Privacy
Policy

1.1 Who we are

We are Urim Trader ("Company", "we", "us", or "our"), a company registered in Kenya. We operate the mobile application Urim Trader (the "App") and related services. Our mission is to provide a risk-free, simulated environment for learning about the Nairobi Securities Exchange (NSE).

1.2 Scope of this Privacy Policy

This Privacy Policy describes how we collect, use, process, and disclose your information, including personal information, in conjunction with your access to and use of the Urim Trader App and our associated services (collectively, the "Services"). By using our Services, you consent to the practices described in this policy.

1.3 Effective Date and Updates

This policy is effective as of January 8, 2026. We may update this Privacy Policy from time to time. If we make material changes, we will notify you by updating the date at the top of this policy and, where appropriate, by providing notice through the App.

2.1 Information You Provide Directly

• Account Information: When you register, we collect your username, email address, and password.
• Profile Information: You may choose to provide a profile picture, biography, or other personal details.
• Support Communications: If you contact us for support, we collect the information you provide in your query (e.g., email content, screenshots).
• Preferences: We collect your settings choices, such as language preference, currency display, and notification settings.

2.2 Information Collected Automatically

• Usage Data: We collect information about your interactions with the App, such as the pages or screens you view, the trades you simulate, and the features you use (e.g., Monte Carlo simulations, Health Scores).
• Device Information: We collect data about the device you use to access the App, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
• Log Data: Our servers automatically record information, including your IP address, access times, and app crashes.

2.3 Information from Third Parties

• Authentication Services: If you link, connect, or login to the App with a third-party service (e.g., Google), we receive certain information, such as your profile information, from that service.
• Analytics Providers: We may receive aggregated data from analytics partners to help us understand how users engage with our Services.

2.4 Children’s Data

Our Services are not intended for children under 18 years of age. We do not knowingly collect personal information from children under 18. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information.

3.1 Providing and Improving the Service

• To create and maintain your account.
• To process your simulated trades and track your virtual portfolio performance.
• To provide the features and functionality of the App (e.g., real-time NSE data, AI insights).
• To troubleshoot technical issues and improve the stability of the App.

3.2 Communication and Support

• To send you technical notices, updates, security alerts, and support and administrative messages.
• To respond to your comments, questions, and customer service requests.
• To send you push notifications regarding market pulses or price alerts (if enabled).

3.3 Analytics and Personalization

• To monitor and analyze trends, usage, and activities in connection with our Services.
• To personalize your experience, such as suggesting stocks based on your viewing history (simulated data only).
• To improve our AI algorithms and educational content.

3.4 Security and Fraud Prevention

• To detect, investigate, and prevent fraudulent transactions and other illegal activities.
• To protect the rights and property of Urim Trader and others.

3.5 Legal and Regulatory Purposes

• To comply with applicable legal obligations, such as the Data Protection Act, 2019 of Kenya.
• To enforce our Terms and Conditions.

4.1 With Service Providers

We share information with third-party vendors and service providers who perform services on our behalf, such as:

• Cloud Hosting: To store our data securely (e.g., Railway, Firebase).
• Analytics: To understand user behavior (e.g., Google Analytics).
• Communication: To send emails and notifications.

4.2 For Legal Reasons

We may disclose your information if we believe it is necessary to:

• Comply with a law, regulation, legal process, or governmental request.
• Protect the safety of any person.
• Address fraud, security, or technical issues.
• Protect our rights or property.

4.3 Business Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction as permitted by law and/or contract.

4.4 With Your Consent

We may share your information with third parties when we have your consent to do so.

5.1 Where We Store Your Data

Your personal data is processed and stored on secure servers. While we operate from Kenya, our cloud service providers may store data in other jurisdictions.

5.2 Cross-Border Transfers

If we transfer your personal data out of Kenya, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved for use which give personal data the same protection it has in Kenya.

6.1 Access, Correction, and Deletion

You have the right to:

• Access: Request a copy of the personal data we hold about you.
• Correction: Request that we correct any inaccurate or incomplete data.
• Deletion: Request that we delete your personal data ("Right to be Forgotten"), subject to certain legal exceptions. You can delete your account directly within the App settings.

6.2 Opt-Out of Marketing

You can opt-out of receiving promotional communications from us by following the unsubscribe instructions in those messages or by adjusting your App settings.

6.3 Withdrawal of Consent

Where you have provided your consent to the collection, processing, and transfer of your personal data, you have the right to withdraw your consent at any time.

6.4 Complaints to the Office of the Data Protection Commissioner

If you believe we have infringed your rights, you have the right to lodge a complaint with the Office of the Data Protection Commissioner (ODPC) in Kenya.

7.1 Our Security Measures

We use administrative, technical, and physical security measures to help protect your personal information. These measures include encryption of data in transit and at rest, access controls, and regular security assessments.

7.2 What You Can Do

Please keep your password secure and do not share your account credentials with anyone. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

8.1 How Long We Keep Data

We retain your personal data only for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

8.2 Deletion Requests

Upon your request to delete your account, we will delete your personal information from our active databases. However, we may retain certain information in our archives to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use, and/or comply with applicable legal requirements.

9.1 What We Use

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. This helps us track activity on our Services and hold certain information.

9.2 Managing Cookies

Most web browsers are set to accept cookies by default. You can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our App.

12.1 How to Reach Us

If you have questions or comments about this policy, you may contact us by email at hello@urimtrader.me, by phone at 0114374864, or by post.

12.2 Data Protection Officer

We have appointed a Data Protection Officer to oversee compliance with this Privacy Policy. If you have any questions about this Privacy Policy or how we handle your personal information, please contact the Data Protection Officer at hello@urimtrader.me.