EQUITY GROUP HOLDINGS PLC
DATA PRIVACY POLICY
Table of Contents
1.
DEFINITIONS
3
2.
WHO WE ARE
3
3.
INFORMATION WE COLLECT
4
4.
INFORMATION YOU PROVIDE
4
5.
AUTOMATICALLY COLLECTED INFORMATION
5
6.
THIRD-PARTY INFORMATION
6
7.
HOW WE USE INFORMATION
7
8.
HOW WE WORK WITH OTHER EQUITY GROUP HOLDINGS PLC ND IT’S SUBSIDI RIES
14
9.
ASSIGNMENT, CHANGE OF CONTROL, AND TRANSFER
15
10.
HOW THE GENERAL DATA PROTECTION REGULATION APPLIES TO OUR EUROPEAN REGION USERS
15
11.
HOW YOU EXERCISE YOUR RIGHTS
15
12.
MANAGING AND DELETING YOUR INFORMATION
16
13.
LAW AND PROTECTION
16
14.
OUR GLOBAL OPERATIONS
16
15.
UPDATES TO OUR POLICY
17
16.
CONTACT INFORMATION
17
17.
HOW WE PROCESS YOUR INFORMATION
18
18.
INTELLECTUAL PROPERTY POLICY: YOUR COPYRIGHTS AND TRADEMARKS
20
18.1
Copyright
20
18.2
Trademark
21
19.
COOKIES
22
19.1
About cookies
22
19.2
How we use cookies
22
19.3
How to control cookies
22
20.
DISCLAIMER
23
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 company.
GDPR
Means the General Data Protection Regulation((EU) 2016/679)
Data
Data Protection Act no. 24 of 2019 under the laws of Kenya as amended
Protection Act
and modified from time to time
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
Means information security department
Person
Register of
Means a register of all systems or contexts in which personal data is
Systems
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.
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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.
In addition we may collect, store and use following information about you while you access
your bank account with us through the imobile app or any other electronic devices:
Bayuserid
First name
Middle name
Last name
MPIN - Storing in base64 encoded format.
CIFNumber
Password - Storing in base64 encoded format.
WLDevice ID
Device model
Device OS version
Device OS Type
Last login success date
First activated date
Last reactivated date
Please note, however, that in certain circumstances it may be still lawful for us to continue
processing this information even where consent has been withdrawn, if one of the other legal
bases described below is applicable.
4.
INFORMATION YOU PROVIDE
a) Your Contact and Financial Data
You provide your basic information (including a profile name) to create an account. You
provide us, all in accordance with applicable laws. You may provide us an email address
and your account name. You may also add other information to your account, such as a
profile picture and about information.
b) Your Use Of Our Payments Services
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If you use our payment services available in your country, we process purchase and
transaction information as described in the applicable payments Terms and Conditions.
c)
Customer Support (Communication Data)
You may provide us with information related to your use of our Services, including copies of
your messages, and how to contact you so we can provide you with customer support. For
example, you may send us an email with information relating to our services performance
or other issues.
d)
Personal Contact Details
You may provide us with your biometrics (fingerprints), personal contact details such as
name, title, addresses, telephone numbers, and personal email addresses, Date of birth,
Gender, Employment status and salary, Marital status and dependants, Financial
information, Pay records, Location of employment or workplace, Copies of driving licences
or other IDs like passports.
e)
Third Party Information
Information we obtain from third parties, such as information that we obtain when verifying
details supplied by you and information collected from publicly available sources such as
Companies House. Such third parties may include fraud prevention agencies, banks,
merchants and credit reference agencies. Other information about an individual that you
or they disclose to us when communicating with us, CCTV footage and other information
obtained through electronic means, Photographs, IP addresses, Cookies.
5.
AUTOMATICALLY COLLECTED INFORMATION
a) Usage and Log Information
We collect information about your activity on our Services, like service-related, diagnostic,
and performance information. This includes information about your activity (including how
you use our Services, your Services settings, how you interact with others using our Services,
as well as the time, frequency, and duration of your activities and interactions while using
our Services), log files, and diagnostic, crash, website, and performance logs and reports.
