1. WHAT PERSONAL DATA IS COLLECTED
- Your provision of personal data to us is voluntary. If you choose not to provide us with your personal data, it may not be possible for us to provide you with access to our Platforms or the Services that you require.
- “Personal data” is data that can be used to identify a natural person. In the course of your access and use of our Platforms and Services, we collect personal data such as:
- your name, gender, date of birth, telephone number, e-mail address, contact address, identification number and other related information;
- your financial information (e.g. credit card numbers , m-pesa account information);
- personal data of other individuals (e.g. if you use our services to share content with other individuals, or invite them to use our Platforms or services); and
- other information that we are required or authorised to collect under any applicable law to authenticate or identify you, or to verify any data that you have provided.
- Automated collection.
In the course of your access and use of our Platforms and Services, certain personal data is automatically collect from you or through the device you use to access our Platforms and Services, including:
- device or software information (e.g. configuration information on your mobile devices, web browsers or other applications or platforms used to access our Platforms);
- geo-locational information via your mobile devices;
- IP addresses, browsing information (e.g. search history) and other browsing-related data in connection to your use of our Platforms and services;
- information about your access to and usage of other mobile applications and software through our Platforms and Services; and
- You may disable the automatic collection of certain data. However, certain aspects (or the whole) of our Platforms and services may not be available to you if you choose to do so.
- We may also collect personal data and information where required or permitted by any applicable law.
- We may also collect personal data and information from you when you submit an enquiry, feedback or email through our websites or other communication channels.
- If you provide or allow the collection of personal data of anyone other than yourself, you warrant that you have informed him/her of the purposes for which we require his/her personal data and that he/she has consented to your disclosure of his/her personal data to us for those purposes.
2. HOW WE USE PERSONAL DATA COLLECTED
- We collect and use the personal data received from you for the purposes listed below and any other related or associated purposes.
- Service-related purposes.
We collect and use your personal data for the purposes of serving you, such as:
- providing you with the Services that you have requested for;
- authenticating, operating and maintaining your user account;
- to invite you in creating, developing, operating, providing, improving and promoting our Platform, products, Services and content;
- to provide you with personalised services based on how you access and use our Platform and Services;
- to develop, conduct research about and market our products and Services. This includes collecting data relating to your use of our Platforms and Services to offer you personalized electronic content and electronic marketing material pertaining to our products and Services.
- to send you important notices and announcements such as services-related information, modification to terms, rules and software upgrading; and
- to respond to your feedback
In connection with the above, we may disclose, transfer and jointly use your personal data to and with our affiliated companies. In addition, we may disclose your personal data to third parties, such as our other service providers or related businesses and service providers.
If you also subscribe to our mailing list, we may email to you updates about our products and Services.
If we use or disclose your personal data for a purpose (“secondary purpose”) other the main reason for which it was originally collected (“primary purpose”), to the extent required by law, we will ensure that:
- The secondary purpose is related to the primary purpose of collection and you would reasonably expect that we would use or disclose your information in that way; or
- You have consented to the use or disclosure of your personal information for the secondary purpose; or
- The use or disclosure is required or authorised by or under law; or
- The use or disclosure is otherwise permitted by law (for example, as a necessary part of an investigation of suspected unlawful activity).
- Business purposes
We may also collect and use your personal data for purposes connected or relevant to our business, such as:
- complying with our legal obligations and requirements;
- enforcing obligations owed to us, and contractual terms and conditions;
- accounting, risk management and record keeping;
- carrying out research, planning and statistical analysis;
- to prevent, detect, process and investigate fraudulent or other illegal activities, or mitigate the risk of occurrence of the aforementioned events;
- staff training; and
- any other reasonable purposes related to the aforesaid.
- Additional purposes.
If you have consented, we may collect and use your personal data for additional purposes such as:
- inviting you to promote our Platforms and Services on social media platforms;
- informing you of our latest activities, special offers and promotions;
- informing you of other third party products and/or Services that you may be interested in;
- inviting you to participate in polls and questionnaire surveys that may be conducted by us and/or third parties; and
- publicising your feedback about us and/or our services on our marketing materials (including but not limited to newspapers, social media channels, etc.).
- Contacting you.
When using your personal data to contact you for the above purposes, we may contact you via regular mail, e-mail, SMS, telephone, push notifications (on your devices) or other means. You may determine the type and manner of information that you will receive from us by adjusting your communication preferences on our Platforms or your device.
3. DISCLOSURE OF PERSONAL DATA
- Disclosure to third parties.
We may disclose your personal data to our related entities, affiliates, partners, contractors and associates for the purposes set out in Clause 2 above.
- Disclosure to service providers.
We may disclose your personal data with third parties such as:
- our service providers and data processors that provide services to us (e.g. accounting, hosting and maintenance services, data analytics services, e-mail message services, delivery services, payment transactions services, marketing, etc.); and
- our consultants and professional advisors (e.g. accountants, lawyers, auditors).
- Disclosure for corporate transactions.
We and our affiliates may be engaged in business asset transactions e.g. mergers, acquisitions and transfer of assets. In such circumstances, we may transfer and/or disclose your personal data to facilitate the completion of the transactions.
- Other permitted disclosure.
We may disclose your personal data as required or permitted by law, e.g. to regulatory authorities, statutory bodies or public agencies to comply with their requirements, policies and directives.
4. TRANSFER OF PERSONAL DATA OUT OF RESIDENCE COUNTRY
- You agree and consent to our transfer of your personal data to any location outside of the country where you reside for the purposes set out above.
- If we transfer your personal data to a country or territory outside of the country where you reside, we will ensure that the recipient is obligated to protect your personal data at a standard of protection comparable to the protection under the laws and regulations of the country where you reside, by ensuring that the recipient is either in a jurisdiction with comparable data privacy laws or is legally bound to protect your personal data.
5. RETENTION AND PROTECTION OF PERSONAL DATA
- We will retain your personal data for so long as we need the personal data for our business and legal purposes. We will dispose of or delete such information if it is no longer necessary for us to retain your personal data.
- We will take reasonable precautions to safeguard your personal data to prevent the loss, improper use, or unauthorised disclosure of your personal data. However, we cannot be held responsible for any safety or security breach (e.g. hacking) that is beyond our control.
- When you use our Platforms and Services, you may choose to share and upload your personal data to be publicly available to other users. We are not responsible for protecting and may not be able to remove from our Platforms any personal data that you have made publicly available. Please carefully consider any content that you share, upload, release or communicate through our Platforms and Services.
6. YOUR RIGHTS
- You may:
- access your personal data through your user account;
- make corrections to your personal data through your user account;
- We may charge you a fee for responding to your requests for access to your personal data or information about the ways in which we have (or may have) used your personal data. If a fee is to be charged, we will inform you of the amount beforehand and will respond to your request once payment is received.
7. CHANGES TO POLICY
8. CONTACT US
If you have any concerns on how we handle your personal data, wish to make any requests in relation to your personal data, or have any queries in relation to this Policy, please contact us at email@example.com