Greenlight Planet commits to protecting the personal and private data that it collects from customers, distribution partners, employees, and external affiliates. This policy outlines the measures Greenlight Planet takes to keep sensitive data secure as well as the expectations of all Greenlight employees to protect the personal data they may come into contact with.

This policy applies to all employees and contractors of Greenlight Planet, and it pertains to all employee, customer, and distribution partner data collected and stored by Greenlight Planet.

Data protection principles

Greenlight Planet commits to processing data in accordance with the regulatory requirements of the countries we operate in. Across all companies, all data collected about our customers, employees, and any other personal or sensitive information will:

• Be collected for explicitly specified and legitimate purposes;
• Be limited to what is necessary, in relation to the purposes for which they are processed;
• Not be used for any purpose other than the communicated and specific intent;
• Be processed lawfully, fairly, and in a transparent manner;
• Be accurate and kept up to date; every reasonable step will be taken to ensure that data that are inaccurate are erased or rectified without delay;
• Be stored in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the data are processed;
• Be processed in a manner that ensures appropriate security of the data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage.

Note that data may be further processed or stored for longer periods of time for archiving purposes solely if intended to serve the public interest, or for scientific, historical, or statistical purposes, subject to the relevant regulation to safeguard the rights and freedoms of individuals.

Data collection and processing practices.

Data may only be processed on the following grounds: through consent, contract, legal obligation, public request, or legitimate interest as defined by local regulation.

Greenlight Planet will follow the legal grounds for processing data in each country of operation.

Where consent is required to lawfully process data, evidence of willing opt-in consent shall be stored with the data.

When communications are sent to individuals based on their consent, the option to revoke that consent should be clearly available, and Greenlight must ensure that such revocation is accurately and immediately reflected in its systems.

Where legally required, Greenlight will apply for relevant certifications or permissions, to collect, process, and store data through the designated regulatory bodies. For example, in Kenya, Greenlight Planet will seek certification to be deemed a ‘data controller’ through the commissioner of data protection.

Guidelines around the type of data collected, processed, and stored:

• Greenlight Planet will ensure that personal data are adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed.
• Greenlight Planet will take reasonable steps to ensure that employees’, distribution partners’, commission sales agents’ and customers’ personal data is accurate and kept up to date.
• Greenlight will put in place and follow an archiving policy for each country in which data is processed and review this process annually or as per each country’s regulations. The archiving policy will indicate which data should or must be retained, for how long it should be retained, and reasons for retaining that data.

Data security

Greenlight Planet will ensure that data is stored securely, using current, modern software. Access to personal data will be limited to personnel that need access, on the basis of their job descriptions.

Additionally, the following measures shall protect data security:

• measures to avoid unauthorized sharing of information;
• safe and thorough practices to make sure that deleted data is irrecoverable;
• the presence of back-up and disaster recovery solutions;
• password requirements to ensure access is limited to authorized individuals;

Data sharing principles

Data may need to be shared between authorized individuals to process, interpret, or make decisions based on collected information. When data is shared, the following principles must be adhered to:

• For projects, where data is shared for an appropriate use that delivers public benefit:
  • Evidence of an appropriate aim and feasibility, in line with a relevant purpose test, where applicable;
  • Evidence that legal, ethical, and moral considerations have been addressed;
  • Indication of which individuals or groups will work on the project;
  • Clear communication of which data will be used and for what purposes and expected outcomes, as well as the timeframes for which the user will use the data;
• For people, where users have appropriate authority to access data:
  • A formal application by a user to become an authorised user;
  • Evidence that the user is part of an organization that has an overarching agreement with a data custodian;
  • Confirmation that the user is technically capable of data analysis;
  • A signed agreement between between the individual with access and Greenlight Planet governing access and use of data to be shared;
  • Evidence that the user has completed training regarding their rights and responsibilities as a data user.
• For settings: the environment in which the data is shared will minimize the risk of unauthorized use or disclosure. Specifically:
  • Work areas will be designed to minimize exposure to unauthorized individuals;
  • Workstations will be secured when the authorized user steps away;
  • Forwarding or sharing data with unauthorized individuals will be prohibited;
  • Outputs intended to be shared with a wider audience will require approval from the data custodian;
  • Security breaches or incidents will be communicated to the data custodian(s) as soon as practicable;
  • Data will not be removed from the approved setting without authorization;
  • Login details will not be shared with unauthorized individuals.
• Appropriate and proportionate protections will be applied to the data.
• Output: the output from a data sharing agreement must be appropriately safeguarded before anything can be shared.

