1. Who this policy applies to
This policy applies to people who visit Marble Networks websites, request connectivity or other services, submit an application, become customers, contact our teams or otherwise provide personal information to Marble Networks Limited.
2. Information we collect
Depending on the service and stage of your relationship with Marble, information may include identity and contact details, installation and service addresses, location pins, property access details, selected products and packages, billing information, communications, support records, signed declarations, consent records and technical information required to provision or operate a service.
Our online services may also process technical information such as IP address, browser or device information, security verification results, timestamps and audit records where necessary for security, fraud prevention and reliable operation.
3. How we obtain information
Information may be provided directly by you through our website, customer portal, application forms, email, telephone, WhatsApp, SMS or interactions with Marble staff. We may also obtain relevant service and account information from Marble systems and authorised service providers where necessary to identify an existing customer or fulfil a request.
4. Purposes of processing
We process information for purposes that include responding to enquiries, recognising existing customers, assessing coverage and feasibility, preparing and managing applications and service orders, scheduling surveys and installations, provisioning services, billing, support, service assurance, customer communications, security, fraud prevention, record keeping and compliance with lawful obligations.
Where Marble does not currently have network presence at your requested location, we may retain appropriate application and location information to assess network expansion, feasibility or future service availability, subject to our retention practices and your applicable rights.
5. Lawful and fair processing
Marble processes personal information only where there is an appropriate lawful basis. Depending on the circumstances, this may include taking steps requested by you before entering into a contract, performing a contract, complying with a legal obligation, pursuing legitimate business or security interests, or obtaining consent where consent is the appropriate basis.
6. Data minimisation
We aim to request only information that is reasonably necessary for the relevant service or interaction. Where Marble already holds sufficiently verified and current customer information, we may reuse it rather than asking you to provide the same information again.
7. Communications and marketing
We may use contact information to send messages necessary to process an application, deliver or support a service, provide billing information or communicate important operational matters.
Promotional or marketing communications are treated separately. Where consent is required, declining marketing will not prevent you from applying for or receiving Marble services.
8. Service providers and sharing
Marble may use carefully selected service providers to support functions such as hosting, communications, messaging, payments, network operations, security, customer support and other technology services. Personal information should only be shared to the extent reasonably necessary for the relevant purpose or where disclosure is otherwise permitted or required by law.
9. International processing
Some technology or communications service providers may process information using infrastructure located outside Kenya. Where cross-border processing occurs, Marble will seek to apply appropriate safeguards required for the information and processing involved.
10. Retention
Marble retains personal information for no longer than reasonably necessary for the purpose for which it was collected, including providing services, resolving disputes, maintaining appropriate business records, security and meeting legal, regulatory, accounting or contractual requirements.
Retention periods may differ depending on whether a person is only an applicant, becomes an active customer, has an outstanding transaction or is associated with records that Marble is required to preserve.
11. Your data protection rights
Subject to applicable law and the circumstances of the request, you may have rights relating to access to your personal information, correction of inaccurate information, objection to certain processing, restriction or deletion, portability and withdrawal of consent where processing relies on consent.
Marble may need to verify your identity before fulfilling a request involving customer-specific information.
12. Automated security checks
Marble may use automated security measures to protect public forms and systems from bots, abuse, excessive requests and fraudulent activity. These measures may process technical information such as IP address, browser information and security signals.
13. Children
Marble services are ordinarily contracted by adults or authorised organisations. If information relating to a child is required for a particular service or transaction, additional safeguards and appropriate authority should be applied before that information is processed.
14. Data incidents
Marble maintains processes intended to identify, contain, investigate and respond to suspected personal-data security incidents. Where notification is required by applicable law, Marble will follow the relevant reporting and communication requirements.
15. Changes to this policy
We may update this policy when our services, systems, business practices or legal obligations change. Material revisions will be published with an updated effective date and policy version.
16. Contact Marble about your privacy
For privacy, personal-data or data-protection enquiries, contact:
You may also have the right to raise a complaint with the Office of the Data Protection Commissioner of Kenya.