Privacy Policy

The controller is Kembielti, reachable at contact@kembielti.tn.

The processing described below is subject to organic law no. 2004-63 of 27 July 2004 on the protection of personal data.

• Company and user identification: legal name, tax identification number, address, sector, bank accounts (account number, bank, branch); name, e-mail address, role and account identifier of each user.
• Instrument data: amounts, dates, references (the instrument's number, an invoice reference), the mentions carried on the instrument, including the drawee's name and address and the paying bank branch, the parties' legal identifiers — national identity number, tax identification number, bank account number — and the scanned image of the document.
• Settlement data: for every settled instrument, the outcome (on time, late, unpaid), the amount, the due date and the settlement date.
• Sending data: for every instrument sent to another company, the matricule fiscal and the name the sender gives for it, the name under which a company registers when the instrument was waiting for that matricule fiscal, the sending and answer dates and, for a refusal, the note that comes with it.
• Billing data: the plan taken out, the contracted price, the documents issued and the payments recorded.
• Technical data: activity and security logs, correlation identifiers, display preferences.
• Sign-in data: for each sign-in to an account and each refused sign-in attempt, the IP address and the approximate location derived from it (country, city and its approximate coordinates, network operator), computed using a database installed on our own servers, with nothing sent to a third party; for a sign-in, also the platform and browser used.
• Device data: for each phone on which a user is signed in to the mobile app, the notification identifier, the platform and the language, to send the notifications they turned on; a random device identifier, set in the browser or the app; and, for each trusted device, the browser and system derived from the user agent, the date it was trusted, its last use and its expiry date.
• Fraud-prevention data: at account creation only — IP address, browser user agent, the domain of the creator's e-mail address, and a timestamp.

• Providing the Service: digitising and extracting instruments, tracking receivables and payables, compliance checks, sending instruments between companies, printing, dashboards.
• Solvency network: calculating and making available a score per partner identifier (article 5).
• Fraud and abuse prevention: detecting multiple registrations, identity reuse and the double pledging of one instrument.
• Notifications: due-date, late-payment and instrument-event alerts, according to the company's preferences.
• Invoicing and accounting obligations: issuing documents and retaining them as required by law.
• Account security: knowing where the sign-ins to each account come from, in order to detect and block unauthorised access.
• Security and support: logging, incident diagnosis and assistance.
• Service improvement and model training: evaluating and improving automatic extraction and score calculation from the documents and data processed by the Service, after pseudonymisation or anonymisation where the purpose allows.

• Performance of the contract: providing the Service, notifications, invoicing.
• Express consent: participation in the solvency network and the use of documents and data to improve the Service. That consent is collected when the account is created, through a box that is not pre-ticked, and retained together with the exact version of the text accepted and its timestamp.
• Legal obligation: retention of accounting and tax records.
• Legitimate interest: fraud prevention, account security and platform security, strictly as described in article 3.

The network is mutualised: it is the heart of the Service and the reason express consent is asked for. Here is precisely what it processes.

• What is processed: only instrument settlement events — outcome, amount, due date, settlement date — attached to the debtor's legal identifiers (identity card, tax identification number, bank account number). No telephone number is ever used as an identifier.
• What is published: never the instruments themselves, and never the identity of holders. A lookup returns an aggregated A-to-E band, a confidence indicator and summary figures — number of events, share settled on time, total volume, date of the last default.
• What is not processed: an instrument rejected by its holder never enters the calculation; an outstanding instrument not yet due produces no event; acceptance and aval have no effect on the score.
• Scope: the score is global — fed by all companies using the Service and consultable by them for a given identifier.
• Reliability: below three observed settlements, the score is explicitly flagged as resting on insufficient data. It is a decision-support aid, never an automated decision.

A data subject may request access to the events recorded under their identifier and the rectification of inaccurate data, in the manner set out in article 9.

A company's instrument data and documents are accessible to its own authorised users, and to another company only in the cases described below. The Publisher's staff access them only for support and security purposes. At the Company's request, they may also act on its behalf for support purposes. Such access and such actions are traced.

For the solvency network, only the settlement data described in article 5, in aggregated form, is shared among the companies using the Service. In addition, when an instrument is transferred from one company to another, or that transfer is declined, its history names each of them by the name it bore on that day. An instrument offered to another company is shown to it before it accepts: amount, dates, names of the parties, reference, the mentions carried on the instrument and the drawee's solvency score. A transferred instrument reaches the receiving company with its data and its image. An instrument can also be sent to a company that does not use the Service yet, under its matricule fiscal and the name the sender gives: it is shown to that company, with the sender's name, when a company registers under that matricule fiscal. The sender then sees the name under which that company registered. No data is sold, or transferred for advertising purposes.

The Publisher uses technical subcontractors (processors) for hosting the platform and its backups, delivering e-mail, collecting online payments and automatically extracting the content of scanned documents. They act solely on the Publisher's instructions and for those purposes alone, and are bound by contract to ensure the confidentiality and security of the data they process. Backups are encrypted before they leave our servers. Some of these subcontractors may be located outside Tunisia; any transfer of data outside Tunisia takes place in accordance with the conditions laid down by organic law no. 2004-63.

• Account and instrument data: for the duration of the contractual relationship, then archived in accordance with Tunisian accounting and tax obligations. The drawee's name and address, which appear on the instrument, are kept for the same period.
• Instrument history: each operation on an instrument is kept with it, as a commercial record, for as long as the instrument itself. A company name that appears in it, including a sole trader's, is not removed from it when a person's account is deleted.
• Instrument sendings: kept with the instrument, for as long as it is. A sending still waiting for an answer is closed when the account of the company that sent it, or that was to answer it, is deleted: the instrument then returns to its sender.
• Settlement events: retained beyond the contractual relationship, since the network's value rests on history; the data is then reduced to what the calculation requires.
• Accounting records: for the applicable statutory retention period.
• Fraud-prevention data: retained for as long as the corresponding signals need to be handled.
• Technical logs: retained for a short period, for security and diagnosis.
• Sign-in data: kept for 90 days after each sign-in or refused attempt; it is then reduced to a count per day and city, with no identifier, which we erase one year after the day it counts.
• E-mails and notifications sent: erased from our sending queue 90 days after they are sent, or after the last attempt for one that could not be delivered.
• Device data: the notification identifier stops being used as soon as the user signs out on the phone or the phone no longer receives notifications, and it is erased 30 days later, or sooner with the account; a device is trusted for 30 days at most, then erased 7 days after it expires or is revoked.

The Publisher implements appropriate technical and organisational measures: encryption in transit, centralised authentication, role-based access control, strict data partitioning between companies, access logging and regular backups. Logs contain neither personal identifiers nor secrets.

Hosting: the final hosting location is not settled as at the date of this version. Should the data be hosted outside Tunisia, the authorisation required by the applicable regulations would be obtained beforehand and this policy updated.

In accordance with organic law no. 2004-63, every data subject has a right of access, rectification, objection and erasure, within the limits of the statutory retention obligations binding on the Publisher.

These rights are exercised by written request to contact@kembielti.tn, together with proof of identity. A response is provided as promptly as possible.

To ask for your account to be deleted, follow the steps on the Delete your account page.

As regards settlement data, rectification concerns the accuracy of the recorded event. A score can only be corrected by correcting the events that make it up: it cannot be edited directly.

The use of cookies and local storage is described in the cookie policy.

The prior declaration of the processing described above to the National Authority for the Protection of Personal Data is being prepared. This policy will be updated once those formalities are complete.

For any question about this policy or your data: contact@kembielti.tn — WhatsApp: +216 50 730 689