Team Investment Concept (Ikigai Nairobi) 
Privacy Policy 

 

This privacy statement informs you about how we process your Personal Data. We may ask you – throughout our website and member platform to share certain personal data with us, including but not restricted to your name, surname, phone number and email address (identification data). For certain specific obligations, you may need to provide additional data, for example company name. 

We only collect Personal Data that is necessary to inform you of our offerings and services, to carry out an agreement with you and to be in contact with you. In order to do so, we base ourselves on the agreement’s grounds for processing, the legal obligations, our legitimate interest and in some cases, your permission (see also article 2). You can also subscribe to the Ikigai Nairobi Newsletter. 

The processing of your Personal Data is subjected to this privacy statement. For questions and/or comments, please write to admin@ikigai.co.ke. By providing your Personal Data, you are considered to have acknowledged the use of your Personal Data in accordance with this privacy statement. 

Last Modified on 03 March 2020. 

Article 1: Definitions

“Act” means the Data Protection Act, (Act No 24 of 2019), Laws of Kenya 

“Data Controller” has the meaning as defined in the Act. Ikigai Nairobi will be qualified as the Data Controller which determines the purposes and processes of the processing of your Personal data. 

“Data Processor” has the meaning as defined in the Act, which processes the Personal data on behalf of and under orders of the Controller. 

“Ikigai Nairobi” refers to Team Investment Concept Limited a limited liability company incorporated in the Republic of Kenya whose address is care of Post Office Box Number 1093-00606, Nairobi within the Republic of Kenya. 

“Member Platform” refers to the software application used by Ikigai Nairobi to communicate and provide service to its clients. 

“Personal Data” has the meaning as defined in the Act, including any information that allows a natural person (also data subject) to be identified or with which a natural person can be identified. 

“Website” means the website of Ikigai Nairobi: www.ikigai.co.ke and www.ikigainairobi.com and www.roastedtruth.com 

Article 2: Processing Purposes and Legal Ground

Customer Data 

As part of our services and activities, we collect and process the Personal Data of our customers and clients, their personnel, workers, agents and other useful contacts. The purposes for these processing operations are the performance of agreements with our customers, customer management, accounting and direct marketing activities such as sending promotional or commercial information. The legal grounds are the performance of the agreement, the compliance with legal and regulatory obligations, our legitimate interest and in some cases permission. 

Data of Suppliers and Contractors 

We collect and process the identity and contact data of our suppliers and subcontractors, as well as their (sub)subcontractors, personnel, workers, agents and other useful contacts. The purposes of these processing operations are the performance of the agreement, the management of the suppliers/subcontractors, accounting and direct marketing activities such as sending promotional or commercial information. The legal grounds are the performance of the agreement, the compliance with legal and regulatory obligations and/or our legitimate interest (such as for direct marketing). 

Other Data 

In addition to the data of customers, suppliers/subcontractors and personnel we also process Personal Data of others, such as potential new customers/prospective customers, useful contacts in our sector, network contacts, contacts of experts, etc. This is via our Website or via other channels, which shall include but not be limited to Social Media, events, referrals from clients. The purposes of these processing operations are in the interest of our activities, direct marketing and public relations. The legal ground is our legitimate interest, the performance of an agreement and/or in some cases permission. 

Specifically, we may use the personal data we collect for the following purpose: 

  • To identify you as a user of the website or Member Platform; 
  • To provide information to you regarding our projects, products and services; 
  • To provide our services to you and perform possible agreements; 
  • To process and treat possible complaints or requests; 
  • To help us evaluate, correct or improve the Website or Member Platform and all related products or services of Ikigai Nairobi; 
  • For direct marketing purposes; 
  • For internal reasons, including business administration and archiving purposes. 

Article 3: Confidentiality of  Your Personal Data

Every time you, as a user of the Website, Member Platform or in any other way, provide Personal data to us, we will treat this information in accordance with the provisions of this privacy statement and the legal obligations in connection with the processing and storing of Personal Data, under the Act. 

