Data protection privacy statement

1. INTRODUCTION

Wananchi Group (Kenya) Limited (“Wananchi Group”) is committed to protecting the privacy of Personal Data.

This privacy statement describes how Wananchi Group protects the Personal Data it processes, why and how we collect and use your Personal Data and how you can exercise your rights in relation to the processing of your Personal Data.

2. SCOPE

This privacy statement shall apply to all customers and employees of Wananchi Group and all external business partners (such as suppliers, contractors, and consultants engaged by Wananchi Group) from whom we shall receive, send, collect, access, or process Personal Data in any way.

3. DEFINITIONS

a). Personal Data constitutes personally identifiable information that identifies you as a unique individual or any information that reveals the identity of an actual living person. This includes information such as your name(s) identification numbers, account number, phone number, location, date of birth, email, IP address, passport number, postcode or city of residence, login name/screen name/handle/nickname, age & gender, Web cookies and usage data.

b). Sensitive personal data constitutes data revealing your race, health status, ethnic social origin, conscience, belief, genetic data, biometric data, property details, marital status, family details including details of your children, parents, spouse or spouses, sex or sexual orientation.

c). Wananchi Group, we, our (s), us means Wananchi Group (Kenya) Limited and includes its successors in title and assigns, its affiliates and/or its subsidiaries .

d). “You” means customer using our services and products; visitors who gain access to our premises; contractors; consultants and service provided contracted by Wananchi Group.

4. PROCESSING OF PERSONAL DATA

Wananchi Group shall in the course of interactions with you will collect your Personal Data with your knowledge and consent with exception to cases where prior consent cannot be obtained for real reasons and the processing of the data is permitted by law.

Wananchi Group will collect your data in the following circumstances:-

• When you are making an application to purchase or use any of our products and services;
• When you use our network as part of service provision;
• When you subscribe to our newsletters, email alerts, SMS or other messaging services from us;
• When you contact us through various social media platforms, WhatsApp, official telephone numbers, emails etc. to ask for information about a product or service with a query or complaint;
• When you visit or browse our website;
• When you visit our premises;
• When you are employed or make an application for a job at Wananchi Group;
• When you have been identified as a next of kin by our customer or employee;
• When you respond to or participate in a survey, marketing promotion, prize competition or special offers;
• We may also obtain data about you from 3^rd parties

The list above is non-exhaustive, which is reflective of the varied nature of the Personal Data we may collect.

You have choices when it comes to the data you share with us. When we ask you to provide Personal Data, you can decline. Most of our products require some Personal Data for us to be able to provide you with a service. Where we need to collect Personal Data by law or to enter into or carry out a contract with you, and you do not provide the data, we will not be able to enter into the contract; or if this relates to an existing product/service you’re using, we may have to suspend or cancel it.

5. USE OF PERSONAL DATA

Wananchi Group is committed to ensure that your Personal Data is processed in a way that is compatible with the specified, explicit, and legitimate purpose of collection.

We shall use your Personal Data to facilitate current and potential business dealings with you, which includes but is not limited to:

• Verify your identity, accuracy of your account(s) with us and contact information;
• Verification of age and consent where the personal data relates to a child;
• Complete transactions effectively and bill for services;
• Respond to your request for service, queries or complaints;
• Perform market analysis, market research, business and operational analysis;
• Provide, develop, maintain and improve our products and services which includes updating, securing, and troubleshooting, as well as providing support.
• Anticipate and resolve issues and concerns with our products and services;
• Advertise and market to you about new products and services which includes sending promotional communications, targeting advertising, and presenting you with relevant offers (unless you opt out of receiving such marketing messages (you may contact Wananchi Group) at any time to opt out of receiving marketing messages).
• Ensure adherence to legal and regulatory requirements for prevention and detection of fraud and crimes.
• “Remember” your online profile and preferences.
• In business practices including quality control, training and ensuring effective systems operations.
• We also use the data to operate our business, which includes analyzing our performance, meeting our legal obligations, developing our workforce, and doing research.
• Manage and process your job application. We may use your Personal Data provided to us through job applications for purposes of processing your job application. This may also include data we collect from 3^rd parties such as recruitment firms, references, past employers and academic institutions in order to identify and evaluate candidates for potential employment. We may conduct vetting for some job roles which may include criminal background checks and other relevant checks we may deem necessary.
• Where you are an employee (including consultants), we create an employment record of you on our system to facilitate continuous monitoring during your employment with us.
• For security purposes when accessing any of Wananchi Group buildings/premises; and
• Where you attend an event sponsored or hosted by Wananchi Group, we will be taking photos or videos of the event. These images or videos will be used by us to share news about the event, and may be used in press releases, printed publicly, and published on our website and social media pages.