Breach of security

In the event that a breach of security leads to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, data, Greenlight Planet shall promptly assess the risk to the organization, employees, partners, sales agents, customers, or other individuals, and follow the reporting and escalation procedures defined for such incidents per local legislation. For example, in Kenya, such security breaches must be reported to the data protection commissioner.

Management of data security at Greenlight Planet

The Risk function shall take responsibility for Greenlight Planet’;s ongoing compliance with this policy. Any concerns, suspected breaches of, or questions about this policy should be addressed to the head of the Risk department, Sarah Mijabi.

Greenlight Planet will register with the Data Protection, Information Commissioner’s Office, or other relevant oversight office as required in each country where we process employee, partner or consumer data.

This policy shall be reviewed annually and updated periodically, in line with any required or changing regulations.

INTRODUCTION

Greenlight India Private Limited (‘Greenlight India’) is a for-profit social business that develops and manufactures, high quality solar powered home energy solutions for off-grid and under-electrified households and businesses. Greenlight India is owned and operated by engineers, sales force experts, and operations gurus who love to solve difficult problems that change our customers’ lives before our eyes. Our offices across the world are cultural melting pots of technological and grass-roots innovation. Corporate Social Responsibility (CSR) has been an integral part of the way we have been doing our business since Greenlight’s inception in 2008. The Company’s activities and innovation has played pivotal role in improving the lives of nearly 50 million people around the world. Our corporate values, internal policies and governance structures are all grounded by our fundamental beliefs in promoting equality of opportunity, respect, integrity, and inclusivity, and we are committed to enabling these ideas as an employer. These principles underlie our commitments to being a collective of socially responsible corporate citizens.

OUR CSR VISSION

Through sustainable measures, our corporate social responsibility activities should contribute to the social, economic and/or environmental development of the communities we serve as consumers or employees.

OUR CSR MISSION

The purpose of this policy is to state our commitment to making corporate social responsibility a company-wide priority and to describe the guidelines of how we develop and run our CSR activities.

OUR CSR RESPONSIBILITIES

A) Towards our communities – We will involve communities surrounding our operations to bring about a positive change in their lives through holistic, sustainable, and integrated development.

B) Towards our customers – We commit to serving our customers by designing sustainable products and services to meet their core home energy needs, by treating them with dignity and consideration, and by employing respectful businesses practices in all our customer interactions.

C) Towards our business partners – We require our suppliers and distribution partners to follow fair and ethical business and employment practices, and we commit to conducting our business interactions with such vendors and customers with respect and integrity.

D) As corporate citizens – We reaffirm our commitment to conduct our business with environmental accountability. We will endeavour to adopt environment-friendly technologies and energy efficiency in our operations while continuously monitoring and reducing emissions.

E) As an employer – We will foster a work culture grounded in ethical practices and based on the expectation that employees conduct their work with integrity, a commitment to our social mission, and the spirit of inclusivity. We recognize and reward professional growth opportunities based solely on merit. We strive towards ensuring safe and healthy work environments for our employees and contractors and towards minimizing our impact on the environment.

CSR ACTIVITIES, PROJECTS AND ACTIVITIES

The CSR activities we pursue will be in line with our stated vision and mission, focused not just around our plants and offices, but also on communities across India, based on the need and our ability to contribute in a positive, meaningful way. The scope of CSR activities may include, but not be limited by, the following projects and programs:

1. 1. Ensuring environmental sustainability and ecological balance through:
      • Planting drives in schools, villages, our manufacturing units and office premises and other areas in general;

      • Reviving endangered plants, promoting agro-forestry;

      • Protection of flora and fauna;

      • Conservation of natural resources;

      • Maintaining quality of soil, air, and water;

      • Adoption of wastelands to cultivate plants;

      • Promoting biodiversity;

      • Animal welfare and veterinary services;

      • Technical support and knowhow for improving farming practices for small holder farmers.

      • Promoting alternative energy resources.

   2. Promoting safe and preventative healthcare through awareness programs and health check-ups,
   3. Eradicating hunger, poverty, and malnutrition:
      • Provision of food, nutrition supplements, clothes, and other supplies for the poor.

      • Supporting nutrition in anganwadi centers.

      • Promoting sanitation and providing safe drinking water

   4. Promotion of education especially among children, women, elderly and the differently abled including
      • Tutoring, literacy or other informal education programs.