This also includes information about when you registered to use our Services, the features
you use like our messaging, calling, Status, or groups features, profile photo, about
information.
b) Device and Connection Information
We collect device and connection-specific information when you install, access, or use our
Services. This includes information like hardware model, operating system information, app
version, browser information, connection information including phone number, mobile
operator or ISP, language, time zone, IP, device operations information, and identifiers like
device identifiers
products associated with the same device or account).
c) Location Information
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We collect device location information if you use our location features, like when you
choose to share your location with your contacts, view locations nearby or those others
have shared with you, and the like, and for diagnostics and troubleshooting purposes such
as if you are having trouble with our app's location features. We use various technologies
to determine location, including IP, GPS, Bluetooth signals, and information about nearby
Wi-Fi access points, beacons, and cell towers.
d) Cookies
We use cookies to operate and provide our services, including to provide our Services that
are web-based, improve your experiences, understand how our Services are being used,
and customize our Services. For example, we use cookies to provide Equity Group for web
and desktop and other web-based services. We may also use cookies to understand which
of our Frequently Asked Questions (FAQs) are most popular and to show you relevant
content related to our Services. Additionally, we may use cookies to remember your
choices, like your language preferences, to provide a safer experience, and otherwise to
customize our Services for you.
6.
THIRD-PARTY INFORMATION
a)
Information Others Provide About You
We receive information about you from other users and businesses. For example, when
other users or businesses you know use our Services, they may provide your account
number, name, and other information (like information from their mobile address book or in
the case of businesses, additional information about you such as unique identifiers), just as
you may provide theirs. We require each of these users and businesses to have lawful rights
to collect, use, and share your information before providing any information to us.
b)
Businesses on Equity Group
Businesses you interact with using Our Services provide us information about their
interactions with you. A service on Equity Group may also use another company to
authenticate our users, assist it in storing, reading, and responding to your messages on
behalf of and in support of that business. Please note that when businesses use third-party
services, their own terms and privacy policies will govern your use of those services and their
use of your information on those services.
c)
Third-Party Service Providers
We work with third-party service providers and the “Equity Group & its subsidiaries (Equity
customize, support, and market our Services. For example, we work with companies to
distribute our apps, provide our infrastructure, delivery, and other systems, supply location,
map, and places information, process payments, help us understand how people use our
Services, market our Services, help you connect with businesses using our Services, conduct
surveys and research for us, and help with customer service. These companies may provide
us information about you in certain circumstances; for example, app stores may provide us
reports to help us diagnose and fix service issues.
d)
Third-Party Services
We allow you to use our Services in connection with third-party services and Equity Group
and its Subsidiaries’ Products. If you use our Services with such third-party services or Equity
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Group and its Subsidiaries Products, we may receive information about you from them. For
example, if you use the share button on a news service to share a news article with groups,
or broadcast lists on our Services, or if you choose to access our Services through a mobile
carrier's or device provider's promotion of our Services. Please note that when you use third-
party services or Equity Group and its Subsidiaries Products, their own Terms and Privacy
Policies will govern those 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
We use the information we have to operate and provide our Services, including providing
customer support, and improving, fixing, and customizing our Services. We understand how
people use our Services and analyze and use the information we have to evaluate and
improve our Services, research, develop, and test new services and features, and conduct
troubleshooting activities. We also use your information to respond to you when you
contact us.
b)
Safety and Security
We verify accounts and activity, and promote safety and security on and off our Services,
such as by investigating suspicious activity or violations of our Terms, and to ensure our
Services are being used legally.
c)
Communications About Our Services And The Equity Group Holdings Plc and its subsidiaries
We use the information we have to communicate with you about our Services and features
and let you know about our terms and policies and other important updates. We may
d)
No Third-Party Banner Ads
We still do not allow third-party banner ads on Our Services. We have no intention to
introduce them, but if we ever do, we will update this policy.
e)
Commercial Messaging
We will allow you and third parties, like businesses, to communicate with each other using
Our Services , such as through order, transaction, and appointment information, delivery
and shipping notifications, product and service updates, and marketing. For example, you
may receive flight status information for upcoming travel, a receipt for something you
purchased, or a notification when a delivery will be made. Messages you may receive
containing marketing could include an offer for something that might interest you. We do
not want you to have a spammy experience; as with all of your messages, you can manage
these communications, and we will honor the choices you make.
f)
Measurement, Analytics, and Other Business Services
We help businesses who use Our Equity Group measure the effectiveness and distribution
of their services and messages, and understand how people interact with them on our
Services.
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g)
Information You and We Share
You share your information as you use and communicate through our Services, and we
share your information to help us operate, provide, improve, understand, customize,
support, and market our Services.
