Introduction
Protecting the personal, private and confidential information of Connect website users, whether obtained on the website, electronically through email, over the telephone or through our offices, is a fundamental principle, and fundamental to the way we conduct our business. Our operations are therefore based on a Privacy Policy that guides the handling of any and all personal information that we collect. This policy is consistent with the privacy and data protection policy (2018-Kenya) enforced by article 31 of the Constitution and the Kenya Data Protection Act No. 24 of 2019. AmCham Kenya reserves the right to change this policy, and it may be updated periodically. These changes may affect our use of your personal information. Please check for changes regularly.- 1. Privacy Statement This policy deals only with personal information handled by AmCham Kenya through the Connect website. Personal information identifies a specific individual but excludes business contact information. The following explains how we handle your personal information.
- 2. Accountability AmCham Kenya is accountable for all personal information under its control. The Chamber’s privacy officer who is responsible for the privacy policy is: Mercy Mwangi Email: mercy@amcham.co.ke Any questions about our handling of personal information should be directed to our Privacy Officer. Please see below for more information about the process for referring questions regarding your personal information.
- 3. Purpose of Personal Information The purpose for which AmCham Kenya collects personal information will be identified at or before the time the information is collected. We may collect personal information for the purposes of: • Allowing access to restricted information, data or publications on Connect; • Offering various services as listed on the Connect website. • Responding to direct inquiries and making follow-ups. • Providing additional information on our work and other services not listed on Connect. We will not use personal information for any purpose other than that identified at or before the time of collection.
- 4. Consent AmCham Kenya seeks consent for all personal information we collect, use and/or disclose prior to, or at the time of, collection. If you have voluntarily provided information, you have consented to the collection, use and/or limited disclosure of your personally identifiable information as described in this privacy policy. As required by law, we will not use your personal information for any purpose other than that for which you have consented. Should we require personal information for a new purpose, we will contact you to seek consent for that new use.
- 5. Limits for Collecting, Using, Disclosing and Keeping Personal Information AmCham Kenya does not collect, use or disclose personal information of individuals except when you give consent (explicit or implied) and provide the information on a voluntary basis. There may be occasions where more specific personal information is necessary for us to proceed with a request for information or provide you with a product or service. In such cases, we will provide you with a description on the information we need. In all cases, AmCham Kenya limits the amount and type of information collected to only that which is required to provide you with the requested information, product, or service. We collect only information that is voluntarily provided by you and undertake that such information will be kept strictly confidential. We retain personal information only as long as is necessary to provide you with a requested product, service or information. We then delete or destroy this information as appropriate to do so. In some cases, note that legal reporting and retention requirements require us to retain information for a specific amount of time. Under these limited circumstances, privacy-protected information will only be kept for the period required by law. AmCham Kenya will not sell or trade any personal information with third parties. Disclosures of information will be made in circumstances where AmCham Kenya has entered into a contractual arrangement with a third party, and the purpose of that contract is the provision of a product, service or benefit. In such circumstances, information disclosure will be limited to information strictly necessary for the provision of the contracted benefit or service. AmCham Kenya may transfer information to service providers where information processing is outsourced in the course of certain administrative or contractual procedures or services. Where personal information is transferred to a service provider for processing, we require that the provider respect this Privacy Policy and we restrict them from using or disclosing personal information transferred to them for any purpose other than the provision of services to us. Any personal information that we store is always stored in such a manner as to ensure its security and confidentiality.
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6. Safeguarding Personal Information
AmCham Kenya respects the privacy of Connect website
visitors and internet users and will protect that
privacy as vigorously as possible. We store personal
information in electronic and physical files that
are secure.
Our security measures include:
- • Secure locks on filing cabinets
- • Computer system firewall protection
- • Password protected files
- • Virus protected software
- 7. Data Retention AmCham Kenya employ security measures to protect your information from access by unauthorized persons and against unlawful processing, accidental loss, destruction and damage. We will retain your information for a reasonable period or if the law requires.
- 8. Information That We Collect from You When you visit, register or order products or services on Connect you may be asked to provide certain information about yourself including your name, contact details, and credit or debit card information. We may also collect information about the following: Your usage of our website as well as information about you from any messages you post to the website and/or e-mails or electronic communication you send to us. Information about your visit, including but not limited to: your IP Address, operating system, browser version, geographical location, length of your visit and pages visited. This information is held on our server logs and is used for generating anonymous statistics to help us improve our service to you. We reserve the right to use this information to investigate and take action against any misuse of the site. Information provided by you via online forms. This includes, but is not limited to; enquiries, complaints, service request and interest submission forms. Any transaction you perform on our site. This includes personal information that may identify you for the purposes of the transaction and any account you may hold with us. We may also use this information for anonymous statistical purposes.
