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EQUITY GROUP HOLDINGS PLC
DATA PRIVACY POLICY
Table of Contents- DEFINITIONS
- WHO WE ARE
- INFORMATION WE COLLECT
- INFORMATION YOU PROVIDE
- AUTOMATICALLY COLLECTED INFORMATION
- THIRD-PARTY INFORMATION
- HOW WE USE INFORMATION
- HOW WE WORK WITH OTHER EQUITY GROUP HOLDINGS PLC AND IT’S SUBSIDIARIES
- ASSIGNMENT, CHANGE OF CONTROL, AND TRANSFER
- HOW THE GENERAL DATA PROTECTION REGULATION APPLIES TO OUR EUROPEAN REGION USERS
- HOW YOU EXERCISE YOUR RIGHTS
- MANAGING AND DELETING YOUR INFORMATION
- LAW AND PROTECTION
- OUR GLOBAL OPERATIONS
- UPDATES TO OUR POLICY
- CONTACT INFORMATION
- HOW WE PROCESS YOUR INFORMATION
- INTELLECTUAL PROPERTY POLICY: YOUR COPYRIGHTS AND TRADEMARKS
19.3 How to control cookies
1. DEFINITIONS
| Biodata | Biographical information: Personal information with regard to gender, nationality, contact information, physical location, and any other |
| Controller | Means the natural or legal person, authority, organization or other agency that makes decisions individually or together with other parties regarding the purposes and means for processing Personal Data. |
| Equity Group | Means Equity Group Holdings Plc, a registered holding company and its subsidiaries. |
| GDPR | Means the General Data Protection Regulation((EU) 2016/679) |
| Personal Data | Means any information identifying you or information relating to you that we can identify (directly or indirectly) from that data alone or in combination with other identifiers we possess or can reasonably access. Personal Data excludes anonymous data or data that has had the identity of you as an individual permanently removed. |
| Processor | Means a natural or legal person, authority, organization or other agency that processes Personal Data on behalf of the Controller. |
| Responsible Person Subsidiaries | Means information security department means, with respect to Equity Group Holdings Plc, any corporation, association, partnership or other business entity of which more than 50% of the total voting power of shares of Capital Stock or other interests (including partnership interests) entitled (without regard to the occurrence of any contingency) to vote in the election of directors, managers, general partners or trustees thereof is at the time owned or controlled, directly or indirectly, by (i) Equity Group Holdings Plc; (ii) Equity Group Holdings Plc and one or more Subsidiaries of Equity Group Holdings Plc; or (iii) one or more Subsidiaries of Equity Group Holdings Plc. |
| Register of Systems | Means a register of all systems or contexts in which personal data is processed by Equity Group. |
2. WHO WE ARE
We are Equity Group Holdings Plc (“Equity Group”, “we”, or “us”) – a parent holding company of Equity Group subsidiaries with our registered office at Equity Centre, Hospital Road, Upper Hill, Nairobi, Kenya. If you live in Kenya or any other country, we are the data controller responsible for your personal information when you subscribe to and access/ use any of our services available in our banking and non-banking subsidiaries. The services may be subscribed to/ accessed via personal contact, Equity group websites, mobile app, and via telephone. Our Privacy Policy("Privacy Policy") helps explain our information (including correspondences) practices, including the information we process to support our Services. For example, we talk about what information we collect and how this affects you. We also explain the steps we take to protect your privacy. This Privacy Policy applies to all Equity Group services unless specified otherwise. Please also read Terms and Conditions ("Terms"), which describe the terms under which you access and use our Services.3. INFORMATION WE COLLECT
We must receive or collect some information to operate, provide, improve, understand, customize, support, and market our Services. This also includes when you install, access, or use our Services. The types of information we receive and collect depend on how you use our Services.4. INFORMATION YOU PROVIDE
- a) Your Contact and Financial Data
- b) Your Use Of Our Payments Services
- c) Customer Support (Communication Data)
5. AUTOMATICALLY COLLECTED INFORMATION
- a) Usage and Log Information
- b) Device and Connection Information
- c) Location Information
- d) Cookies
6. THIRD-PARTY INFORMATION
- a) Information Others Provide About You
- b) Businesses on Equity Group
- c) Third-Party Service Providers
- d) Third-Party Services
7. HOW WE USE INFORMATION
We use the information we have (subject to choices you make) to operate, provide, improve, understand, customize, support, and market our Services. Here's how:- a) Our Services
- b) Safety and Security
- c) Communications About Our Services And The Equity Group Holdings Plc and its subsidiaries
- d) No Third-Party Banner Ads
- e) Commercial Messaging
- f) Measurement, Analytics, and Other Business Services
- g) Information You and We Share
- h) Send Your Information to Those You Choose To Communicate With
- Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
- Our business partners, suppliers and sub-contractors for the performance of any contract we enter into with you
- Advertisers and advertising networks that require the data to select and serve relevant ad-verts to you and others. [We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users)
- Our agents
- Government and enforcement agencies and
- Credit and other payment card companies and screening companies.