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
Your phone number, profile information, and receipts may be available to anyone who is
in a group and uses our Services, although you can configure your Services settings to
manage certain information available to other users and businesses with whom you
communicate.
j)
Your Contacts and Others
Users and businesses with whom you communicate may store or reshare your information
(including your phone number or messages) with others on and off our Services. You can
use your Services settings and the block feature in our Services to manage the users of our
Services with whom you communicate and certain information you share.
k)
Businesses on Equity Group
We help businesses who use Our Services measure the effectiveness and distribution of their
services and messages, and understand how people interact with them on our Services.
l)
Third-Party Service Providers
subsidiaries to help us operate, provide, improve, understand, customize, support, and
market our Services. When we share information with third-party service providers and
your information on our behalf in accordance with our instructions and terms.
m) Third-Party Services
When you use third-party services or Equity Group and its Subsidiaries Products that are
integrated with our Services, they may receive information about what you share with them.
For example, if you use a data backup service integrated with our Services (like iCloud or
Google Drive), they will receive information you share with them. If you interact with a third-
party service linked through our Services, you may be providing information directly to such
third party. Please note that when you use third-party services or Equity Group and its
Subsidiaries Products, their own terms and privacy policies will govern your use of those
services. Below is further use and information table:-
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How we use your information
Legal basis
Where necessary for the performance of our
agreement or to take steps to enter into an
agreement with you
Where the law requires this
To provide and manage your account(s)
Where it's in our legitimate interests to ensure
and our relationship with you
that our customer accounts are well-
managed, so that our customers are
provided with a high standard of service, to
protect our business interests and the
interests of our customers
Where necessary for the performance of our
To give you statements and other
agreement or to take steps to enter into an
information about your account
or
our
agreement with you
relationship
Where the law requires this
Where necessary for the performance of our
agreement or to take steps to enter into an
agreement with you
Where the law requires this
Where it's in our legitimate interests to ensure
that complaints are investigated, for
To handle enquiries and complaints
example, so that our customers receive a
high standard of service and so that we can
prevent complaints from occurring in future
In the case of sensitive information, such as
medical information, where you have
agreed
Where necessary for the performance of our
agreement or to take steps to enter into an
To provide our services to you
agreement with you
Where the law requires this
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For assessment, testing (including systems
tests) and analysis (including credit and/ or
behaviour scoring), statistical, market and
Where the law requires this
product analysis and market research. [We
Where it's in our legitimate interests to
may use this information to prepare
develop, build, implement and run business
statistical reports to be shared internally or
models and systems which protect our
with our group companies. We compile
business interests and provide our customers
these reports from information about you
with a high standard of service
and our other customers. The information in
these reports is never personal and you will
never be identifiable from them].
Where it’s in our legitimate interests
continually to evaluate, develop or improve
To evaluate, develop and improve our
our products as well as the experiences of
services to you and other customers
users of our sites, so that our customers are
provided with a high standard of service
Where it's in our legitimate interests to
protect our people, business and property
and to develop our strategies
Where necessary for the performance of our
agreement or to take steps to enter into an
To protect our business interests and to
agreement with you
develop our business strategies
Where the law requires this
In the case of sensitive information, such as
medical information, where you have
agreed
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To contact you, by post, phone, text, email
Where the law requires this
and other digital methods. This may be:
Where we have agreed to contact you in
to help you manage your accounts
our agreement
to meet our regulatory obligations
Where the law requires this
to keep you informed about
Where you agree
products and services you hold with
us and to send you information
Where it’s in our legitimate interests to share
about products or services
information with our customers about
products / services that may be relevant and
(including
those
of
other
companies)
which may be of
beneficial to them. Where we send you
interest to you.
marketing messages, you can always tell us
when you no longer wish to receive them.
Please see more information in the Contact
Us section
Where it's in our legitimate interests to collect
any debts owing to us
To collect any debts owing to us
In the case of sensitive information, such as
medical information, where you have
agreed
Where the law requires this
To meet our regulatory compliance and
Where it's in our legitimate interests to
reporting obligations and to prevent,
prevent and investigate fraud, money
detect, investigate and prosecute fraud
laundering and other crimes
and alleged fraud, money laundering and
other crimes. We may record your image on
Where such processing is a contractual
CCTV when you visit our premises.
requirement of the services or financing you
have requested
Where you have made data public
Where such actions are in our legitimate
interests, for the protection of our business
To assess any application you make,
interests
including carrying out fraud, money
laundering, identity, sanctions screening
Where the law requires this
and any other regulatory checks.
