Data Protection Policy

Data Protection Policy

Last updated: 16 October, 2023

Your privacy is important to us. This Privacy Notice (the “Policy”) explains the personal data Car Club Kenya Limited collects, how Car Club Kenya processes it, and for what purposes. This statement applies to all customers, suppliers, and all visitors to Car Club Kenya premises. Personal data in this context means information relating to an identified or identifiable natural person.

We advise you to read the Notice in its entirety.

Collection of Personal Information

We collect or obtain Personal Information when you do any of the following (please note that this list is not exhaustive):

  • Buy or use a product or service from an Car Club Kenya, on a mobile or other device, on our website, on our social media platforms;
  • Obtain a quote for Car Club Kenya products or services from an Car Club Kenya retail shop, on a mobile or other device, on our website, on our social media platforms;
  • Register for a business account with Car Club Kenya (e.g., SME, fleet, garage, corporate, dealer accounts)
  • Respond to or participate in a survey, marketing promotion, prize competition or special offer;
  • Ask Car Club Kenya for more information about a product or service or contact Car Club Kenya with a query or complaint on any of our channels (e.g., email, social media, call, in branch)
  • Visit, access or use the Car Club Kenya website
  • Download, register, access or use the Car Club Kenya mobile app
  • We may collect your information when you interact with us as a supplier as prescribed in this statement;
  • Visit our premises

We do not collect personal data from minors (any person under 18 years of age) as our services are for those who are licenced to own vehicles, and thus must be 18 years of age or older. If you have reason to believe that a child has provided personal data to us, please contact us and we will endeavour to delete that information from our databases.

Categories of Personal Data we collect

The Personal Data we collect and store about you includes but is not limited to the following:

  • Personal details:given name(s); preferred name, other biographical details
  • Contact details:email addresses, telephone numbers, social media details, other contact or address details
  • Vehicle details: car registration, VIN number, and other information about your vehicle
  • Transaction details: records of the products and services you purchase, amount paid, payment method used, where you made the purchase, time and date of purchase
  • Information relating to contacting Car Club Kenya(e.g., call us, interact with us through social media, use our chat bot, email, SMS, respond to survey): We may record your conversations, social media, email, SMS, survey or other interactions with us
  • Information relating to use of Car Club Kenya Wi-Fi in: We record the device address and also log traffic information in the form of sites visited, duration and date sent/received
  • Information relating to delivery and pick up & drop off services: When you request us to deliver a product to you (e.g., deliver and fit a battery), or drop-off your car to you, we will collect information required to fulfil this request. This information includes but is not limited to: Your name, phone number, email address, physical address for the delivery and/or drop-off, payment method
  • Information relating to business accounts:We may need to collect personal information from representatives and/or shareholders relating to the business account
  • Information relating to our Sites and Apps:device type; operating system; browser type; browser settings; IP address; language settings; internet service provider; mobile provider; dates and times of connecting to a Site; App usage statistics; App settings; dates and times of connecting to an App; location data, and other information (some of which may constitute Personal Information); usage data; aggregate statistical information

 

Use of Personal Information

We use the personal data we collect to provide, maintain, and improve the services we offer. We also use it to:

  • The end user’s personal info will not be shared or sold to third parties for the purpose of marketing
  • Send you technical notices, general updates, goodwill messages, security alerts, and support and administrative messages (such as changes to our terms, conditions, and policies) and to respond to your comments, questions, and customer service requests;
  • Receive and respond to your submissions on the Services such as submissions on the Car Club Kenya website, web applications and mobile applications, social media and submissions to Customer Service Contacts;
  • Communicate with you about products, services, events, and special offers from Car Club Kenya and others, and provide news and information we think will be of interest to you;
  • Monitor and analyse trends, usage, and activities in connection with our Services;
  • Update our product and service offering, and enhance our current product and service offering;
  • Detect, investigate, and prevent fraudulent transactions and other illegal activities, and protect the rights and property of Car Club Kenya and others;
  • Comply with any legal, governmental or regulatory requirement or for internal use in connection with any legal proceedings; and
  • Carry out any other purpose described to you at the time of collecting information

Lawful basis for processing

We will process your personal information based on any of the lawful basis provided for under the Data Protection Action 2019:

  • The Processing is necessary in connection with any product/service agreement that you have entered into with us; or
  • We have a legitimate interest in carrying out the Processing; or
  • The Processing is necessary for compliance with a legal obligation; or
  • We have obtained your prior consent to the Processing; or
  • The Processing is necessary to protect the vital interests of any individual; or
  • The Processing is in the public interest

