- INTRODUCTION AND CONTENTS
- This policy describes the information privacy practices that Jengaleo (“we”, “us”, or “our”, if not explicitly referring to the company) follow when handling personal information that we collect or receive in conducting our business, including through our services, products, websites, employee(s) and user application(s) and is addressed to individuals outside our organisation with whom we interact, including customers, visitors to our Sites, users of our Apps, other users of our products or services, and visitors to our premises (together, “you”). Defined terms used in this Policy are explained below.
- Our values guide everything that we do including how we use personal data.
- We are strongly committed to keeping your personal data safe. This commitment exists throughout the lifecycle of your personal data, from the design of any Jengaleo service which uses personal data to the deletion of that data.
- We think carefully about our use of personal data, and below you can find the details of what we do to protect your privacy. This policy covers, among other topics:
- Information about your rights, the choices available to you, and our obligations in Kenya and elsewhere globally;
- Transparency about how we collect and use your personal data, including when and how it is shared;
- Information on how we protect your personal data and;
- Information on how we will facilitate your rights and respond to your questions.
- This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Information, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Policy.
- Personal data is any information about you by which you can be identified or be identifiable. This can include information such as: your name, date of birth, email address, postal address, phone number, mobile number, financial details, such as payment cards you use to purchase products, subscriptions or information about your device (such as the IP address, which is a numerical code to identify your device that can provide information about the country, region or city where you are based), information relating to how you use and interact with our sites, apps and services.
- When we refer to “personal data” in this policy, we are also referencing
- Who we are and how to contact us
Jengaleo , P.O. Box ………………….., Nairobi ,Kenya is the data controller in respect of your personal data. This means that we are responsible for deciding how and why we hold and use your personal data. If you want to contact us directly, you can find our contact details in the “How to contact us” section below.
“App” means any application made available by us (including where we make such applications available via third party stores or marketplaces, or by any other means);
“Applicable laws” includes the Data Protection Act, No. 24 of 2019, Laws of Kenya and any other Laws of Kenya;
“Controller” means the entity that decides how and why Personal Information is Processed;
“Cookie” means a small file that is placed on your device when you visit a website (including our Sites). In this Policy, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs;
“Data Protection Authority” means an independent public authority that is legally tasked with overseeing compliance with the applicable laws;
“Member Platform” means the software application used by Jengaleo to communicate and provide service to its clients.
“Personal Data,” means any information relating to an identifiable natural person;
“Personal Information” means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual;
“Process”, “Processing” or “Processed” means anything that is done with any Personal Information, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
“Processor” means any person or entity that Processes Personal Information on behalf of the Controller (other than employees of the Controller);
“Profiling” means any form of automated Processing of Personal Information consisting of the use of Personal Information to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements;
“Relevant Personal Information” means Personal Information in respect of which we are the Controller;
“Sensitive Personal Information” means Personal Information about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that is deemed to be sensitive under the applicable laws;
“Site” means any website operated, or maintained, by us or on our behalf;
“Social Media” includes Facebook, Twitter, Instagram and G-mail;
- COLLECTION OF PERSONAL DATA AND INFORMATION
- The types of personal data we collect about you
- We collect your personal data when you visit our websites and apps, subscribe for products or services, contribute to Jengaleo or when you interact with us;
- We will only collect your personal data in line with the applicable laws.
- We collect your personal data in various ways:
- directly from you, when you sign up for our services and when you browse our sites or use our apps;
- personal data we generate about you, e.g. personal data we use to authenticate you, or personal data in the form of your IP address or your preferences;
- personal data we collect from third parties, e.g. personal data that helps us to combat fraud or which we collect, with your permission, when you interact with your social media accounts.
- The personal data we collect when you register for a Jengaleo account
- When you register for a Jengaleo account on jengaleo.com, we collect:
- your name;
- your email address;
- other details such as your residential or billing address when you sign up for membership or a subscription;
- some limited data from your social media profile (further information on this is below), if you have signed in to jengaleo.com using your social media details; and
- your photograph, if you add one to your profile page.