In the case of sensitive information, such as
medical information, where you have
agreed
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Where it’s in our legitimate interests, to check
your instructions to us, to prevent and detect
fraud and other crime, to analyse, assess
and improve our services to customers, and
To monitor, record and analyse any
for training, for the enhancement of our
communications between you and us,
customer service provision and protection of
including phone calls
our business interests
In the case of sensitive information, such as
medical information, where you have
agreed
To transfer your information to or share it with
Where necessary for the performance of our
any third party to whom your account has
agreement with you
been or may be transferred following a
Where we have a legitimate interest in
restructure, sale or acquisition of any group
restructuring or selling part of our business
company
Where the law requires this
Where we have a legitimate interest in
performing certain credit checks so that we
can make responsible business decisions. As
a responsible organisation, we need to
ensure that we only provide certain products
to companies and individuals where the
products are appropriate, and that we
continue to manage the services we
To share your information with UK or other
provide, for example if we consider that you
relevant tax authorities, credit reference
may have difficulties making a payment to
agencies, fraud prevention agencies, and
us.
UK and overseas regulators and authorities
Where we have a legitimate interest in
assisting with the prevention and detection
of fraud and other crime
Where we have a legitimate interest in
assisting UK and overseas regulators, who
monitor banks to ensure that they comply
the law and regulations
More detail on our data sharing with these
organisations is set out below
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Where necessary for the performance of our
agreement
To share your information with our partners
Where we have a legitimate interest in using
and service providers
third parties to provide some services for us
or on our behalf
8. AUTOMATED DECISION MAKING
If you apply to us for a product, your application may be processed by an automated decision-
making process which may carry out credit and affordability assessment checks to determine
whether your application will be accepted. Where these automated processes suggest that your
application should be rejected, we will manually review your application before making a final
decision. We may also use automated processes to decide credit limits.
We may also carry out automated anti-money laundering and sanctions checks. This means that
we may automatically decide that you pose a fraud or money laundering risk if the processing
reveals your behaviour to be consistent with that of known fraudsters or money launderers, is
inconsistent with your previous submissions, or you appear to have deliberately hidden your true
identity.
If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk: (i)
we may refuse to provide the services you have requested, or we may stop providing existing
services to you; and (ii) a record of any fraud or money laundering risk will be retained by the fraud
prevention agencies, and may result in others refusing to provide services or employment to you.
If you have any questions about this, please contact us on the details set out below.
9. INFORMATION SHARING
We keep all your personal data confidential. However, in order to be able to service your needs
to the best of our ability, we may share any information you provide to us with our group
companies and their agents, counterparties and support service or data providers, wherever
located. If you have provided information to other members of our group, those entities may also
share that information with us. We will ensure that if we share such information with third parties,
any such disclosure is at all times in compliance with Data Protection Legislation.
To help us provide services, your data will be processed internally and externally by other third
parties. We use third parties for [administrative, servicing, monitoring and storage of your data].
We will outsource some services to third parties whom we consider capable of performing the
required processing activities so that there is no reduction in the service standard provided to you
by us.
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The recipients or categories of recipients, of your information may be:
Any revenue service or tax authority including to HMRC, if obliged to do so under
applicable regulations. For Common Reporting Standards and FATCA, we may also have
to report your account(s) to the necessary tax authorities.
UK and overseas regulators and authorities in connection with their duties (such as crime
prevention).
Anyone to whom we may transfer our rights and/or obligations;
Any other person or organisation after a restructure, sale or acquisition, as long as that
person uses your information for the same purposes as it was originally given to us or used
by us (or both).
Credit reference, identity and address verification organisations who may record and use
your information and disclose it to other lenders, financial services organizations and
insurers. Your information may be used by those third parties to make assessments in
relation to your creditworthiness for debt tracing.
Fraud prevention agencies and law enforcement agencies who will use it to prevent fraud
and money-laundering and to verify your identity if false or inaccurate information is
provided by you and fraud is identified. We, fraud prevention agencies and law
enforcement agencies may access and use your information for example, when:
Checking details on applications for credit and credit related or other facilities;
Managing credit and credit related accounts or facilities;
Recovering debt;
Checking details on proposals and claims for all types of insurance.
Fraud prevention agencies can hold your personal data for different periods of time. If they’re
concerned about a possible fraud or money laundering risk, your data can be held by them for
up to six years or as required by law.
10. RETENTION AND DISPOSAL OF DATA AND OUTPUT
We will only keep the information we collect about you on our systems or with third parties for
as long as required for the purposes set out above or as required to comply with any legal
obligations to which we are subject. This will involve us regularly reviewing our files to check
that information is accurate and up-to-date and still required.
We will normally destroy or erase data after statutory timelines lapse. However, we may retain
your information, or information relating to your account after you cease to be a customer for
longer than this, provided it is necessary for a legal, regulatory, fraud prevention or other
legitimate business purpose.
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11.