- i) Account Information
- j) Your Contacts and Others
- k) Businesses on Equity Group
- l) Third-Party Service Providers
- m) Third-Party Services
8. HOW WE WORK WITH OTHER EQUITY GROUP HOLDINGS PLC AND IT’S SUBSIDIARIES
We are part of the Equity Group Holdings Plc and its subsidiaries. As part of the Equity Group Holdings Plc and its subsidiaries, Equity Group receives information from, and shares information with, the Equity Group Holdings Plc and its subsidiaries. We may use the information we receive from them, and they may use the information we share with them, to help operate, provide, improve, understand, customize, support, and market our Services and their offerings. This includes helping improve infrastructure and delivery systems, understanding how our Services or theirs are used, helping us provide a way for you to connect with businesses, and securing systems. We also share information to fight spam, threats, abuse, or infringement activities and promote safety and security across the Equity Group and its Subsidiaries Products. However, your messages will not be shared onto the Group and its subsidiaries for others to see. In fact, the Group and its subsidiaries will not use your messages for any purpose other than to assist us in operating and providing our Services.9. ASSIGNMENT, CHANGE OF CONTROL, AND TRANSFER
All of our rights and obligations under our Privacy Policy are freely assignable by us to any of our affiliates, in connection with a merger, acquisition, restructuring, or sale of assets, or by operation of law or otherwise, and we may transfer your information to any of our affiliates, successor entities, or new owner.10. HOW THE GENERAL DATA PROTECTION REGULATION APPLIES TO OUR EUROPEAN REGION USERS
- a) Our Legal Bases For Processing Information
- as necessary to fulfill our Terms;
- consistent with your consent, which you can revoke at any time;
- as necessary to comply with our legal obligations;
- occasionally to protect your vital interests, or those of others;
- as necessary in the public interest; and
- as necessary for our (or others') legitimate interests, including our interests in providing an innovative, relevant, safe, and profitable service to our users and partners, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data.
11. HOW YOU EXERCISE YOUR RIGHTS
Under the General Data Protection Regulation or other applicable local laws, you have the right to access, rectify, port, and erase your information, as well as the right to restrict and object to certain processing of your information. This includes the right to object to our processing of your information for direct marketing and the right to object to our processing of your information where we are performing a task in the public interest or pursuing our legitimate interests or those of a third party. You can access or port your information using our in-app Request Account Info feature (available under Settings > Account). You can access tools to rectify, update, and erase your information directly in-app as described in the Managing and Deleting Your Information section. If we process your information based on our legitimate interests or those of a third party, or in the public interest, you can object to this processing, and we will cease processing your information, unless the processing is based on compelling legitimate grounds or is needed for legal reasons. You can also object to our processing of your information and learn more about your options for restricting the way we use your information by visiting http://equitygroupholdings.com/privacy-policy. Where we use your information for direct marketing for our own Services, you can always object and opt out of future marketing messages using the unsubscribe link in such communications.12. MANAGING AND DELETING YOUR INFORMATION
We store information until it is no longer necessary to provide our services, or until your account is deleted, whichever comes first. All information you provide to us is stored on our secure servers. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access. Length of data retention is a case-by-case determination that depends on things like the nature of the information, why it is collected and processed, and relevant legal or operational retention needs.13. LAW AND PROTECTION
We collect, use, preserve, and share your information if we have a good-faith belief that it is reasonably necessary to: (a) respond pursuant to applicable law or regulations, to legal process, or to government requests; (b) enforce our Terms and any other applicable terms and policies, including for investigations of potential violations; (c) detect, investigate, prevent, and address fraud and other illegal activity, security, or technical issues; or (d) protect the rights, property, and safety of our users, Equity Group, the Equity Group Holdings Plc and it’s subsidiaries , or others, including to prevent death or imminent bodily harm.14. OUR GLOBAL OPERATIONS
Equity Group shares information globally, both internally within the Equity Group Holdings Plc and its subsidiaries, and externally with our partners and with those you communicate around the world in accordance with this Privacy Policy. Information controlled by Equity Group will be transferred or transmitted to, or stored and processed, in the Republic of Kenya or other countries outside of where you live for the purposes as described in this Privacy Policy. These data transfers are necessary to provide the Services set forth in our Terms and globally to operate and provide our Services to you. If the other jurisdiction does not have the same level of protection for personal data, when we do process the data, we shall put in place appropriate safeguards e.g. contractual commitments to ensure the data is adequately protected. We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. Where third parties are based in other jurisdictions, their processing of your personal data will involve a transfer of data to other jurisdictions. Equity Group shares information globally, both internally within the Equity Group Holdings Plc and its subsidiaries, and externally with businesses, service providers, and partners and with those you communicate with around the world. Your information may, for example, be transferred or transmitted to, or stored and processed in the United States or other countries outside of where you live for the purposes as described in this Privacy Policy.15. UPDATES TO OUR POLICY
