Privacy Policy – WISE Shop

Introduction /background

Our Client’s data and personal information are crucial to us. This privacy policy explains how WISE Shop processes data provided by its clients. Where there is a conflict with regard to the protection of client data, this policy shall prevail.

Definitions

‘’Customer’’ – the person who subscribes to, uses or purchases any of our products and services, accesses our websites or social media sites.
‘’Employee’’ -Any person employed by WISE on a contract basis who has signed or shall sign an Employment Agreement.
‘’WISE’’ – WISE Shop
“Personal Data” has the meaning as defined in the Act, including any information that allows a natural person (also data subject) to be identified or with which a natural person can be identified.
‘’Consultant’’– Any entity (person or Company) hired by WISE on a project basis and has signed a Consultancy Agreement.
‘’Supplier’’ – Any entity (person or Company) that provides products or services to WISE
‘’Temporary Staff’’ – Any person hired by WISE on a temporary basis in relation to a project duration or on the basis of a temporary assignment.
References ‘’ Data ‘’ means

As defined in General Data Protection Regulation (GDPR) and the Data Protection Act 2018 to include a telephone number, email address and purchase details.

Policy Statement

WISE Shop is committed to the highest standards of honesty, openness and accountability. It aims to ensure that it operates in a responsible manner, taking into account ethical business standards. It recognizes that every individual has an important role in helping to achieve these standards. The purpose of this Policy is, therefore, to assist and enable sufficient service delivery to our customer’s.

Collection and Use of Personal Information

This Privacy policy provides for our client’s rights as a data subject and for information on how we collect, use, process, share and protect their personal data.

What information do we collect?

Our interaction with our clients enables us to collect information that is not limited to personal data i.e. telephone number, email address, purchase details, social media handles, websites, company information, physical, email addresses. This data is collected in the normal course of business and is collected with the customer’s consent that such data shall only be utilized for the purposes as set out in this policy.

The Legal Grounds we have to use Client Personal Information

WISE generally collects only the personal information necessary to fulfil the client requests. Where additional, optional information is sought, we notify our clients of this at the point of collection.

We are permitted under law to process personal data under the following conditions: –

Performance of a contract: where processing of Client personal information is necessary in order to perform our obligations under a contract;
Legal obligation: to fulfil legal obligations to capture information for the purpose of taxation and providing information to a public body or law enforcement agency;
Legitimate interests: we will process client information where it is in our legitimate interest in running a lawful business to do so in order to further that business, so long as it does not outweigh client interests; or
Client consent: where we have obtained our Client consent to process their data in a particular way.

Examples of the ‘legitimate interests’ referred to above are:

To improve, enhance, and tailor the Website for you, and to improve and enhance the overall Website experience for all of the Website users.
To prevent fraud or criminal activity and to safeguard our IT systems.
To conduct, and to analyze, our marketing activities.
To meet our corporate and social responsibility obligations.
To exercise our fundamental rights including our freedom to conduct a business and right to property.
To provide the features and functionality of the Website to you.
To consider your candidacy for employment.
To identify you as the sender of, and to process, your emails.
To respond to questions and comments.
To carry out specific actions you may request.
For account validation purposes.
For analytics and trending purposes.

Use of Information

We may use and analyze Client information for the following purposes:

Processing products and services that our clients have bought from WISE through various channels;
Billing our clients for services procured
Responding to any client queries or concerns;
Keeping client’s informed generally about new products and services and contacting them with offers or promotions;
to comply with any legal, governmental or regulatory requirement or for use by our lawyers in connection with any legal proceedings;
In business practices including to quality control, training and ensuring effective systems operations;
To understand how clients use our products and services for purposes of developing or improving products and services;
For research, statistical, survey and other scientific or business purposes;
Provide aggregated data (which do not contain any information which may identify our clients as an individual) to third parties for research and scientific purpose;
Administer any of our online platforms/websites.

Additionally, individuals who voluntarily register on our mailing list, receive our monthly email along with information about upcoming events.

What Personal Data do we collect and process?

Personal Data means any information relating to an identified or identifiable natural person (i.e. living individual).