We implement internationally acceptable measures and procedures to secure and protect the Personal Data we collect through the website, Member Platform, or via (electronic) correspondence. 

In this way we undertake, as far as can reasonably be expected, to prevent any illegal processing of Personal Data and unintentional loss or destruction of your Personal Data. Despite these precautions, we cannot guarantee that your Personal Data will be protected if it is forwarded outside the Website or Member Platform in an unsecured manner through other channels or otherwise communicated. 

We try to optimize the security of your Personal Data by limiting access to your Personal data to individuals on a “need-to-know” basis (for example only employees, workers or subcontractors who need your Personal Data for the purposes described in Article 2 will be able to access the data). Upon reasonable request, we may provide you with the names of such subcontractors. 

Article 4: How Does Ikigai Nairobi Collect Your Personal Data and How Long is it Saved?

We collect your Personal Data in the following cases – non exhaustive: 

  • When sending a request for information on the website (via the contact form); 
  • When booking a meeting room on the website (using the designated form); 
  • When booking an event space on the website (using the designated form); 
  • When your picture is taken at an Ikigai Nairobi location; 
  • When booking a tour on the website (using the designated form); 
  • When you reach a contract (of employment) with us; 
  • If you call, mail or correspond with us in any other way other than via the website or Member Platform; 
  • When signing up for a service or membership (using the member platform); 
  • When visiting a member at a location (using the designated visitor registration system) 

We can combine the Personal Data we collect with information you provide to us in another way or which third parties provide to us. 

We save and process Personal Data for a period that is necessary to fulfil the purposes of the processing and to fulfil the (possibly contractual) relationship between the company and you. 

Customer data and data of suppliers or subcontractors will in any case be deleted from our systems after a period of 5000 365 days following the termination of the agreement or project, with the exception of Personal Data that we are required to save for a longer period following specific legislation or in the event of an ongoing dispute for which the Personal Data is still necessary. 

 

Data collected via a form on our Website or via another channel which shall include but not be limited to Social Media, events, referrals from clients, is not saved for longer than a period of that we shall deem necessary in the circumstances after the last time there was a meaningful contact with you. 

Personal Data of personnel is removed after a period which we shall deem necessary and reasonable in the circumstances. 

We avoid the collection of Personal Data that is not relevant for the purposes set out in Article 2. 

Article 5: Transfer of Personal Data

There may be circumstances where we will be required to transfer your Personal Data to third parties in and outside of Kenya. By accepting the terms in this agreement, you consent to us transferring your Personal Data where we deem it necessary or appropriate, subject to the conditions set out in this Article 5. 

Where we deem it necessary or appropriate to transfer your Personal Data, we will ensure that the transfer of and receipt of your Personal Data will be done with the implementation of internationally acceptable measures and procedures to secure and protect your Personal Data. 

Any transfer of Personal Data to a recipient as listed above is in accordance with the provisions of the Act. 

We shall ensure that measures are adopted so that the recipients cannot use this Personal Data for purposes other than those listed exhaustively in Article 2 and also, that the recipients have taken sufficient technical and organizational measures to protect these data. 

To guarantee the security of Personal Data, we will always reach a processor agreement with the aforementioned recipients of this Personal Data. We will take all necessary precautions to ensure that employees and workers who have access to Personal Data process this exclusively in accordance with this privacy statement and the legal obligations under the Act. 

Article 6: Rights of the Data Subject

Right of Access to Personal Data 

You have the right to instruct us to disclose any Personal Data that we hold about you, provided that the rights of other data subjects are not affected. 

Right to Rectify Personal Data 

We kindly ask you to ensure that the Personal Data in our database is as accurate and complete as possible. If you believe that the data provided to us is incorrect or incomplete, please inform us as described above. Your Personal Data will be corrected or supplemented as soon as possible. 

