PRIVACY POLICY

FINDEL ASSOCIATES (“We”) are committed to protecting and respecting your privacy.

This policy (together with our terms of use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.findelassociates.co.ke and its sub-domains you are accepting and consenting to the practices described in this policy.

For the purpose of the Data Protection Act, 2019 of the Laws of Kenya (the Act); and General Data Protection Regulations (GDPR) of the European Union (EU), the Data Protection Officer is Findel Associates of PO Box 38035-00100 Nairobi.

INFORMATION WE COLLECT FROM YOU

We will collect and process the following data about you:

• Information you give us. This is information about you that you give us for uploading on our website www.findelassociates.co.ke (our “Website”) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our Website, subscribe to our service, participate in discussion boards or other social media functions on our Website, enter a competition, promotion or survey, and when you report a problem with our Website. The information you give us may include your name, address, internet protocol, geolocation, e-mail address and phone number.
• Information we collect about you. With regard to each of your visits to our Website we will automatically collect the following information:
• technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
• information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our Website (including date and time), products you viewed or searched for page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.
• Information we receive from other sources. This is information we receive about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on this Website. We will also have told you for what purpose we will share and combine your data. We may work closely with third parties (including, for example, business partners, sub-contractors in technical services, advertising networks, analytics providers, search information providers). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

COOKIES

Our Website uses cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse the Website and also allows us to improve it. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy.

USES MADE OF THE INFORMATION

We use information held about you in the following ways:

• Information you give to us. We will use this information:
• to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
• to provide you with information about other services we offer that are similar to those that you have already purchased or enquired about. If you are an existing customer, we will only contact you by electronic means (e-mail or telephone) with information about such services or to notify you about changes to our service;
• to ensure that content from our Website is presented in the most effective manner for you and for your computer.
• to market the Website using aggregated data as opposed to any user specific data.
• Information we collect about you. We will use this information:
• to administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our Website and to ensure that content is presented in the most effective manner for you and for your computer;
• to allow you to participate in interactive features of our service, when you choose to do so;
• as part of our efforts to keep our Website safe and secure;
• to make suggestions and recommendations to you and other users of our Website about goods or services that may interest you or them.
• Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

DISCLOSURE OF YOUR INFORMATION

You agree that we have the right to share your personal information with:

• Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in the Companies Act, 2015.
• Selected third parties including:
• business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
• analytics and search engine providers that assist us in the improvement and optimisation of our

We will disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
• If FINDEL ASSOCIATES or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of FINDEL ASSOCIATES, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

WHERE WE STORE YOUR PERSONAL DATA

The data that we collect from you will be transferred to, and stored at www.findelassociates.co.ke. It will also be processed by staff operating in Nairobi, Kenya who work for us or for our suppliers. This includes staff engaged in, among other things, the fulfilment of your needed services, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

YOUR RIGHTS

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at info@findelassociates.co.ke.

Our site may, from time to time, contain links to and from the webs of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

You can contact us to exercise your rights as under the following Laws/ Directives/ Regulations:

1. Data Protection Act, 2019 – Only applicable to Kenyans.
2. General Data Protection Regulations, 2016 – Only applicable to citizens of the members of the European Union/ European Economic Area.
3. California Consumer Privacy Act, 2018 – Only applicable to citizens of California, US.

ACCESS TO INFORMATION

The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request will be subject to a minimum fee of KES. 1,000.00 to meet our costs in providing you with details of the information we hold about you.

CHANGES TO OUR PRIVACY POLICY

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

CONTACT  US

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to info@findelassociates.co.ke