- When you register for a Jengaleo account on jengaleo.com, we collect:
- You can change or remove these details using the profile and settings area of your Jengaleo account.
- Personal data we generate about you
- When you register for a Jengaleo account, we assign you a unique ID number that we use to recognise you when you are signed in to our services. This will recognise you if you sign in using the same account on a new device or through a different application such as the Jengaleo app on mobile devices;
- your IP address – a numerical code to identify your device, together with the country, region or city where you are based;
- your geo-location data – your IP address can be used to find information about the latitude, longitude, altitude of your device, its direction of travel, your GPS data and data about connection with local Wi-Fi equipment;
- information on how you interact with our services;
- your browsing history of the content you have visited on our sites, including how you were referred to our sites via other websites; and
- details of your computer, mobile, TV, tablet or other devices, for example, the unique device ID, unique vendor or advertising ID and browsers used to access our content.
- We will not collect special categories of data from you – such as personal data concerning your race, political opinions, religion, health or sexual orientation – unless you have chosen to provide that type of personal data to us.
- When you use our apps
- The Jengaleo apps use personal data based on the content you have viewed;
- Information on bugs and crashes is also sent to us when you use our apps;
- A list of the articles that you have recently viewed is also cached in the local storage on your mobile device. You can delete this reading history in the settings of the app; and
- You can choose to receive notifications on your mobile device via the app, and manage these notifications in the settings of the app.
- Using your social media details to sign into your Jengaleo account
- When you sign in to our sites or apps using any of your social media login details, you give permission to the relevant social media to share with us your email address and certain aspects of the specific social media profile if you have made these public on the specific social media profile. This only includes your first and last name, age range, link to the specific social media profile and profile picture;
- We do not have access to updates on your social media profiles;
- If you use your Google login details, you give Google permission to share the personal data that you have made public in your Google profile. This only includes your first and last name, your email address and whether your email address has been validated, your age range, a link to your Google profile and, if you have one, your profile picture;
- If you register or sign in with your Apple ID, you give Apple permission to share your personal data with us. You can also choose to hide your email and Apple will create a random email address so your personal email can stay private. This email address will be linked to your Jengaleo profile and will be used to retrieve your subscribed content. We will then use this personal data to form a profile for your Jengaleo account.
- If you remove the Jengaleo app from your Social Media settings, or from your Google settings, or your Apple ID, we will no longer have access to this data. However, we will still have the personal data that we received when you first set up your Jengaleo account using your Social Media, Google login, or Apple ID.
- Personal data when you post comments about Jengaleo on other social media sites
If you have mentioned Jengaleo in posts on social media sites, then we may collect your social media handles. For example, when you mention Jengaleo in a tweet, we may collect your Twitter handle.
- When you post publicly (comments) on our sites
- When you post on a discussion board or comment publicly on an article on one of our sites, the personal data you post, including your username and other information about yourself, are publicly accessible. This personal data can be viewed online and collected by other people. We are not responsible for the way these other people use this personal data;
- When contributing to a discussion, we strongly recommend you avoid sharing any personal details, including information that can be used to identify you directly such as your name, age, address and name of employer.
- We are not responsible for the privacy of any identifiable information that you post in our online community or other public pages of the site.
- How we collect personal data
We collect personal data when you:
- become a supporter or register for an account on jengaleo.com;
- make contributions to fund and support Jengaleo;
- pay for a subscription or purchase any other products/services;
- attend our events;
- enter our competitions and surveys;
- sign up for our newsletter emails;
- post in our online community;
- sign up for marketing communications;
- use mobile devices to access our content;
- access and interact with any of our sites and app;
- through cookies and other similar technology;
- when you contact us via email, social media, our apps or similar technologies or when you mention us on social media.
- HOW WE USE YOUR PERSONAL DATA
We use personal data collected through our sites and apps only when we have a valid reason and the legal grounds to do so. We determine the legal grounds based on the purposes for which we have collected your personal data.
- Legal grounds for using your personal data
The legal ground may be one of the following:
- Consent: For example, where you have provided your consent to receive marketing emails from us. You can withdraw your consent at any time. In the case of marketing emails you can withdraw your consent by clicking on the “unsubscribe” link at the bottom of the email or through your email preferences in the “emails and marketing” tab, when signed into your Jengaleo account.