Right to Erase Personal Data 

You have the right to delete your Personal Data without undue delay in the following cases: 

  • If it is no longer necessary to retain the Personal Data for the purposes for which it was collected or otherwise processed; 
  • In the event of withdrawal of consent for permission-based processing; 
  • Processing intended for direct marketing; and 
  • If the Personal Data was unlawfully processed. 

However, there are certain general exclusions to the right to erase. These general exclusions comprise the cases where processing is necessary: 

  • For exercising the right of freedom of expression and information. 
  • For compliance with a legal obligation. or 
  • For the establishment, exercise or defense of legal claims. 
Right to Limit the Processing of Data 

In the following cases you have the right to limit the processing of your Personal data: 

  • To dispute the correctness of your Personal Data; 
  • When the processing is unlawful, but you do not want the Personal Data to be erased; or 
  • If you object to the processing of your Personal Data, and verification of that objection is pending. 

If processing is restricted on this basis, we may continue to store your Personal Data. However, we will only process the data with your express consent to institute, exercise or defend legal claims, to protect the rights of another natural or legal person or for reasons of substantial public interest. 

Right to Object 

You have the right to object to our processing of your Personal Data. 

Right of Data Portability 

If you wish to exercise your right of data portability, we will transfer the Personal Data in a structured, common and machine-readable form to a data controller of your choice. 

Right to Withdraw Consent 

To the extent that the legal basis for our processing of your Personal Data is your consent, you have the right to withdraw your consent at any time. However, such withdrawal shall not affect the lawfulness of the processing that took place before the withdrawal. 

Article 7: Referral to Third Parties

The Website or Member Platform may contain links to other websites that are not managed by us. While we do our utmost to ensure that links only lead to websites that have corresponding security and confidentiality standards, we are in no way responsible for the protection and confidentiality of Personal Data, including the data you provide on other websites, after you leave the Website. 

We reiterate that you must work carefully and always consult the privacy statement that applies to the website in question before providing Personal Data on other websites. 

Article 8: Cookies Article 8: Cookies

Ikigai Nairobi uses “cookies” every time you use the Website or Member Platform. A “cookie” is information sent to your device via the server and is stored on the device’s hard disk. Cookies help Ikigai Nairobi to recognize your device when you use the Website or Member Platform. It allows Ikigai Nairobi to make the processing more user-friendly and to offer a personalized service. 

Google Tag Manager and Google Analytics (collectively referred to as “Google”): 

Google collects anonymous data (ad views, analytics, browser information, cookie data, date/time, demographic data, hardware/software type, internet service provider, interaction data, page views, and serving domains), pseudonymous data (IP Address (EU PII), Device ID (EU PII), PII (name, address, phone number, email address, login, EU- IP address, EU-unique device ID), sensitive (financial information). Aggregate data, anonymous data, PII data and sensitive data is shared by Google with third-party parties. We use the information we get from Google only to improve this website and for marketing purposes. Google collects only the IP address assigned to you on the date you visit this website, rather than your name or other identifying information. You can review Google’s privacy policy at https://www.google.com/policies/privacy/. 

Although Google plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this website, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google about your visits to this website is restricted by the Google Terms of Use and the Google Privacy Policy. You can prevent Google from recognizing you on return visits to the website by disabling cookies on your browser (see below). 

GA Audiences and Double Click 

Google operates GA Audiences, which collects anonymous data (ad views, analytics, browser information, cookie data, date/time, demographic data, hardware/software type, internet service provider, interaction data, page views, and serving domains), pseudonymous data (IP Address (EU PII), search history, location based data, and Device ID), and PII (name, address, phone number, email address, login, EU- IP address, and EU-unique device ID). GA Audience’s privacy policy can be found at: http://www.google.com/intl/en/policies/privacy/. We do not combine the information collected through GA Audience with personally identifiable information. 