6. SENSITIVE PERSONAL DATA

We may collect Sensitive Personal Data about you (this includes details about your race, health status, ethnic social origin, conscience, belief, genetic data, biometric data, property details, marital status, family details including details of your children, parents, spouse or spouses, sex or sexual orientation and biometric data). We will rely on any of the legal basis provisions below for such collection

7. LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA

We will process your Personal Data and Sensitive Personal Data as permitted by the Data Protection Act as amended from time to time:

• For the performance of a contract which you are party to;
• Where processing is necessary for the purposes of legitimate business interests pursued by Wananchi Group or by a third party within the confines of the law;
• For the establishment, exercise or defense of a legal claim;
• Compliance with a mandatory legal obligation to which Wananchi Group is subject to;
• With your consent;
• Public interest;
• To protect your vital interest or the vital interests of any 3^rd  Party

8. TRANSFER OF PERSONAL DATA

Wananchi Group has affiliates locally and globally and from time to time we may share your Personal Data within the various affiliate entities. Such information may be used by each entity for its internal business, operational and investigation purposes as well as any other purpose consistent with the intended purpose for which the information was originally collected.

Where we send your information outside the Republic of Kenya, we will make sure that your data is properly protected in accordance with the applicable Data Protection Laws. We shall ensure that there is proof of adequate data protection safeguards in the recipient country or consent from you on transfer of your personal data.

9. DATA INTEGRITY

You are responsible for the accuracy of all Personal Data that you provide to us. We will make reasonable efforts to maintain the accuracy and integrity of your Personal Data and to update it once you notify. Please contact our Customer Experience Department to update your details.

10. DISCLOSURE OF PERSONAL DATA

Wananchi Group will safeguard your data and may disclose under below circumstances; –

• With your consent,
• to its affiliates, professional advisors and other service providers of Wananchi, including
• credit bureaux (in order to perform credit and background checks) and collection agencies (for the collection of outstanding accounts),
• survey agencies that conduct survey on behalf of Wananchi Group,
• regulatory bodies, other government agencies and other law enforcement bodies and for compliance with legal obligations to which Wananchi is subject to,
• emergency service providers when you make an emergency call;
• if the data is required to detect, prevent or address fraud, security or technical issues,
• any other person that we deem legitimately necessary to share the data with.

11. DIRECT MARKETING

From time to time, we may also use your Personal Data to contact you with offers, promotions or to provide you with information about new services or other services we think would be of interest to you.

We respect your right to control your Personal Data depending on which of our products or services you use. Therefore, at a minimum, we will always give you the opportunity to opt out of receiving such direct marketing messages. You may exercise this right to opt-out at any time.

 12. RETENTION OF INFORMATION

Wananchi Group shall not retain your personal data for longer than is necessary except if the same is required to fulfil the purposes we collected it for which may include any legal, regulatory, tax, accounting or reporting requirements. In the event there is a complaint, litigation or dispute of whatever nature, we shall retain your personal data for a longer period.

When we have no ongoing legitimate business to process or retain your personal data, we will either delete or anonymize it or where this is not possible, we will securely store it and isolate it from any further processing until deletion is possible in accordance with our Data Retention Policy.

13. SECURITY PRACTICES AND PROCEDURE

We have implemented reasonable security practices and procedures, to include technical, operational and physical security controls in order to protect your Personal Data from unauthorized access or disclosure while it is under our control. However, no method of transmission over internet or electronic storage is full proof secure hence we cannot guarantee absolute security of your personal data.

14. YOUR RIGHTS

Subject to legal and contractual exceptions, you have rights in relation to your Personal Data which we hold in our possession. These rights are:

• Right to be informed; You have the right to be informed that we are collecting your Personal Data and for what purpose;
• Right to access Personal Data in our custody;
• Right to request that we correct your Personal Data where it is false, misleading, inaccurate or incomplete;
• Right to object to the processing of your Personal Data;
• Object to processing your Personal Data for direct marketing. You can exercise the right by opting out as maybe provided. If you opt out of marketing, you may still receive service-related messages.
• Right to request that we erase your Personal Data noting that we may continue to retain your information if obligated by the law or entitled to do so;
• Right to object and withdraw your consent to processing of your Personal Data. We may continue to process if we have a legitimate or legal reason to do so;
• Right to request restricted processing of your Personal Data noting that we may be entitled or legally obligated to continue processing your data and decline your request;
• Right to request transfer of your personal data to another data controller.

 15. CONTACT US

Please contact our Data Protection Officer if you want to exercise any of your rights in relation to your Personal Data by writing to us on email at dataprotection@ke.wananchi.com

 17. CHANGES TO THE PRIVACY STATEMENT

Wananchi Group reserves the right to amend or modify this privacy statement from time to time and your continued use of our products and services constitutes your agreement to be bound by the terms of any such amendment or variation.

Any amendment or modification to this statement will take effect with immediate effect. You can access the most current version of our privacy statement from www.zuku.co.ke