- Performance of a contract with you (or in order to take steps prior to entering into a contract with you): For example, where you have purchased a subscription from us and we need to use your contact details and payment data in order to process your order and deliver your subscription.
- Compliance with law: In some cases, we may have a legal obligation to use or keep your personal data.
- Our legitimate interests: Where it is necessary for us to understand our clients, promote our services and operate our sites and apps efficiently for the creation, publication and distribution of our content both online and in print form. Examples of when we rely on our legitimate interests to use your personal data include:
- when we analyse what content has been viewed on our sites and apps, so that we can understand how they are used and improve our content;
- to carry out marketing analyses to better understand your interests and preferences so that we can make our marketing more relevant to your interests and preferences. This includes when we promote our own products and services. For example, we look at what you have viewed on our sites and apps and what products and services you have bought (including what you have looked at and what products or services you have bought on our other platforms). You can opt out from having your personal data used for marketing analyses by going into your account to the tab “emails and marketing”;
- to show you personalised advertising by identifying your interests and to create “segments” of particular types of audiences so that we may show you advertisements that may be more relevant to your interests and the ‘’segments’’ you may be in. These ‘’segments’’ are also used to inform the building of custom audiences so that we can identify our audience across third party websites, such as social media platforms;
- for internal administrative purposes related to when you use our services – such as our accounting and records – and to make you aware of any changes to our services;
- to collect and log IP addresses to improve the website and monitor website usage;
- to personalise our services (for example, so you can sign in) by remembering your settings, and recognising you when you sign in on different devices;
- enabling you to share our content with others using social media or email;
- when responding to your queries and to resolve complaints;
Where we rely on cookies to collect any personal data.
- Access permissions when you are using the Jengaleo app
When you use the Jengaleo app, we ask for the following permissions to access particular functions of your mobile device:
- For the Android version, we ask for permission to access your contact details/profile on your mobile device, so that we can add or find your Jengaleo account on your phone. We also ask for permission to access the storage on your mobile device, so that you can store content and read when offline;
- For the iOS version, we ask for permission to save pictures to your photo library, so that you can save pictures that you find in our articles on your mobile device.
- Updating your personal data and your profile page on our sites
When you register for an account with jengaleo.com, you have access to a profile page. Under “edit profile” you can review and update what personal data is public when you comment on our articles, or if people look up your profile.
You may also update your marketing preferences in the “emails and marketing” tab in your account.
- PERSONAL DATA THAT WE RECEIVE ABOUT YOU FROM OTHER ORGANISATIONS
- Adding to or combining the personal data you provide to us
- When you sign up to our services we may add to the personal data you give us by combining it with other personal data shared with us by other trusted organisations. This includes, for example, the region that you are located in, so that we can show you the prices for subscriptions or other products in your local currency. We may also add personal data to improve the accuracy of your delivery address when we send out mail. We may also obtain your personal data from partners whose offers we include in some of our marketing communications and we use this personal data to ensure that we do not send you irrelevant marketing.
- We also use personal data based on the content you have viewed on our sites and apps and your interaction with the content to add you to groups with similar interests and preferences, so that we can make our online advertising more relevant. Sometimes we use data about your interests or demographics that some of our global third parties have collected from you online to add you to these groups.
- Adding to or combining the personal data you provide to us
- Personal data shared by event partners
When you register or book a ticket for a Jengaleo event organised by an event partner, your registration data may be shared with us by the event partner.
- USING CHILDREN’S PERSONAL DATA
- We do not knowingly collect personally identifiable information from children (any person under 18 years of age). If you are a parent or guardian and you are aware that your child has provided Us with Personal Data, please contact Us via ……..(insert email address) If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
- By using our site, you represent that you are at least 18 years or that you are the parent or guardian of such a minor and consent to such minor use of the Site.
- SECURITY OF YOUR PERSONAL DATA
- We have implemented appropriate technical and organisational controls to protect your personal data against unauthorised processing and against accidental loss, damage or destruction.
