IMPORTANT INFORMATION AND WHO WE ARE
This Privacy Policy covers collection of your personal data where you access any of the services offered by Lakeatts (Services) either online (for example through our website or our mobile apps) or where we collect your personal data offline (for example collection of data through email, physical forms, telephone, or in person).
By using our Services or by otherwise sharing with us your personal data, you agree to the terms of this Privacy Policy. Please review it carefully to understand our privacy practices. If you have questions about this Policy, please contact our team at info@lakeatts.co.ke
Data controller: Depending on the Service that you are accessing or using, the data controller will be the Lakeatts that you have entered into a contract with or are seeking to enter into a contract with, or, that you have otherwise provided your personal data to, and such company will be responsible for your personal data. In this Policy, the contracting Lakeatts subsidiary and Lakeatts’s group of companies are collectively referred to as “Lakeatts”, “we” or “us”.
Our contact details: If you have any questions about this Privacy Policy or our privacy practices, please contact us at info@lakeatts.co.ke.
Changes to the Privacy Policy and your duty to inform us of changes: We keep our Privacy Policy under regular review. When we make material changes to this Privacy Policy, we will notify you by posting the updated policy on our website and Lakeatts’s mobile apps, and we will update the effective date at the top of this policy. By continuing to use any of our Services or accessing our website and mobile apps after being notified of material changes to this policy, you agree to the terms of the updated policy.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links:strong> Our website and mobile apps may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website or mobile apps, we encourage you to read the Privacy Policy of every website you visit. Children Data: The Services are not intended for children and we do not knowingly collect data relating to children with or without parental consent.
THE DATA WE COLLECT ABOUT YOU
Personal data means any information relating to an identified or identifiable natural person. It does not include data where the identity has been removed (anonymous data). We may collect, use, store, process and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data which includes your first name, maiden name, last name, username or similar identifier, and usernames on social media platforms or other online platforms.
- Contact Data which includes billing address, delivery address, email address, telephone numbers, and digital contact details.
- Faith Data which includes the name of your church, your group in your church, and your position in your church (only applicable to our Faith Based Products).
- Financial Data which includes bank account details, payment card details, mobile payments, and other financial-related information.
- Transaction Data which includes details about offerings you give to the church.
- Technical Data which includes internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website and mobile apps. When you use any of our mobile apps, they may automatically collect and store information from your mobile device including, without limitation, your preferred language, phone number or other unique device identifier, IP address, manufacturer and model of your mobile device, mobile operating system, type of mobile internet browsers used, geolocation, and information about how you interact with the mobile apps (such as frequency and duration of use).
- Profile Data which includes your username and password, services you have accessed, and any information that indicates your behaviour as a customer or user of our Services.
- Usage Data which includes information about how you use our mobile apps, website, products, and services.
- Marketing and Communications Data which includes your preferences in receiving marketing communications from us and our third parties, and your communication preferences.
- Location Data which includes details of the location from which you access our Services or location details that you provide to us.
HOW IS YOUR PERSONAL DATA COLLECTED
We use different methods to collect data from and about you including through: Direct interactions: You may give us your Identity, Contact and Financial Data by filling in forms (online or offline) or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Apply for our Services.
- Create an account on our website/mobile apps.
- Subscribe to any of our Services or publications.
- Request marketing information to be sent to you.
- Enter a competition, promotion, or survey.
- Give us feedback or contact us.
- Technical Data from analytics providers, advertising networks, and search information providers.
- Identity, Contact, Financial, and Transaction Data from providers of technical, verification, payment, and delivery services.
- Identity and Contact Data from data brokers or aggregators.
- Identity and Contact Data from publicly available sources.
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party), and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
We will get your consent before sending direct marketing communications to you via email or text message or rely on consent given in the agreement you have with us. You have the right to withdraw consent to marketing at any time by contacting us. Purposes for which we will use your personal data. We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
Purpose/Activity Type of Data Lawful basis for processing including basis of legitimate interestWe use your personal data for the purposes set out below. Depending on the activity involved, we rely on one or more lawful bases under applicable data protection laws, including performance of a contract, compliance with legal obligations, and our legitimate interests.
Registration of Users
To register you as a new user of our Services, we process the following data:
- Identity Data
- Contact Data
Lawful basis: Performance of a contract with you.
Processing Your Instructions
We process your personal data in order to:
- Manage payments, fees, and charges
- Collect and recover money owed to us
- Determine the amount we will charge you for our Services
- Determine the location where you will receive our Services or where you require our Services
This processing involves the following categories of data:
- Identity Data
- Contact Data
- Financial Data
- Transaction Data
- Marketing and Communications Data
- Location Data
Lawful basis: Performance of a contract with you.
Managing Our Relationship With You
We use your personal data to manage our relationship with you, including:
- Communicating with you while providing our Services
- Notifying you about changes to our terms or this Privacy Policy
- Requesting reviews or participation in surveys
The categories of data used include:
- Identity Data
- Contact Data
- Profile Data
- Marketing and Communications Data
Lawful basis: Performance of a contract, compliance with legal obligations, and our legitimate interests (such as keeping records updated and understanding how our Services are used).
Competitions, Prize Draws, and Surveys
To enable your participation in prize draws, competitions, or surveys, we process:
- Identity Data
- Contact Data
- Profile Data
- Usage Data
- Marketing and Communications Data
Lawful basis: Performance of a contract and our legitimate interests (such as improving and growing our business).