We collect the following Personal Data through the Website:

Information You Provide to Us

When you use our Website, including when you create an account in our Careers section or submit a CV to us, or when you ask a question through the Website, you may provide us with information that identifies you or your contacts (“personal information”), such as:

Your full name, address, email address, other information may identify you as an individual.
Any personal information you submit to us in any forums, chats or blogs.

Information We Collect from You Automatically

When you use the Website, we may also collect information about your use of the Website and the device used to access the Website that relates to you, but on its own does not identify you (“non-personal information”) such as your:

IP address and country location.
Browser information (including browser type, capabilities, and language).
Operating system.
Date and time, you accessed the Website.
Website usage information, including the paths taken as you move from one website or webpage to another website or webpage.

To the extent WISE associates your personal information with non-personal information within our database; we will treat all the associated information as personal information under this Privacy Policy.

7). Lawful Basis for processing your information

We process clients personal information based on any of the lawful basis provided for under the Data Protection Law.

The performance of a Product/Service Agreement with our clients;
WISE’s legitimate business interests;
Compliance with a mandatory legal obligation;
With client consent;
Public interest;
Client’s vital interest.

8). Retention of Information

We only retain client personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of client personal data, the purposes for which we process client personal data and whether we can achieve those purposes through other means, the need to comply with our internal policy and the applicable legal, regulatory, tax, accounting or other requirements.

9). Disclosure of Information

Any disclosure of client information shall be in accordance with applicable law and regulations. WISE shall assess and review each application for information and may decline to grant such information to the requesting party.

10). Grounds for disclosure of information:

We may disclose client information to our subsidiaries, associates, partners, software developers or agents who are involved in delivering WISE products and services you order or use; Survey agencies that conduct surveys on behalf of WISE;

We cannot release any information to any individual or entity that is acting beyond its legal mandate. We are obliged to get our client’s express consent before we share your personal data with any third party for direct marketing purposes.

11). Direct Marketing

Our clients may be required to opt-in or give any other form of explicit consent before receiving marketing messages from us.

Our clients can ask us to stop sending those marketing messages at any time by writing to us at [email protected]

12). Safeguarding and Protection of Information

WISE has put in place technical and operational measures to protect client information from unauthorized access, accidental loss or destruction.

WISE Employees, Suppliers and Consultants are bound by this Data Privacy Policy and are obliged to uphold it at all times, failure to which shall lead to the immediate termination of any contract that may exist between WISE and the party in breach.

WISE Employees, Suppliers and Consultants shall indemnify and hold indemnified WISE for any breach of this policy that results in the unauthorized access, accidental loss or destruction of our client’s data.

WISE reserves the right to take action against any employee, suppliers and consultant who breach this policy in any manner.

WISE Employees, Suppliers and Consultant understand that the breach of this Data Privacy Policy and of the Data Protection Act with regards to the client data held by WISE may be subject to prosecution under the law.

13). Client Rights

Subject to legal and contractual exceptions, clients have rights under data protection laws in relation to their personal data. These are listed below:

Right to be informed that we are collecting personal data about them;
Right to access personal data that we hold about them and request for information about how we process it;
Right to request that we correct their personal data where it is inaccurate or incomplete;
Right to request that we erase their personal data noting that we may continue to retain their information if obligated by the law or entitled to do so;
Right to object and withdraw their consent to processing of their personal data.
We may continue to process if we have a legitimate or legal reason to do so;
Right to request restricted processing of their personal data noting that we may be entitled or legally obligated to continue processing their data and refuse their request;
Right to request transfer of their personal data in [an electronic format].

We may need to request specific information from them to help us confirm their identity and ensure their right to access their personal data (or to exercise any of their other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact our clients to ask them for further information in relation to your request to speed up our response.

14). Right to Lodge Complaint

Clients have the right to lodge a complaint with the relevant supervisory authority that is tasked with personal data protection within the Republic of Kenya

15). Non-Compliance with this Policy

WISE shall have the right to terminate any agreement with our employees, consultants and suppliers for failure to comply with the provisions of this policy.

16). Amendments to this Policy

WISE reserves the right to amend or modify this policy at any time.

Policy Effective Date

1st of May 2021