- You are responsible for choosing a secure password when we ask you to set up a password to access parts of our sites or apps. You should keep this password confidential and you should choose a password that you do not use on any other site. You should not share your password with anyone else, including anyone who works for us.
- Unfortunately, sending any information, including personal data, via the internet is not completely secure. Although we will do our best to protect your personal data once with us, we cannot guarantee the security of any personal data sent to our site while still in transit and so you provide it at your own risk.
- WHEN WE SHARE OR SELL YOUR PERSONAL DATA
- Within Jengaleo group of companies
- We may share your personal data within the Jengaleo group of companies in Kenya. We may share it in order to perform a contract with you, for administrative purposes, or when we have a legitimate interest in doing so.
- If you are going to one of our events hosted by an event partner, we may share your personal data with that partner for event administration purposes;
- Sometimes we may receive a letter, email or another form of communication from you that we consider to be significant to the history of Jengaleo. We may decide to share this with the Jengaleo Archive run by Jengaleo for historic and archiving purposes;
- We may share your data to understand how you interact across our group products or to tailor and offer relevant advertising to you.
- Within Jengaleo group of companies
- With external organisations
We share your personal data with other organisations that are not directly linked to us under the following circumstances:
- Service providers – We may share your data with other organisations that provide services on our behalf. We may do this to perform a contract we have entered into with you, where it is in our legitimate interests or with your consent. Examples of when we may share your data with service providers include sharing with:
- online payments processors who process credit and debit card transactions on our behalf;
- fraud management providers that help us to identify and prevent online fraud;
- internet and cloud hosting services providers;
- life-cycle engagement platforms to help us build and manage our campaigns;
- software service providers that assist us with our customer relationship management;
- communications services providers;
- error tracking software providers to help us diagnose and fix errors and optimise the performance of our website and apps;
- service providers that help us carry out analytics, facilitate audience creation and segmentation and to measure our audience engagement;
- service providers that help provide us with insights and analytics that help us to improve our products and services;
- data management companies that help us collect data via online forms and surveys.
- Advertising partners – We may also share your data collected through our websites and apps with our advertising partners. These partners help us deliver relevant advertising across our websites and apps. For example, we use Google Ad Manager to assist us with the delivery of relevant ads.
- Agencies and authorities if required by law – We may reveal your personal data to any law enforcement agency, court, regulator, government authority, or in connection with any legal action if we are required to do so to meet a legal or regulatory obligation, where the request is proportionate, or otherwise to protect our rights or the rights of anyone else. We will attempt to notify you prior to disclosing your data unless:
- prohibited by applicable law from doing so, or
- there are clear indications of unlawful conduct in connection with your use of our services.
- Event sponsors and partners – we may share your personal data with sponsors of Jengaleo events and partners who we hold events with for marketing purposes when you have given your permission for us to do so.
- Social media organisations – We may share your personal data with other organisations when our web pages use social plug-ins from these organisations (such as the “Facebook Recommend” function, Twitter’s retweet function, Google+ function). These other organisations may receive and use personal data about your visit to our sites or apps. If you browse our site or view content on our apps, personal data they collect may be connected to your account on their site. For more information on how these organisations use personal data, please read their privacy policies.
- Any organisations which access your data in the course of providing services on our behalf will be governed by strict contractual restrictions to make sure that they protect your data and keep to all data privacy laws that apply. We may also independently audit these service providers to make sure that they meet our standards.
- These transfers to third parties may constitute “sale” of your personal information under Kenyan law.
- Third-parties do not sell personal information that has been sold to them by Jengaleo unless you have first received explicit notice and are provided an opportunity to exercise the right to opt out.
- INTERNATIONAL DATA TRANSFERS
- Data we collect may be transferred to, stored and processed in any country or territory where one or more of our Jengaleo group companies or service providers are based or have facilities;
- Whenever we transfer your personal data out of Kenya, we ensure similar protection and put in place at least one of these safeguards:
- We will only transfer your personal data to countries that have been found to provide an adequate level of protection for personal data;
- We may also use specific approved contracts that use Standard Contractual Clauses for the protection of personal data where appropriate, with our service providers that are based in countries outside Kenya. These contracts give your personal data the same protection it has in Kenya.