Retention of Personal Data

We take every reasonable step to ensure that your Personal Information is only processed for the minimum period necessary for the purposes set out in this Policy. The criteria for determining the duration for which we will retain your Personal Information is as follows:

  • We will retain Personal Information only for as long as:
    • This data helps us provide services to you and your vehicle. We will consider this until you have notified us that you and your vehicle are no longer present in Kenya;
  • PLUS the duration of:
    • Any period we are required to hold you data for legal, regulatory, or tax requirements; or
    • Any period during which any person could bring a legal claim against us in connection with your Personal Information, or to which your Personal Information is relevant

How personal data is shared

We may share your personal data as follows or as otherwise described in this Notice:

With our data processors that host, maintain, manage, or provide other services to us in relation to providing, maintaining and improving our services;

To co-operate with public and government authorities and law enforcement, or to provide information in accordance to existing laws;

For other legal reasons, such as to monitor compliance with and enforce our terms and conditions, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, to protect against criminal activities, and for risk management purposes; and

In connection with a sale or business transaction, such as to an acquiring entity or its advisors in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings)

If we engage a third-party Processor to Process your Personal Information in accordance with (1), (3), or (4) above, the Processor will be subject to binding contractual obligations in accordance with section 24 of the Data Protection Regulations 2021.

We may also share aggregated pseudonymised or anonymised information that cannot reasonably be used to identify you.

We do not share personal information outside the Republic of Kenya. If this is required in future, we will make sure that your information is properly protected in accordance with the applicable Data Protection Laws.

Control Your Privacy & Data

Marketing emails and alerts

If you no longer want to receive marketing-related emails and alerts from Car Club Kenya, you may opt out/ unsubscribe by following the instructions contained within each such message or through the Car Club Kenya contact centre. We will endeavour to comply with your request as soon as is reasonably practicable.

Please note that if you opt-out of receiving marketing-related emails and alerts, we may still send you administrative messages, from which you cannot opt out or unsubscribe.

The Use of Cookies

We may store some information (using “cookies”) on your computer when you visit our websites. This enables us to recognise you during subsequent visits. The type of information gathered is non-personal (such as: the Internet Protocol (IP) address of your computer, the date and time of your visit, which pages you browsed and whether the pages have been delivered successfully.

We may also use this data in aggregate form to develop customised services – tailored to your individual interests and needs. Should you choose to do so, it is possible (depending on the browser you are using), to be prompted before accepting any cookies, or to prevent your browser from accepting any cookies at all. Please note that if you choose to remove or reject cookies, this could affect the functionality of our website.

Access to and Updating your Information

To access and/or update your information you can log-in to our mobile app at any time

The Use of Hyperlinks

Our websites may provide hyperlinks to other locations or websites on the Internet.

Please note that Car Club Kenya is not responsible for the privacy or information security practices of other websites. You should carefully review the applicable privacy and information security policies and notices for any other websites you click through from our websites.

We do not endorse, recommend, approve or guarantee any third- party products and services by providing hyperlinks to an external website or webpage and do not have any co-operation with such third parties unless otherwise disclosed. We are not in any way responsible for the content of any externally linked website or webpage.

Security

We seek to use appropriate technical and organizational measures to safeguard personal data within our organization against loss, theft, breach, and unauthorized use, disclosure, or modification.

Your rights

Subject to legal and contractual exceptions, you have rights under data protection laws in relation to your personal data. These are listed below:

  • Right to be informed that we are collecting personal data about you;
  • Right to access personal data that we hold about you and request for information about how we process it;
  • Right to request that we correct your personal data where it is inaccurate or incomplete;
  • Right to request that we erase your personal data noting that we may continue to retain your information if obligated by the law or entitled to do so;
  • Right to object and withdraw your consent to processing of your personal data. We may continue to process if we have a legitimate or legal reason to do so;
  • Right to request restricted processing of your personal data noting that we may be entitled or legally obligated to continue processing your data and refuse your request;
  • Right to request transfer of your personal data

If you wish to exercise any of the rights set out above, please contact us on [email protected].

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within timelines set forth in the Data Protection Regulations 2021.

Occasionally it could take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Contact us

If you have any other questions concerning this Notice, please contact us as per the below:

Right to lodge complaint

You have the right to lodge a complaint with the relevant supervisory authority that is tasked with personal data protection within the Republic of Kenya

Changes to this notice

From time to time, we may revise this Notice. Changes may be made for any number of reasons, including to reflect industry initiatives, changes in the law, and changes to the scope of the Services, among other reasons. You can tell when we last updated the Notice by checking the date at the beginning of the Notice. Any changes will become effective when we post the revised Notice on the Services.

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