We will notify you before we make changes to this Privacy Policy and give you the opportunity to review the revised Privacy Policy before you choose to continue using our Services.16. CONTACT INFORMATION
If you are in the European region; The Data Protection Officer for Equity Group can be contacted at info@equitygroupholdings.com. If you have questions about our Privacy Policy, please contact us or write us here: Equity Group Holdings Plc 9th Floor, Equity Centre Hospital Road, Upper Hill Nairobi, Kenya P.O. Box 75104-00200 You have the right to lodge a complaint with Equity Group. If you are outside the European region; If you have questions about our Privacy Policy, please contact us on info@equitygroupholdings.com or write us here: Equity Group Holdings Plc 9th Floor, Equity Centre Hospital Road, Upper Hill Nairobi, Kenya P.O. Box 75104-0020017. HOW WE PROCESS YOUR INFORMATION
Under European law, companies must have a legal basis to process data. You have particular rights available to you depending on which legal basis we use, and we've explained these below. You should know that no matter what legal basis applies, you always have the right to request access to, rectification of, and erasure of your data under the General Data Protection Regulation (the "GDPR"). For all people who have legal capacity to enter into an enforceable contract, we process data as necessary to perform our contracts with you (the Terms of Service, the "Terms"). We describe the contractual services for which this data processing is necessary in Our Services section of the Terms and in the additional informational resources accessible from our Terms. The core data uses necessary to provide our contractual services are: To provide, improve, customize, and support our Services as described in "Our Services";- To promote safety and security;
- To transfer, transmit, store, or process your data outside the EEA, including to within the United States and other countries; and
- To communicate with you, for example, on Service-related issues.
- We'll use the data we have to provide these services; if you choose not to provide certain data, the quality of your experience using Equity Group may be impacted.
- When we process data you provide to us as necessary to perform our contracts with you, you have the right to port it under the GDPR. To exercise your rights, visit How You Exercise Your Rightssection of the Privacy Policy.
- a) Your Consent:
- b) Our legitimate interests or the legitimate interests of a third party, where not outweighed by your interests or fundamental rights and freedoms ("legitimate interests"):
- To provide, improve, customize, and support our Services as described in Our Services;
- To promote safety and security; and
- To communicate with you, for example, on Service-related issues.
- c) The legitimate interests we rely on for this processing are:
- To create, provide, support, and maintain innovative Services and features that enable people under the age of majority to express themselves, communicate, discover, and engage with information and businesses relevant to their interests, build community, and utilize tools and features that promote their well-being;
- To secure our platform and network, verify accounts and activity, combat harmful conduct, detect and prevent spam and other bad experiences, and keep our Services and all of the Equity Group and it’s Subsidiaries Products free of harmful or inappropriate content, and investigate suspicious activity or violations of our terms or policies and to protect the safety of people under the age of majority, including to prevent exploitation or other harms to which such individuals may be particularly vulnerable.
- d) For all people, including those under the age of majority:
- To provide accurate and reliable reporting to businesses and other partners, to ensure accurate pricing and statistics on performance, and to demonstrate the value our partners realise using our Services; and
- In the interests of businesses and other partners to help them understand their customers and improve their businesses, validate our pricing models, and evaluate the effectiveness and distribution of their services and messages, and understand how people interact with them on our Services.
- e) For providing marketing communications to you. The legitimate interests we rely on for this processing are:
- To promote Equity Group and its Subsidiaries Productsand issue direct marketing.
- To share information with others including law enforcement and to respond to legal requests. See our Privacy Policy under Law and Protectionfor more information. The legitimate interests we rely on for this processing are:
- To prevent and address fraud, unauthorized use of the Equity Group and its Subsidiaries Products, violations of our terms and policies, or other harmful or illegal activity; to protect ourselves (including our rights, property or Products), our users or others, including as part of investigations or regulatory inquiries; or to prevent death or imminent bodily harm.