- How long we keep your personal data
- We keep your personal data for only as long as we need to;
- We may also need to keep your personal data for accounting purposes, for example, where you have bought a subscription;
- If we no longer need your data, we will delete it or make it anonymous by removing all details that identify you;
- If we have asked for your permission to process your personal data and we have no other lawful grounds to continue with that processing, and you withdraw your permission, we will delete your personal data. However, when you unsubscribe from marketing communications, we will keep your email address to ensure that we do not send you any marketing in future.
- HOW WE MAY CONTACT YOU
- Service communications
From time to time we may send you service emails, for example, telling you your subscription is coming to an end or thanking you when you contribute or place an order with us.
- Marketing communications and editorial newsletters
- If we have your permission, we may send you materials we think may interest you, such as offers and updates. Depending on your marketing preferences, this may be by email, phone, SMS or post;
- We offer a range of editorial newsletters. You can manage your subscription to these emails through your profile page when you are signed in to your Jengaleo account;
- You can decide not to receive these emails at any time and will be able to “unsubscribe” directly by clicking a link in the email or through your email preferences in the tab “emails and marketing” when you are signed in to your Jengaleo account.
- Market research
Sometimes we may contact you for market research purposes, for example about a survey. You can opt out from being contacted in this way by signing into your Jengaleo account and going to the tab “emails and marketing”.
- Responding to your queries or complaints
If you have raised a query or a complaint with us, we may contact you to answer your query or to resolve your complaint.
- COOKIES AND SIMILAR TECHNOLOGIES
- YOUR PRIVACY AND DATA PROTECTION RIGHTS WITH REGARD TO THE PERSONAL DATA THAT WE HOLD ABOUT YOU
- Subject to the applicable laws, you may have the following rights regarding the Processing of your Relevant Personal Information:
- the right not to provide your Personal Information to us (however, please note that we will be unable to provide you with the full benefit of our Sites, Apps, products, or services, if you do not provide us with your Personal Information – e.g., we might not be able to process your requests without the necessary details and you may not be able to use our services without providing the necessary information);
- the right to request access to, or copies of, your Relevant Personal Information, together with information regarding the nature, Processing and disclosure of those Relevant Personal Information;
- the right to request rectification of any inaccuracies in your Relevant Personal Information;
- the right to request, on legitimate grounds:
- erasure of your Relevant Personal Information; or
- restriction of Processing of your Relevant Personal Information.
- the right to have certain Relevant Personal Information transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable;
- where we Process your Relevant Personal Information on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Information in reliance upon any other available legal bases); and
- the right to lodge complaints regarding the Processing of your Relevant Personal Information with a Data Protection Authority.
- the right to object, on grounds relating to your particular situation, to the Processing of your Relevant Personal Information by us or on our behalf; and
- the right to object to the Processing of your Relevant Personal Information by us or on our behalf for direct marketing purposes.
- Subject to the applicable laws, you may have the following rights regarding the Processing of your Relevant Personal Information:
- This does not affect your statutory rights.
- To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Policy, or about our Processing of your Personal Information, please use the contact details provided below.
- Please note that:
- in some cases, it will be necessary to provide evidence of your identity before we can give effect to these rights; and
- where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.
- CONTACT US FOR INFORMATION ABOUT HOW WE USE YOUR PERSONAL DATA
- If you have any questions about how we use your personal data or if you have a concern about how your personal data is used, please contact the Data Protection Officer at ……………………………… Or, email …………………………
- Complaints will be dealt with by the Data Protection Team, and will be responded to within 30 days.
- If you are not satisfied with the way your concern has been handled, you can refer your complaint to the Information Commissioner’s Office.
- If you have a question about anything else, please see our Contact us page.
- If the changes are significant, we may also choose to email all our registered users with the new details.
- If required by law, we will get your permission or give you the opportunity to opt out of any new uses of your data.
- ACCEPTANCE OF THIS POLICY
You acknowledge that you have read this Policy and agree to all its terms and conditions. By using the Website or its Services you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to use or access the Website and its Services.