1. About This Privacy Policy

This privacy policy applies when you visit or use our websites, apps and other services, including events, that refer or link to this privacy policy (each, a "Service"). This privacy policy may be supplemented by additional privacy statements, terms or notices provided to you. KYANDA which owns or administers the Service, as identified therein, is the primary controller of your personal information provided to, or collected by or for, the Service. We will indicate within the registration processes of our products and services and other registration forms what types of personal information are required and those that are requested. You may choose not to submit the requested information, but that may limit or prohibit the services that KYANDA can provide to you.

2. Information We Collect

We collect information about you in three ways: directly from your input, from third-party sources, and through automated technologies.

2.1 Data You Provide to Us

The types of personal information that we collect directly from you depend on how you interact with us and the Service, which may include:

• Contact details, such as your name, email address, postal address, social media handle, and phone number;
• Account login credentials, such as usernames and passwords, password hints and similar security information;
• Other account registration and profile information, such as job title, educational and professional background and qualifications, and photo;
• Payment information, such as a credit or debit card number;
• Comments, feedback and other information you provide to us, including search query data and questions or information you send to us;
• Interests and communication preferences, including preferred language.

2.2 Data From Your Organisation

We may obtain personal information about you from the organisation with which you are employed or affiliated to activate and manage your access to and use of the organisation’s subscription to the Service, including:

• Contact details, such as your name and organisational email address, postal address, and phone number;
• Other account registration information such as job title; and/or
• Organisational user ID

2.3 Data From Other Sources

We also may obtain contact details and other information about you from our affiliates and other third parties, including:

• Social networks when you grant permission to the Service to access your data on one or more networks;
• Service providers that help us determine a location to customise certain products to your location;
• Businesses with which we offer co-branded services or engage in joint marketing activities; and/or
• Publicly-available sources and data suppliers from which we obtain data to validate or supplement the information we hold.

2.4 Data From Service Use, Including Cookies

The Service may automatically collect information about how you and your device interact with the Service, including:

• Computer, device and connection information, such as IP address, browser type and version, operating system and other software installed on your device, mobile platform and unique device identifier and other technical identifiers, error reports and performance data;
• Usage data, such as the features you used, the settings you selected, your URL click stream data, including date and time stamp and referring and exit pages, search terms you used, and pages you visited or searched for on the Service;
• For location-aware Services, the region, city or town where your device is located provides you with more relevant content for where you are in the world.
• Publicly-available sources and data suppliers from which we obtain data to validate or supplement the information we hold.

We collect this data through our servers and the use of cookies and other technologies. Cookies are small text files that can be read by a web server in the domain that put the cookie on your hard drive. We may use cookies and other technologies to store your preferences and settings, help you with signing in, provide targeted ads and analyse site operations. You can control cookies through your browser’s settings and other tools.

3. How We Use Your information

We use your personal information depending on how you interact with us and the Service. to:

• Provide, activate and manage your access to and use of our Services;
• Process and fulfil a request, order, download, subscription or other transaction;
• Respond to your requests, inquiries, comments and concerns;
• Notify you about changes, updates and other announcements related to the Service and our other products and services;
• Comply with our legal obligations, resolve disputes, and enforce our agreements.

4. Sharing of Your Information

4.1 Your Organisation

If you access the Service through interaction with our site or social media handles, your personal information and certain usage data gathered through the Service may be accessed by or shared with the administrators authorised by your organisation for the usage analysis.

4.2 For Legal Reasons

We also will disclose your personal information if we have a good faith belief that such disclosure is necessary to:

• Meet any applicable law, regulation, legal process or other legal obligation;
• Detect, investigate and help prevent security, fraud or technical issues; and/or
• Protect the rights, property or safety of KYANDA, our employees or others; and
• As part of a corporate transaction, such as a transfer of assets to or an acquisition by or a merger with another company.

5. Grounds for Processing

When we collect or otherwise process any personal information within the scope of POPI Act data protection laws, we do so:

• Where necessary to provide the Service, fulfil a transaction or otherwise perform a contract with you or at your request before entering into a contract;
• Where necessary for our compliance with applicable law or other legal obligation;
• Where necessary for the performance of a task carried out in the public interest;
• Where necessary to enable our customers to comply with their legal obligations;
• Where applicable, with your consent; and/or
• Where necessary to operate our business, protect the security of our systems, customers and users, detect or prevent fraud, or fulfil our other legitimate interests as described in sections 2-4 above, except where our interests are overridden by your privacy rights.

Where we rely on your consent to process personal information, you have the right to withdraw your consent at any time, and where we rely on legitimate interests, you may have the right to object to our processing.

6. Data Retention

We retain your personal information for as long as necessary to provide the Service and fulfil the transactions you have requested, or for other essential purposes such as complying with our legal obligations, maintaining business and financial records, resolving disputes, maintaining security, detecting and preventing fraud and abuse, and enforcing our agreements. If you access the Service through our website or social media platforms we retain your organisational contact details after the termination of your organisation’s subscription to continue to communicate with you.

7. Locations of Processing

Your personal information may be stored and processed in your region or another country where KYANDA, its affiliates and their service providers maintain servers and facilities. We take steps, including through contracts, intended to ensure that the information continues to be protected wherever it is located in a manner consistent with the standards of protection required under applicable law.

8. Data Security

We implement technical and organisational measures to seek to ensure a level of security appropriate to the risk to the personal information we process. These measures are aimed at ensuring the integrity, confidentiality, and availability of personal information.

9. Children’s Privacy

We do not knowingly collect information from children under the age of 13 or target the Service to children under 13.

10. Your Communications Preferences

You can customise and manage your communications preferences and other settings when you take on our services. We reserve the right to notify you of changes or updates to the Service whenever necessary.

11. Accessing and Updating Your Information

11.2 Your Rights

You have the right under POPI and certain other privacy and data protection laws, as may be applicable, to request free of charge:

• Access to your personal information;
• Rectification or erasure of your personal information;
• Restriction of our processing of your personal information, or to object to our processing; and
• Portability of your personal information.

Please submit your request in writing if you wish to exercise these rights. We will respond to your request consistent with applicable laws. We may require you to verify your identity to protect your privacy and security.

12. Changes

We will update this privacy policy from time to time. Any changes will be posted on this page with an updated revision date. If we make any material changes, we will provide notice through the Service or by other means.

13. Contact

The data protection representative for our businesses that are processing personal data within the scope of Data Protection act of 2019.

If you have any questions, comments, complaints or requests regarding this privacy policy or our processing of your information, please contact us via our email at support@kyanda.co.ke .