- To share information with the Equity Group Holdings Plc and its subsidiaries to promote safety and security. See our Privacy Policy under "How We Work with Other Equity Group Holdings Plc and its subsidiaries"for more information. The legitimate interests we rely on for this processing are:
- To secure systems and fight spam, threats, abuse, or infringement activities and promote safety and security across the Equity Group and its Subsidiaries Products. You have the right to object to, and seek restriction of, such processing; to exercise your rights, visitHow You Exercise Your Rights section of the Privacy Policy. We will consider several factors when assessing an objection including: our users' reasonable expectations; the benefits and risks to you, us, other users, or third parties; and other available means to achieve the same purpose that may be less invasive and do not require disproportional effort. Your objection will be upheld, and we will cease processing your information, unless the processing is based on compelling legitimate grounds or is needed for legal reasons. If you are under the age of majority in your country and have a limited ability to enter an enforceable contract, we will take particular account of the fact that you are below the age of majority and adjust our assessment of our legitimate interests and the balancing of your interests and rights accordingly.
- f) Compliance with a legal obligation:
- g) Protection of your vital interests or those of another person:
- h) Tasks carried out in the public interest:
18. INTELLECTUAL PROPERTY POLICY: YOUR COPYRIGHTS AND TRADEMARKS
Equity Group ("Equity Group," "our," "we," or "us") is committed to helping people and organizations protect their intellectual property rights. Our users agree to our Terms of Service ("Terms") by installing, accessing, or using our apps, services, features, software, or website (together, "Services"). Our Terms do not allow our users to violate someone else's intellectual property rights when using our Services, including their copyrights and trademarks. As explained in more detail in our Privacy Policy, we do not retain our users' messages in the ordinary course of providing our Services. We do, however, host our users' account information, including our users' profile picture, profile name, or status message, if they decide to include them as part of their account information.18.1 Copyright
To report copyright infringement and request that Equity Group remove any infringing content it is hosting (such as a F user's profile picture, profile name, or status message on our Service), please email a completed copyright infringement claim to info@equitygroupholdings.com (including all of the information listed below). You can also mail a complete copyright infringement claim to Equity Group's: Equity Group Holdings Plc Attn: Legal Counsel 9th Floor, Equity Centre Hospital Road, Upper Hill Nairobi, Kenya P.O. Box 75104 - 00200 Before you report a claim of copyright infringement, you may want to send a message to the relevant Equity Group user you believe may be infringing your copyright. You may be able to resolve the issue without contacting Equity Group.18.2 Trademark
To report trademark infringement and request that Equity Group remove any infringing content it is hosting, please email a complete trademark infringement claim to info@equitygroupholdings.com (including all of the information listed below). Before you report a claim of trademark infringement, you may want to send a message to the relevant Equity Group user you believe may be infringing your trademark. You may be able to resolve the issue without contacting Equity Group. What to include in your copyright or trademark infringement claim to Equity Group Please include all of the following information when reporting a copyright or trademark infringement claim to Equity Group: Your complete contact information (full name, mailing address, and phone number). Note that we regularly provide your contact information, including your name and email address (if provided), the name of your organization or client who owns the rights in question, and the content of your report to the person whose content you are reporting. You may wish to provide a professional or business email address where you can be reached. A description of the copyrighted work or trademark that you claim has been infringed. A description of the content hosted on our Services that you claim infringes your copyright or trademark. Information reasonably sufficient to permit us to locate the material on our Services. The easiest way to do this is by providing us the phone number/user name of the individual who has submitted the infringing content on our Services. A declaration that:You have a good faith belief that use of the copyrighted or trademarked content described above, in the manner you have complained of, is not authorized by the copyright or trademark owner, its agent, or the law; The information in your claim is accurate; and you declare, under penalty of perjury, that you are the owner or authorized to act on behalf of the owner of an exclusive copyright or trademark that is allegedly infringed. Your electronic signature or physical signature.19. COOKIES
19.1 About cookies
A cookie is a small text file that a website you visit asks your browser to store on your computer or mobile device.19.2 How we use cookies
We use cookies to understand, secure, operate, and provide our Services. For example, we use cookies:- To provide Equity Group for web and desktop and other Services that are web-based, improve your experiences, understand how our Services are being used, and customize our Services;
- To understand which of our FAQs are most popular and to show you relevant content related to our Services;
- To remember your choices, such as your language preferences, and otherwise to customize our Services for you; and
- To rank the FAQs on our website based on popularity, understand mobile versus desktop users of our web-based Services, or understand popularity and effectiveness of certain of our web pages.
19.3 How to control cookies
You can follow the instructions provided by your browser or device (usually located under "Settings" or "Preferences") to modify your cookie settings. Please note that if you set your browser or device to disable cookies, certain of our Services may not function properly.20. DISCLAIMER
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these web-sites 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.
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