Team Investment Concept (Ikigai Nairobi)
Privacy Notice
Contents:
1. Contact details
2. What information we collect, use, and why.
3. Lawful bases and data protection rights.
4. Our lawful bases for the collection and use of your data.
5. Where we get personal information from.
6. How long we keep information.
7. Who we share information with.
8. Sharing information outside the Republic of Kenya.
9. How to contact us
Registered name:
Office of Data Protection Commissioner registration number: 06523
Team Investment Concept Limited
(Company Registration number: BN/2016/424535)
This privacy notice tells you what to expect us to do with your personal data.
P.O. Box 2016, Peponi Road Westlands, Nairobi, 00606, KENYA
Telephone: +254 797 519 466
Email: admin@ikigai.co.ke
2. What information we collect, use, and why
We collect or use the following information for the operation of members and clients’ accounts:
- Names and contact details
- Addresses
- Payment and Financial details
- Account information, including registration details
- Information used for security purposes
- Marketing preferences
We collect or use the following information for marketing purposes:
- Names and contact details
- Addresses
- Marketing preferences
- Recorded images, such as photos or videos
- Records of consent, where appropriate
- Social Media Accounts
We collect or use the following information to comply with legal requirements:
- Name
- Contact information
- Identification documents
- Financial transaction information
- Health and safety information
- Kenya Revenue Authority PIN number
We collect or use the following information for recruitment purposes:
- Contact details (eg name, address, telephone number or personal email address)
- Kenya Revenue Authority PIN number
- National identification or other photo ID
- Employment history (e.g., job application, employment references or secondary employment)
- Education history (e.g., qualifications)
- Right to work information
- Security clearance details (e.g. certificate of good conduct)
We collect or use the following personal information for dealing with queries, complaints or claims:
- Names and contact details
- Address
- Account Service history
- Customer or client accounts and records
- Financial transaction information
- Correspondence
We collect or use the following information to Identification, Know Your Client and Due Diligence (including Suppliers/Vendors):
- Names and contact details
- Purchase or account history
- Payment details (including card or bank information for transfers and direct debits)
- Marketing preferences
- Records of consent, where appropriate
3. Lawful bases and data protection rights
Under Data Protection Act, 2019, we must have a “lawful basis” for collecting and using your personal data. There is a list of possible lawful bases in the Data Protection Act, 2019.
Which lawful basis we rely on may affect your data protection rights which are in brief set out below.
- Your right of access – You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for.
- Your right to rectification – You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete.
- Your right to erasure – You have the right to ask us to delete your personal information.
- Your right to restriction of processing – You have the right to ask us to limit how we can use your personal information.
- Your right to object to processing – You have the right to object to the processing of your personal data.
- Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you.
- Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time.
- If you make a request, we must respond to you without undue delay and in any event within seven to thirty days.
4. Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information for the operation of members and clients’ accounts are:
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you.
- Legal obligation – we have to collect or use your information so we can comply with the law.
- Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone.
Our lawful bases for collecting or using personal information for marketing purposes are:
- Consent – we have permission from you after we gave you all the relevant information. To be clear, you do have the right to withdraw your consent at any time.
Our lawful bases for collecting or using personal information for legal requirements are:
- Legal obligation – we have to collect or use your information so we can comply with the law.
Our lawful bases for collecting or using personal information for recruitment purposes are:
- Consent – we have permission from you after we have given you all the relevant information.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you.
- Legitimate interests – we’re collecting or using your information because it benefits you, our organization or someone else, without causing an undue risk of harm to anyone.
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
- Legitimate interests – we’re collecting or using your information because it benefits you, our organization or someone else, without causing an undue risk of harm to anyone. Our legitimate interests are to ensure efficient communication and resolution of issues, thereby maintaining trust and satisfaction with our services. This process helps us improve our operations and address any potential risks or concerns proactively.
Our lawful bases for collecting or using personal information for Identification, Know Your Client and Due Diligence are:
- Legal obligation – we have to collect or use your information so we can comply with the law.
5. Where we get personal information from
- Directly from you
- CCTV footage or other recordings
- Publicly available sources
- Suppliers and service providers
6. How long we keep information
We are required under the Data Protection Legislation to keep your personal data only for specific period as lawfully required. Some of the considerations we take into account when deciding on the retention of your data is:
- Where it is stipulated under the law; and the necessary time your data is needed for us to deliver the service to you.
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
7. Who we share information with:
- Professional or legal advisors
- Relevant regulatory authorities
- External auditors or inspectors
- Internal departments for purposes of operations of our accounts.
8. Sharing information outside the Republic of Kenya
Where necessary, we may transfer personal information outside of the Republic of Kenya. When doing so, we comply with the Data Protection Act, 2019, making sure appropriate safeguards are in place.
If you have any concerns about our use of your personal data, you can contact us using the details at the top of this privacy notice.
If you remain unhappy with how we’ve used your data after contacting us, you can file a complaint to the Office of the Data Protection Commissioner of Kenya, Britam Towers, 12th Floor, P.O Box 30920-00100 G.P.O Nairobi, Kenya.
Last updated: 06/01/2025