This policy applies to all visitors to our website and customers who have ordered the goods or requested services we provide (“you” and “your”).
Purpose of this policy
We respect your privacy and take the protection of personal information very seriously. The purpose of this policy is to describe the way we collect, store, use, and protect information that can be associated with an identified or identifiable natural person (“personal information”). Personal information:
certain information collected on registration (see below); and
optional information that you provide to us voluntarily (see below).
information that has been made anonymous so that it does not identify a specific person;
permanently de-identified information that does not relate or cannot be traced back to you specifically; and
non-personal statistical information collected and compiled by us and information that you have provided voluntarily in an open, public environment or forum including any blog, chat room, community, classifieds or discussion board. Because the information has been disclosed in a public forum, it is no longer confidential and does not constitute personal information subject to protection under this policy.
Depending on the goods of services that you require, we may collect personal information including your:
financial information – such as your bank account details;
sensitive demographic information – such as your race or ethnicity;
your employment information – including your membership of a trade union; and
sensitive information on your beliefs – including your political or religious beliefs.
Acceptance of terms
Acceptance required. You must accept all the terms of this policy when you use our website or order any of our goods or services. If you do not agree with anything in this policy, then you may not use our website or order any of our goods or order, register for, or use any of our services.
Legal capacity. You must not access our website or order our goods or services if you are younger than 18 years old.
Deemed acceptance. By accepting this policy, you are deemed to have read, understood, accepted, and agreed to be bound by all its terms.
We may change the terms of this policy at any time. We will notify you of any changes by placing a notice in a prominent place on the website or by email. If you do not agree with the change you must stop using the website. If you continue to use the website following notification of a change to the terms, the changed terms will apply to you and you will be deemed to have accepted such terms.
On registration. Once you register on our website, you will no longer be anonymous to us as you will provide us with personal information.
Collection on order or service request. When you order the goods or request the services from us, you will be asked to provide us with additional information on a voluntary basis (“services information”).
Optional details. You may also provide additional information to us on a voluntary basis (“optional information”). This includes content or products that you decide to upload or download from our website or when you enter competitions, take advantage of promotions, respond to surveys, order certain additional goods or request certain additional services, or otherwise use the optional features and functionality of the website.
Cookies. We may place small text files called ‘cookies’ on your device when you visit our website. These files do not contain personal information, but they do contain a personal identifier allowing us to associate your personal information with a certain device. These files serve a number of useful purposes for you, including:
granting you access to age restricted content;
tailoring our website’s functionality to you personally by letting us remember your preferences;
improving how our website performs;
allowing third parties to provide services to our website; and
helping us deliver targeted advertising where appropriate in compliance with applicable laws.
Web beacons. Our website may contain electronic image requests (called a “single-pixel gif” or “web beacon” request) that allow us to count page views and to access cookies. Any electronic image viewed as part of a web page (including an ad banner) can act as a web beacon. Our web beacons do not collect, gather, monitor or share any of your personal information. We merely use them to compile anonymous information about our website.
Recording calls. We will monitor and record telephone calls that you make to our call centre, unless you specifically request us not to.
Purpose for collection. We may use any goods information, service information, and optional information that you provide to us for the purposes that you indicated when you agreed to provide it to us. We may use your usage information for the purposes described above and to:
remember your information so that you will not have to re-enter it during your visit or the next time you access the website;
monitor website usage metrics such as total number of visitors and pages accessed; and
track your entries, submissions, and status in any promotions or other activities in connection with your usage of the website.
Consent to collection
We will obtain your consent to collect personal information:
in accordance with applicable law; and
when you provide us with any registration information or optional information.
Messages and updates. We may send administrative messages and email updates to you about the website. In some cases, we may also send you primarily promotional messages. You can choose to opt-out of promotional messages.
Targeted content. While you are logged into the website, we may display targeted adverts and other relevant information based on the personal information. In a completely automated process, computers process the personal information and match it to adverts or related information. We never share personal information with any advertiser, unless you specifically provide us with your consent to do so. Advertisers receive a record of the total number of impressions and clicks for each advert. They do not receive any personal information. If you click on an advert, we may send a referring URL to the advertiser’s website identifying that a customer is visiting from the website. We do not send personal information to advertisers with the referring URL. Once you are on the advertiser’s website however, the advertiser is able to collect your personal information.
Sharing. We may share your personal information with:
other divisions or companies within the group of companies to which we belong so as to provide joint content and services like registration, for transactions and customer support, to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about our products, services and communications (they will only use this information to send you marketing communications if you have requested their goods or services);
our goods suppliers or service providers under contract who help supply certain goods or help with parts of our business operations, including fraud prevention, bill collection, marketing, technology services (our contracts dictate that these goods suppliers or service providers only use your information in connection with the goods they supply or services they perform for us and not for their own benefit);
credit bureaus to report account information, as permitted by law and
banking partners as required by credit card association rules for inclusion on their list of terminated merchants (in the event that you utilise the services to receive payments and you meet their criteria).
Regulators. If you contact us regarding your experience with using any of our products, we may disclose your personal information as required by law or governmental audit.
Law enforcement. We may disclose personal information if required:
by a court summons or court order;
to comply with any law;
to protect the safety of any individual or the general public; and
to prevent violation of our customer relationship terms.
Marketing purposes. We may disclose aggregate statistics (information about the customer population in general terms) about the personal information to advertisers or business partners.
Employees. We may need to disclose personal information to our employees that require the personal information to do their jobs.
Change of ownership. If we undergo a change in ownership, or a merger with, acquisition by, or sale of assets to, another entity, we may assign our rights to the personal information we process to a successor, purchaser, or separate entity. We will disclose the transfer on the website. If you are concerned about your personal information migrating to a new owner, you may request us to delete your personal information.
Security of personal information
Our hosting company will host our website in a secure server environment that uses a firewall and other advanced security measures to prevent interference or access from outside intruders. We authorize access to personal information only for those employees who require it to fulfil their job responsibilities.
Accurate and up to date
We will try to keep the personal information we collect as accurate, complete and up to date as is necessary for the purposes explicitly defined in this policy. From time to time we may request you to update your personal information on the website. You are able to review or update any personal information that we hold on you by accessing your account online, by emailing us, or by phoning us. Please note that in order to better protect you and safeguard your personal information, we take steps to verify your identity before granting you access to your account or making any corrections to your personal information.
Retention of personal information
We will only retain your personal information for as long as it is necessary to fulfil the purposes explicitly set out in this policy, unless: retention of the record is required or authorised by law; or you have consented to the retention of the record.
During the period of retention, we will continue to abide by our non-disclosure obligations and will not share or sell your personal information.
Updating or removing
You may choose to correct or update the personal information you have submitted to us, by clicking the relevant menu in any of the pages on our website.
We are not responsible for, give no warranties, nor make any representations in respect of the privacy policies or practices of linked or any third party websites.
If you have any questions about this privacy notice or how we handle your personal information, please contact the ICT Manager through email@example.com. You have the right to make a complaint at any time to the Data Commissioner, the Kenyan supervisory authority for data protection issues.
We will only use your personal information for the purposes that we collected it, unless we reasonable consider that we need to use if for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will seek for your consent before hand.
Any personal data collected under this policy shall be processed in accordance with KWAL’s Data Protection Policy.