Privacy Policy

We respect your privacy and are committed to protecting your personal information. This privacy policy (“Policy”) applies to your use of Thelinks.co.ke (referred to as the “Site” or Sites” depending on the context). This Policy sets out how we collect, store, guard, share and use any personal data that we may collect from you when you use or otherwise interact with the Platform or the services offered through our Sites. The Policy and our treatment of your personal data comply with the Data Protection Act of Kenya 2019 (as otherwise amended or varied from time to time).
Please review this Policy carefully to understand our practices.
This Site is not intended for children (i.e. under 18 years) and we do not knowingly collect data relating to children.

TERMS

For ease of reference, the terms below as used in the Policy have the following meaning:
Account means the account you create when registering as a user on the Site to enable you to access some of the Services.
Group means any other business of Ringier One Africa Media Ltd operating in Kenya or within the Ringier companies worldwide.
Personal data means information relating to you and which can identify you as an individual (whether on its own or taken with other information). It does not include aggregated or anonymized data, which is information that can no longer identify you.
Services means such services made available, accessed, published, or otherwise offered through the Site.

DATA CONTROLLER:

Thelinks.co.ke is the data controller and responsible for your personal data (referred to as “we”, “us” or “our” in this Policy). If you have any questions about this Policy please send an email to privacy@thelinks.co.ke

DATA COLLECTED

Depending on the Services you are obtaining or accessing, we may collect, store, use, and transfer the following different types of information:

  • Identity information such as your first name, maiden name, last name, username or similar identifier, marital status, title, nationality, date of birth, or gender.
  • Contact Information such as your billing address, delivery address, email address, and telephone numbers, the name of your business, and/or location.
  • Financial information such as bank account, payment card details, and/or monthly income. Details about monthly income are collected for users of Thelinks.co.ke only.
  • Verification information such as your government-issued national identification or passport, KRA PIN certificate, business permits, company incorporation certificates, and/or location.
  • Account information relating to the use of the Site including profile data such as your username, password, orders, interests, preferences, survey responses, and/or feedback.
  • Automatic information and information about your device including technical data (internet protocol (IP) address, login data, time zone setting, browser type, and version, location, browser plug-in types and versions, operating system and platform, and/or other technology on the devices you use to access the Site. Note that this automatic information and device information is used to screen for potential risks and fraud, to improve and optimize the Site, to ease access to the Site, and carry out upgrades, data analysis, and improve the quality of services. You can set your browser to refuse all or some browser cookies, but this will make parts of the Site inaccessible or inhibit functionality.
  • Marketing and communications data such as your preferences in receiving marketing from us and our third parties and your communication preferences.

    Please note that this is not an exhaustive list.

We may collect and use statistical or demographic information for any purpose. This data is anonymous and it is not personal information as this data will not directly or indirectly reveal your identity. However, if we combine or connect statistical/demographic information with your personal data, we treat the resulting information as personal data and it will be used in accordance with this privacy policy.

We do collect sensitive personal data about you. This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, information about your health, and genetic and biometric data. We also collect information about criminal convictions and offenses.

WHAT IF I DON’T WANT TO PROVIDE ANY PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
HOW DATA IS COLLECTED
We collect personal information:
  • That you provide to us directly for example through the Site, on the phone, or through any other communication channel or method.
  • We obtain it from other sources.
  • Using cookies, logs, web beacons, tags, pixels, and other internet technologies (used to record information about how you browse the Site), for example, the technical data.
ACCURACY OF THE DATA
It is important that the personal data we hold is accurate and current to enable us to deliver the Services. As such, please keep us informed if your personal data or any other information changes in the course of your use of the Site.
You guarantee and declare that you are the owner of the information you submit on the Site or share with us, or that you have the necessary rights to do so. You also guarantee and declare that it is exact, true and verified, and the use of the information is not contrary to this Policy or applicable laws and will not damage a third party’s reputation. You accept full and complete liability for any information that is contrary to this Policy or any applicable laws.
USE OF THE COLLECTED DATA
How we use your personal data depends on the Services you are accessing. We will use your personal data:
  • To provide you with the Services, in particular:
    • Connect you to a buyer or seller, as the case may be (Thelinks.co.ke).
    • Run targeted marketing campaigns (Thelinks.co.ke).
  • To contact you about the Services, events, and promotions (where you have agreed to us doing so).
  • To comply with our legal obligations.
  • To perform a task in the consideration of the greater public interest.
  • Where necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where personal data is required for statistical or research purposes.

Note: we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

SHARING YOUR PERSONAL DATA
Except as specified in this Policy, we will not disclose your personal data to third parties without your consent.

RETENTION OF DATA

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. Your personal data may be retained for a longer period where there has been a complaint or there is a prospect of litigation with respect to your use of the Site
CHANGES TO THE PRIVACY POLICY
We regularly review and update this Policy in order to reflect changes to our practices, for operational, legal or regulatory reasons, and for any other purpose. Any revisions to this Policy will be uploaded to the Site and such upload will be deemed to be sufficient communication to you. Where you are a registered user, we may elect, at our own discretion, to notify you of any revision through a notice on your account.
Last updated: [18-03-2022]