of your consent to ensure protection of our legal rights.
We do not require special category personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic, biometric, health data or data concerning person's sex life or sexual orientation. If you choose to provide such information, it will not be considered during the recruitment process, and we will process it according to this Privacy Policy.
You can request erasure of your personal data. Please note that we will not be able to delete the data, which we are obliged to retain in accordance with applicable laws or which we require for the establishment, exercise or defence of legal claims.
You can exercise your rights by submitting your request in a written form to the email address [email protected]. We will evaluate such requests in accordance with the applicable law and will respond within thirty (30) days.
Please note that we will need to verify your identity before we disclose any information, therefore we may ask you give us additional information.
Furthermore, if you believe that we have unlawfully processed your personal data, you have the right to submit a complaint to the relevant Data Commissioner appointed under section 6 of the Data Protection Act No. 24 of 2019.
6. Privacy policy changes
We may occasionally amend this Privacy Policy. Any amendments will be posted along with our post on open positions in the Company. The version of this Policy is effective as of December 2025.