      • Supporting schools with necessary infrastructure like benches, toilets, potable water, fans, etc.

      • Supporting children in the pursuit of higher education.

   5. Employment and livelihood-enhancing vocational skills and projects including tailoring, beautician, mehandi application, bee-keeping, food processing and preservation, and other life skill training.
   6. Contribution to the Prime Minister’s National Relief Fund or any other fund set up by the India’s central or state governments for socio-economic development and relief for the welfare of ‘scheduled castes’, the ‘scheduled tribes’, other ‘backward classes’, recognized minorities and women;
   7. Such other activities as the Board may consider appropriate.

EXCLUSION FROM CSR

The following activity shall not form part of the CSR activities of Greenlight Planet India Pvt. Ltd.:-

• The activities undertaken in pursuance of normal course of business of a company

• CSR activities, projects, or programs that only benefit the employees of the Company and their families.

• Any direct or indirect contribution to a political party or cause.

• CSR projects or programs or activities undertaken outside India.

CSR COMMITTEE

A CSR committee shall be formed as per the applicable laws, and the committee shall be responsible for the implementation, monitoring, and review of this policy and various projects and/or activities undertaken under the policy. The CSR committee shall submit periodical reports to the board of directors.

CSR BUDGET

The total budget for the CSR projects will be decided by the CSR committee in accordance with applicable provisions of the Act and the CSR Rules. Currently, the corpus for the purpose of carrying on the aforesaid activities would include the following:

• 2% of the average net profit made by the Company during immediately preceding three financial years.

• any income arising there from.

• surplus arising out of CSR activities carried out by the company and such surplus will not be part of business profit of the company.

IMPLEMENTATION, MONITORING AND REVIEW MECHANISM

The CSR activities will be driven under the guidance and support of the CSR Committee and the Board. The CSR committee will play a significant role in ensuring that the CSR policy is embedded across ’s operations and that the CSR initiatives are in line with this policy.

The CSR committee will be responsible for monitoring approved projects and fund disbursals for such projects. The CSR committee will put in place a transparent monitoring and reporting mechanism for ensuring effective implementation of the projects, programs and activities proposed to be undertaken by . Such monitoring mechanisms will include visits, meetings and progress/status reporting by the project teams.

Any or all provisions of this CSR policy may be amended by the Board based on the recommendations of the CSR Committee or in accordance with any statutory guidelines that may be issued from time to time.

Please read carefully the terms and conditions before using this service. Key principles are explained in simple terms and highlighted below.

The Greenlight Planet EasyPesa Loan Product (“Service”) enables you to borrow pre-approved amounts repayable over short periods of time (each a “Loan”). The Service is operated by Greenlight Planet Kenya Limited (“we” or “us”) subject to these Terms of Service (“Terms”).