HOW WE WORK WITH OTHER EQUITY GROUP HOLDINGS PLC AND IT’S SUBSIDIARIES
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.
12.
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.
13.
HOW THE GENERAL DATA PROTECTION REGULATION AND DATA PROTECTION ACT, 2019 (laws of
Kenya) APPLIES TO OUR CUSTOMERS
a) Our Legal Bases For Processing Information
We collect, use and share the information we have as described above:
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.
14.
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
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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://EquityGroup.africa/privacy. 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.
15.
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.
16.
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.
17.
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.
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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.
18.
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.
19.
CONTACT INFORMATION
If you are in the Kenya region;
The Data Protection Officer for Equity Group can be contacted at support@EquityGroup.africa.
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 or Kenya region;
or write us here:
Equity Group Holdings Plc
9th Floor, Equity Centre
Hospital Road, Upper Hill
Nairobi, Kenya
P.O. Box 75104-00200
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20.
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") and Data Protection Act, 2019 (Kenyan laws) as modified and
amended from time to time.
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, KENYA 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 and the Data Protection Act. To
exercise your rights, visit How You Exercise Your Rights section of the Privacy Policy.
The other legal bases we rely on in certain instances when processing your data are:
a) Your Consent:
For collecting and using information you allow us to receive through the device-based
settings when you enable them (such as access to your GPS location, camera, or photos),
so we can provide the features and services described when you enable the settings. When
we process data you provide to us based on your consent, you have the right to withdraw
your consent at any time and to port that data you provide to us, under the GDPR and
Data Protection Act. To exercise your rights, visit your device-based settings, your in app-
based settings like your in-app location control, and the How You Exercise Your
Rights section of the Privacy Policy.
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"):
For people under the age of majority (under 18, in most EU countries and Kenya) who have
a limited ability to enter into an enforceable contract only, we may be unable to process
personal data on the grounds of contractual necessity. Nevertheless, when such a person
uses our Services, it is in our 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:
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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
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:
For providing measurement, analytics, and other business services where we are processing
data as a controller. The legitimate interests we rely on for this processing are:
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 share information with others including law enforcement and to respond to legal
requests. See our Privacy Policy under Law and Protection for more information. The
legitimate interests we rely on for this processing are:
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
You have the right to object to, and seek restriction of, such processing; to exercise
your rights, visit How 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.
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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:
For processing data when the law requires it, including, for example, if there is a valid legal
request for certain data.
g) Protection of your vital interests or those of another person:
The vital interests we rely on for this processing include protection of your life or physical
integrity or that of others, and we rely on it to combat harmful conduct and promote safety
and security, for example, when we are investigating reports of harmful conduct or when
someone needs help.
h) Tasks carried out in the public interest:
For undertaking research and to promote safety and security, as described in more detail
in our Privacy Policy under How We Use Information, where this is necessary in the public
interest as laid down by European Union law or Member State law to which we are subject.
When we process your data as necessary for a task carried out in the public interest, you
have the right to object to, and seek restriction of, our processing. In evaluating an
objection, we'll evaluate several factors, including: reasonable user expectations; the
benefits and risks to you and 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.
21.
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.
21.1 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
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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.
21.2 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
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;
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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.
22.
COOKIES
22.1 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.
22.2 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.
22.3 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.
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23. DETAILS OF DATA TRANSFERS OUTSIDE THE EEA AND KENYA
Information about you in our possession may be transferred to other countries outside the
European Economic Area and Kenya (particularly to our parent company in Kenya) for any
of the purposes described in this Privacy Notice.
You and they understand and accept that these countries may have differing (and potentially
less stringent) laws relating to the degree of confidentiality afforded to the information it holds
and that such information can become subject to the laws and disclosure requirements of
such countries, including disclosure to governmental bodies, regulatory agencies and private
persons, as a result of applicable governmental or regulatory inquiry, court order or other
similar process. In addition, a number of countries have agreements with other countries
providing for exchange of information for law enforcement, tax and other purposes.
When we, or our permitted third parties, transfer information outside the European Economic
Area and Kenya, we or they will impose contractual obligations on the recipients of that data
to protect such information to the standard required in the European Economic Area and
Kenya . We or they may require the recipient to subscribe to international frameworks intended
to enable secure data sharing. In the case of transfers by us, we may also transfer your
information where the transfer is to a country deemed to provide adequate protection of your
information by the European Commission or Data Commissioner or you have consented to the
transfer.
If we transfer your information outside the European Economic Area and Kenya in other
circumstances (for example because we have to provide such information by law), we will
use best endeavours to put in place appropriate safeguards to ensure that your information
remains adequately protected.
24.
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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