Facebook Custom Audience 

Facebook Custom Audience, operated by Facebook Business (formerly Facebook Custom Audience), collects anonymous data (ad views, analytics, browser information, cookie data, date/time, demographic data, hardware/software type, internet service provider, interaction data, page views, and serving domains), pseudonymous data (IP Address (EU PII), search history, location based data, Clickstream Data, PII (name , address, phone number, email address, login, EU- IP address, EU-unique 

device ID ), sensitive (financial information). Facebook Custom Audience’s privacy policy can be found at: https://www.facebook.com/full_data_use_policy. Facebook Custom Audience shares data with third parties (specifics are undisclosed). 

Facebook for Developers (formerly “Facebook Connect”) 

Facebook for Developers operates Facebook Connect, which collects anonymous data (ad views, analytics, browser information, cookie data, date/time, demographic data, hardware/software type, internet service provider, interaction data, page views, and serving domains), pseudonymous data (IP Address (EU PII), search history, location based data, Clickstream Data, PII (name , address, phone number, email address, login, EU- IP address, EU-unique device ID ), sensitive (financial information). Facebook for Developers’ privacy policy can be found at: https://www.facebook.com/about/privacy/. Aggregate data is shared by Facebook for Developers with third parties. Facebook for Developers also shares anonymous data with third parties. Facebook for Developers shares PII data with third parties. Facebook for Developers also shares sensitive data with third parties. We do not combine the information collected through Facebook for Developers with personally identifiable information. 

Analytics, LinkedIn Ads and LinkedIn Marketing Solutions (collectively, “LinkedIn Analytics”) 

LinkedIn Analytics collects anonymous data (ad views, analytics, browser information, cookie data, hardware/software type, internet service provider, interaction data, page views, and serving domains), pseudonymous data (IP Address (EU PII)), Location Based Data, Device ID (EU PII), and PII (name, address, phone number, email address, login). Aggregate and anonymous data is shared by LinkedIn with third-party parties. LinkedIn’s privacy policy for LinkedIn Ads and LinkedIn Analytics can be found at: https://www.linkedin.com/legal/privacy-policy. 

Microsoft Bookings: 

Microsoft Bookings collects information from you that you provide directly through our contact forms and it automatically collects data through your use of our contact forms. Microsoft Bookings automatically collects anonymous data (device type, browser information, page views, serving domain, Device ID, IP Address, mobile network carrier, timezone, and location). Microsoft’s privacy policy can be found at: https://privacy.microsoft.com/en-US/privacystatement 

Hotjar: 

We use Hotjar to anonymously track and record sessions. These sessions are not associated with any specific user. Hotjar cookies are stored in your browser and will expire automatically after 365 days. If cookies are disabled, Hotjar does not track or record visits. 

Some browsers may allow you to manage the storage of cookies on your device. If supported by your browser, you may set your browser to refuse all cookies (or, sometimes all third-party cookies) or to alert you when a cookie is set. However, if you select these settings, you may be unable to access certain parts of the Website. Unless you have adjusted Your browser setting to refuse cookies, the Website will issue cookies. 

For more information about how to manage your cookies preferences, use the ‘help’ menu of Your web browser or explore the customer support sections of your web browser. To opt-out of all cookies or certain advertising cookies, visit the company website for your browser for instructions. 

Article 9: Exemptions from the Privacy Policy

Our Privacy Policy does not apply to any none Personal Data you may send to Ikigai Nairobi by email or instant messaging programs (e.g., Google My Business), or through social media networks, even if you open such programs or services by clicking a link displayed on the Website. Email, social media, and instant messages are not recognized as secure communication forms. 

Article 10: Changes to this Privacy Policy

We reserve the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the Ikigai Nairobi website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use/disclose it. 

Contacting Us

If there are any questions regarding this privacy policy, you may contact us using the information below. 

www.ikigai.co.ke 

P.O. Box 1093-00606 

Nairobi, Kenya 00606 

admin@ikigai.co.ke