TERMS OF SERVICE

1. This is a Contract.
   These Terms constitute a contract. You may not use the Service if you do not accept these Terms. By using any part of the Service, you accept these Terms. If you are under eighteen (18) years of age, you may not use the Service. The laws of Kenya including CHAPTER 23 LAW OF CONTRACT ACT apply to this Contract.
2. You accept our privacy policy.
   To provide you with the Service, you must authorize the provision of certain personal information to us as described in our privacy policy [Link]. Our privacy policy governing the Service is incorporated into these Terms (“Privacy Policy”). By accepting these Terms and using the Service, you consent to and authorize the collection and use of personal information in accordance with the Privacy Policy.
3. You must share truthful information.
   You agree to provide true, accurate and complete information about yourself as prompted (“Account Data”) and you confirm that you have full authority to provide the Account Data including the information relating to the person you have provided as your referee. You agree to indemnify and keep us indemnified in full against all demands or claims that may be brought against us with respect to any information related to third parties provided by you to us during your use of the Service including any information related to your emergency contacts. You also agree to update your Account Data to keep it current. You authorize us and our third-party service providers, such as network providers or credit reference bureaus, to verify Account Data.
4. You must keep your account secure.
   You are responsible for maintaining the confidentiality of your account information. Furthermore, you are entirely responsible for any and all activities that occur through the use of your account. You agree to immediately notify us of any unauthorized use of your account or any other breach of security.
5. We reserve the sole right to accept or reject your Loan application
   We reserve the right to decline the Loan application for any reason.
6. Loan disbursement, fees, and repayment will be done via your mobile money account
   We reserve the right to decline the Loan application for any reason.
7. Fees schedule
   If we accept your Loan application and grant you a Loan, we will charge the following fees.
   -“Commitment fee” paid upfront by you before the loan is credited to your mobile money account
   -“Service fee” that will be added to the Loan and due as part of the repayment schedule
   -“Late fee” charged for every 7 days that you fail to pay in accordance with your repayment schedule, chargeable up to 4 times.
8. Your loan is expected to be repaid according to the repayment schedule
   Repayment Schedule
   Your loan and services fees are to be repaid in the form of 28 equal daily instalments.
9. You agree to be communicated with via the phone number shared via call or SMS
   Greenlight Planet Kenya Ltd’s acceptance of your application for any Service will be communicated via SMS. We will inform you of your loan amount, repayment amount and date of payment via SMS. If you require information you can contact Greenlight Planet Kenya Ltd’s call centre.
   You hereby acknowledge and accept that the acceptance by Greenlight Planet Kenya Ltd of your application for a Service does not create any contractual relationship between you and the Mobile Money Providers beyond the terms and conditions that apply to your Mobile Money Account from time to time
10. Taxes
    All payments to be made by you in connection with these Terms and Conditions are calculated with regard to any taxes payable by you. Taxes payable in connection with the payment, you will pay Greenlight Planet Kenya Ltd an amount equal to the payment multiplied by the appropriate rate of tax. You must do so at the same time as making the payment.
11. You must repay by the Due Date, if not we will take actions to recover the loan
    You must repay the Loan by the dates specified when you take the Loan (“repayment schedule”). It is important that you repay the Loan according to the repayment schedule. In case of any delay, you are also liable to pay late fee(“Late Fees”) specified at the time of application of the Loan in addition to the normal repayments.
    
    If you fail to repay within 30 days you will be in default. This default may be reported by us to any credit reference bureau duly licensed under the Credit Reference Bureau Regulations 2013, within 30 (thirty) days of your default, and such report may affect your ability to borrow money in the future. You will also become responsible for the reasonable costs we, or our service providers, may incur in collecting the payment in accordance with applicable law.
    
    We may contact you and/or your emergency contacts. You expressly agree that, as part of the Service, you may, from time to time, receive communications from us via text message. You also expressly authorize us to contact your emergency contact to verify your information or when we are unable to contact you or when we have not received a repayment from you. You confirm that your emergency contact has consented to the sharing of his/her information with us and to us contacting them with respect to your use of the Service.
    
    Additionally, we may report you to the local authority for arbitration in lieu of collection of the amount owed. Greenlight Planet Kenya Ltd reserves the right to surcharge any additional expenses incurred in the collection of these amounts.
    
    We may handover your details to third party debt collectors in cases of default and after making continued attempts to reach out to you on all available channels without success.
12. Assignment of obligations
    We may at any time assign, charge, subcontract, delegate, declare a trust over or deal in any other manner with any or all of its rights and obligations under this Contract.
    
    You shall not assign, transfer, mortgage, charge, subcontract, delegate, declare a trust over or deal in any other manner with any of its rights and obligations under this Contract, without our prior written consent.
13. Customer Declaration
    In connection with this application and/or maintaining a credit facility with the Greenlight Planet Kenya Ltd Loan Product, I authorise Greenlight Planet Kenya Ltd to carry out credit checks with or obtain my credit information from, a credit reference bureau. In the event of the account going into default, I consent to my name, transaction and default details being forwarded to a credit reference bureau for listing. I acknowledge that this information may be used by banking institutions and other credit grantors in assessing applications for credit by me, associated companies, and supplementary account holders and for occasional debt tracing and fraud prevention purposes
14. Disclosure of information
    You agree that Greenlight Planet Kenya Ltd may disclose details relating to your Greenlight Planet Loan Product account to any third party including credit reference bureaus, if in our opinion such disclosure is necessary for the purposes of evaluating your creditworthiness.
    
    You agree that the Lender may disclose details relating to your Greenlight Planet Kenya Ltd Loan Product account including details of your default in servicing financial obligations on your Greenlight Planet Kenya Ltd Loan Product account to any third party including credit reference bureaus for the purpose of evaluating your creditworthiness or for any other lawful purpose.
15. Modification of these Terms
    We may modify these Terms. These Terms may be modified without notice at any time in the future. Changes will be posted at the Greenlight Planet website or the SunKing shops. It is your responsibility to remain informed of any changes as you are bound by the latest version of the terms.