Business Administration and Protection
We process personal data to administer, grow, and protect our business, website, and mobile apps, including for troubleshooting, data analysis, testing, system maintenance, support, reporting, hosting, verification, research, and development.
- Identity Data
- Contact Data
- Technical Data
- Transaction Data
- Financial Data
- Usage Data
Lawful basis: Our legitimate interests (such as running our business, IT security, fraud prevention, and business reorganisation) and compliance with legal obligations.
Marketing and Advertising Effectiveness
We use personal data to deliver relevant website and mobile app content and advertisements and to measure or understand the effectiveness of the advertising we serve.
- Identity Data
- Contact Data
- Profile Data
- Usage Data
- Marketing and Communications Data
- Technical Data
Lawful basis: Your consent and our legitimate interests (such as developing our Services and informing our marketing strategy).
Analytics and Service Improvement
We use data analytics to improve our website, mobile apps, products, services, marketing efforts, customer relationships, and user experience.
- Technical Data
- Usage Data
Lawful basis: Our legitimate interests in developing and improving our Services.
Personalised Recommendations
We may make suggestions and recommendations to you about services that may be of interest to you based on:
- Identity Data
- Contact Data
- Technical Data
- Usage Data
- Profile Data
- Marketing and Communications Data
Lawful basis: Our legitimate interests in developing and growing our products and services.
Verification and Fraud Prevention
We verify information you provide to us in order to prevent fraud and comply with legal requirements.
- Identity Data
- Contact Data
- Transaction Data
- Financial Data
Lawful basis: Our legitimate interests and compliance with legal obligations.
Marketing Communications
We strive to provide you with choices regarding certain personal data uses, particularly in relation to marketing and advertising.
Promotional offers from us: We may use your Identity, Contact, Technical, Usage, and Profile Data to assess which products and services may be of interest to you. You will receive marketing communications from us only if you have requested information, used our Services, and consented to receive such communications.
Third-party marketing: We will obtain your express consent before sharing your personal data with any third party for marketing purposes.
Opting out: You may stop receiving marketing messages at any time by using the opt-out links provided in our communications or by contacting us directly.
Cookies
You may set your browser to refuse all or some cookies, or to alert you when cookies are being used. If you disable or refuse cookies, certain parts of our website may not function properly.
Job Applicants
If you apply for a job with us, we will process your personal data to assess your suitability for the role and to contact you regarding interviews.
Change of Purpose
We will only use your personal data for the purposes for which it was collected, unless we reasonably consider that another compatible purpose applies. Where required by law, we will notify you.
User Generated Content
Our Services may allow you to submit content such as comments, images, videos, or other materials that may include personal data. Such content may be publicly accessible. We do not control how third parties use publicly available information and encourage you to exercise caution when sharing personal data in public areas.
This Privacy Policy does not apply to information you choose to make public. We are not responsible for the accuracy, use, or misuse of User Generated Content.
DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes described in this Privacy Policy.
- Internal third parties, such as companies affiliated with us.
- External third parties central to the provision of the Services to you, such as our clients or partners that use the Lakeatts platform.
- External third parties with whom we have partnered to offer Services (or auxiliary services) to you.
- Service providers and governmental bodies, including law enforcement agencies, where we are required to do so.
- Third parties with whom you have given us your consent to share your personal data.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. We will also disclose information, including Personal Data, to third parties
- When we are required to do so by a court order or by any regulatory authority.
- Where we are required to do so in order to comply with our legal and regulatory obligations under applicable legislation or regulation, including fraud prevention and anti-money laundering.
- In order to exercise, protect, and defend our rights and property, including our intellectual property.
- Where such disclosure is in the public interest.
TRANSFER OF DATA
We may transfer your Personal Data outside the jurisdiction where we collected it either for ease of delivery of Services, storage or other necessary form of processing. When such transfer is necessary and for your benefit, we ensure an appropriate and similar degree of protection is afforded to it by requiring implementation of relevant safeguards by the recipient of the personal data as required by applicable laws. By accepting this Privacy Policy, you are providing us with your express consent to transfer your personal data as laid out above.
RETENTION OF DATA
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes for which it was collected, and for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. Your personal data may be retained for a longer period where you have consented to the retention, there has been a complaint, there is a prospect of litigation with respect to your use of our Services or for historical and statistical purposes.
DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised 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.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
- Be informed of the use to which your personal data is being put.
- Access your personal data.
- Object to the processing of your personal data.
- Request restriction of the processing of your personal data.
- Request correction of false or misleading personal data.
- Request the transfer of your personal data.
- Request erasure of false or misleading personal data (we may not always be able to comply with such a request for specific legal reasons, which will be notified to you, if applicable, at the time of your request).
- Withdraw consent at any time where we are relying on consent to process your personal data.
If you wish to exercise any of the rights set out above or make a complaint with respect to how we process your personal data, please contact us .We may request specific information from you to enable us to confirm your identity, grant you access to your personal data or exercise any of your other rights in relation to such data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We will endeavour to respond to your complaint or request within fourteen days of its receipt. You will not have to pay a fee to access your personal data, or to exercise any of your rights in relation to the data, or to make a complaint. However, we may apply a charge if your request is clearly unfounded, repetitive or excessive. We may also refuse to comply with your request where permitted or required to do so under the law. Please remember that if you delete or limit the use of your personal data, you may not be able to access the Services.