Last updated: 1st January 2020
When I say ‘personal data’ I mean identifiable information about you, like your name, email, address, telephone number, bank account details, payment information, support queries, community comments and so on. If you can’t be identified (for example, when personal data has been aggregated and anonymised) then this notice doesn’t apply.
I may need to update this notice from time to time. Where a change is significant, I’ll make sure we let you know – usually by sending you an email.
1) Who am ‘I’’?
When I refer to ‘I’ ( ‘we’ or ‘our’ or ‘us’), that mean Amit Gadhia Advocate and my office is on 10th Floor, The Mint Hub, Karuna Road, P.O. Box 1075-00606,Westlands, Nairobi, Kenya.
My principles of data protection
My approach to data protection is built around four key principles. They’re at the heart of everything I do relating to personal data.
– Transparency: I take a human approach to how I process personal data by being open, honest and transparent.
– Enablement: I enable connections and efficient use of personal data to empower productivity and growth.
– Security: I champion industry leading approaches to securing the personal data entrusted to me.
– Stewardship: I accept the responsibility that comes with processing personal data.
2) How I collect your data
When you visit my website or use my services, I collect personal data. The ways I collect it can be broadly categorised into the following:
– Information you provide to us directly: When you visit or use some parts of our websites and/or services I might ask you to provide personal data to us. For example, I ask for your contact information, respond to a job application or an email offer, join us on social media, take part in training and events, contact us with questions or request support. If you don’t want to provide me with personal data, you don’t have to, but it might mean you can’t use some parts of our websites or services.
– Information we collect automatically: I collect some information about you automatically when you visit my websites or use our services, like your IP address and device type. I also collect information when you navigate through our websites and services, including what pages you looked at and what links you clicked on. This information is useful for me as it helps us get a better understanding of how you’re using my websites and services so that I can continue to provide the best experience possible (e.g., by personalising the content you see). Some of this information is collected using cookies and similar tracking technologies.
– Information I get from third parties: The majority of information I collect, I collect directly from you. Sometimes I might collect personal data about you from other sources, such as publicly available materials or trusted third parties like our marketing and research partners. I use this information to supplement the personal data I already hold about you, in order to better inform, personalise and improve my services, and to validate the personal data you provide.
Where I collect personal data, I’ll only process it:
– to perform a contract with you, or
– where I have legitimate interests to process the personal data and they’re not overridden by your rights, or
– in accordance with a legal obligation, or
– where I have your consent.
If I don’t collect your personal data, I may be unable to provide you with all our services, and some functions and features on my website and my services may not be available to you.
If you’re someone who doesn’t have a relationship with me, but believe that one of my subscriber has entered your personal data into my websites or services, you’ll need to contact that subscriber for any questions you have about your personal data (including where you want to access, correct, amend, or request that the user delete, your personal data).
3) How I use your data
First and foremost, I use your personal data to operate my website and provide you with any services you’ve requested, and to manage my relationship with you. I also use your personal data for other purposes, which may include the following:
i) To communicate with you. This may include:
– providing you with information you’ve requested from me or information I am required to send to you as per my contract with you;
– operational communications, like changes to my websites and services, security updates, or assistance with using my websites and services;
– marketing communications (about my service or any other service I think you might be interested in) in accordance with your marketing preferences
– asking you for feedback or to take part in any research I am conducting (which I may engage a third party to assist with).
ii) To support you: This may include assisting with the resolution of technical support issues or other issues relating to the websites or services, whether by email, in-app support or otherwise.
iii) To enhance my websites and services and develop new ones: For example, by tracking and monitoring your use of websites and services so I can keep improving, or by carrying out technical analysis of our websites and services so that I can optimise your user experience and provide you with more efficient tools.
v) To market to you: In addition to sending you marketing communications, I may also use your personal data to display targeted advertising to you online – through my own websites and services or through third party websites and their platforms.
vi) To analyse, aggregate and report: I may use the personal data we collect about you and other users of my websites and services (whether obtained directly or from third parties) to produce aggregated and anonymised analytics and reports, which I may share publicly or with third parties.
4) How I can share your data
There will be times when I need to share your personal data with third parties. I will only disclose your personal data to:
– Advocates, Solicitors, Government offices and to any other person or body so as to enable us perform my contract with you.
– third party service providers and partners who assist and enable me to use the personal data to, for example, support delivery of or provide functionality on the website or services, or to market or promote our goods and services to you.
– regulators, law enforcement bodies, government agencies, courts or other third parties where I think it’s necessary to comply with applicable laws or regulations, or to exercise, establish or defend my legal rights. Where possible and appropriate, I will notify you of this type of disclosure.
– an actual or potential buyer (and its agents and advisers) in connection with an actual or proposed purchase, merger or acquisition of any part of our business.
– other people where I have your consent.
5) Data transfers
International Data Transfers
– When I share data, it may be transferred to, and processed in, countries other than the country you live in – such as to the United States, where my data hosting provider’s servers may be located. These countries may have laws different to what you’re used to. Rest assured, where I disclose personal data to a third party in another country, I put safeguards in place to ensure your personal data remains protected.
– For individuals in the European Economic Area (EEA), this means that your data may be transferred outside of the EEA. Where your personal data is transferred outside the EEA, it will only be transferred to countries that have been identified as providing adequate protection for EEA data (like New Zealand), or to a third party where I have approved transfer mechanisms in place to protect your personal data.
Security is a priority for me when it comes to your personal data. I am committed to protecting your personal data and have appropriate technical and organisational measures in place to make sure that happens.
The length of time I keep your personal data depends on what it is and whether I have an ongoing business need to retain it (for example, to provide you with a service you’ve requested or to comply with applicable legal, tax or accounting requirements).
I’ll retain your personal data for as long as I have a relationship with you and for a period of time afterwards where I have an ongoing business need to retain it, in accordance with my data retention policies and practices. Following that period, I’ll make sure it’s deleted or anonymised.
8) Your rights
It’s your personal data and you have certain rights relating to it. When it comes to marketing communications, you can ask me not to send you these at any time – just follow the unsubscribe instructions contained in the marketing communication, or send your request to email@example.com.
You also have rights to:
– know what personal data I hold about you, and to make sure it’s correct and up to date
– request a copy of your personal data, or ask us to restrict processing your personal data or delete it
– object to my continued processing of your personal data
You can exercise these rights at any time by sending an email to firstname.lastname@example.org
If you’re not happy with how I am processing your personal data, please let us know by sending an email to email@example.com. I will review and investigate your complaint, and try to get back to you within a reasonable time frame.
How to contact us
I am always keen to hear from you. If you’re curious about what personal data I hold about you or you have a question or feedback for me on this notice, my websites or services, please get in touch.
I prefer to communicate with you by email – this ensures that you’re put in contact with the right person, in the right location, and in accordance with any regulatory time frames. My email is firstname.lastname@example.org. My office address is 10th Floor, The Mint Hub, Karuna Road, P.O. Box 1075-00606,Westlands, Nairobi, Kenya.