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9. Use of Your Information
Your information will enable us to provide you with
access
to appropriate parts of our site and to supply the
goods or
services you have requested. It will also enable us
to bill
you and to contact you when necessary, concerning
your
orders. We will also use and analyze the information
we
collect so that we can administer, support, improve
and
develop our business.
In particular, we may use your information to
contact you
for your views on our services and to notify you
occasionally about important changes or developments
to the
site or our services. Further, we might also use
your
information to let you know about other products and
services which we offer which may be of interest to
you and
we may contact you by e-mail.
We may also use your information for all or any of
the
following purposes:
- • To generate anonymous statistical reports. These are essential to give us an overview of how our site is being used and enables us to improve our service.
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• Personal data submitted to this site may
be used for the
following, plus any purpose stated on the
relevant part of
the site:
- o Administer the website;
- o Improve your browsing experience by personalizing the website;
- o Enable your use of the services available on the website;
- o Send statements and invoices to you and collect payments from you;
- o Send you general commercial communications;
- o Send you email notifications which you have specifically requested;
- o Provide third parties with statistical information about our users – without identifying any individual user;
- o Deal with enquiries and complaints made by or about you relating to the website.
- 10. Disclosure of Your Information Third parties outside of Kenya may be used to host the website, process information, fulfil and deliver orders, process credit card payments and provide support services on our behalf. We will only use providers that follow all reasonable safeguards to protect your information. We may also pass aggregate information on the usage of our site to third parties, but this will not include information that can be used to identify you. When providing us with your details, we may also allow carefully selected third parties, including other companies in our membership, to contact you occasionally about products and services which may be of interest to you. They may contact you by e-mail with your consent. Finally, if our business enters into a joint venture with or is sold to or merged with another business entity, your information may be disclosed to our new business partners or owners. Countries outside Kenya may or may not always have strong data protection laws. However, we will always take steps to ensure that your information is used by third parties in accordance with this policy. Unless required to do so by law, we will not otherwise share, sell or distribute any of the information you provide to us without your consent.
- 11. Cookies and Password Protected “Subscription” Accounts Cookies are small amounts of information which we store on your computer. Cookies make it easier for you to log on to and use the site during future visits. They also allow us to monitor website traffic and to personalize the content of the site for you. Cookies cannot damage files, nor can they read information from a user’s hard drive. This cookie does not contain any personal information, but it allows our server to identify you as having successfully logged in so that you do not have to re-enter your password each time you access a password-protected page during that session. You may set up your computer to reject cookies although, in that case, you may not be able to use certain features on our site. In order to access password protected subscription accounts on the Connect website you must accept a cookie from our Web server.
- 12. Accessing and Updating AmCham Kenya will make every effort to keep personal information as accurate, complete, current and relevant as necessary for the identified purposes. We do not routinely update personal information. Also, on written request you may view or edit your personal information as collected and currently stored by AmCham Kenya. You are entitled to see the information held about you and you may ask us to make any necessary changes to ensure that it is accurate and kept up to date. If you wish to do this, please contact us at mercy@amcham.co.ke AmCham will inform you of what personal information we have, what it is being used for and, wherever possible, to whom it has been disclosed. There may be exceptional circumstances as provided by law under which AmCham may not be able to give an individual access to the personal information about her or him held by AmCham, in this case AmCham will explain the reason for this lack of access. Any requests should be directed to our Privacy Officer. To make a request, please send a personally-signed email or letter to: Mercy Mwangi - Privacy Officer Email: mercy@amcham.co.ke In your letter, please specify the following information: your name, complete contact information, business or organizational affiliation, and the nature of your request, including whether you wish to edit or simply view the information, or inquire as to its use and/or disclosure. We will reply to your request within sixty days after receipt of the request, or if we are not able to respond within this time period, we will send you a notice of extension. If we are not able to disclose all the personal information, we hold on you, we will give you a reason for our inability to do so, unless prohibited by law.
- 13. Questions Any questions or comments you may have about our handling of personal information should be directed to our Privacy Officer. 14. Changes to Our Privacy Policy Any changes to our privacy policy in the future will be posted to the site and, where appropriate, through e-mail notification. Contact
