Yelbridges Ltd. is a company registered in Kenya with office at T-Plaza, 4th floor, Kenyatta Highway, Thika, Kenya.
I) THIS POLICY
This Policy is issued by Yelbridges Ltd.
This Policy may be modified or updated now and again to reflect changes in our practices with respect to the Processing of Personal Information or changes in applicable law. We kindly ask you to read this Policy thoroughly and to regularly check this page to review any changes we might make in accordance with the terms of this Policy.
COLLECTION OF PERSONAL INFORMATION
a) Personal Information
We collect or obtain Personal Information. Personal Information means details which identify you or could be used to identify you. This includes information such as your name and contact details. This may also include information about how you use our websites and mobile applications.
b) Information provided to us
We obtain Personal Information when that information is provided to us (e.g., where you contact us via email or telephone, or by any other means, or when you provide us with your business card, or when you create an online profile with us, or when you submit a job application).
c) Relationship information
We collect or obtain Personal Information in the ordinary course of our relationship with you (e.g., we provide a service to you, or to your customer). We collect your Personal Information whenever you use our services, when you use our website or mobile applications, or interact with us via email or our contact centres.
d) Information you make public
We collect or obtain Personal Information that you choose to make public, including via social media (e.g., we may collect information from your social media profile(s), if you make a public post about us).
e) App data
We collect or obtain Personal Information when you download or use any of our Apps.
f) Site data
We collect or obtain Personal Information when you visit any of our Sites or use any features or resources available on or through a Site.
g) Registration details
We collect or obtain Personal Information when you use or register to use any of our Sites, Apps, products or services.
h) Content and advertising information
If you interact with any third-party content on a Site or in an App (including third party plugins and cookies) we may receive Personal Information from the relevant third-party provider of that content.
i) Third party information
We collect or obtain Personal Information from third parties who provide it to us (e.g. credit reference agencies, law enforcement authorities, etc.).
CREATION OF PERSONAL INFORMATION
We also create Personal Information about you in certain circumstances, such as records of your interactions with us (including records of your telephone conversations with us) and details of your customer history.
CATEGORIES OF PERSONAL INFORMATION WE PROCESS
We process the following categories of Personal Information about you:
a) Personal details
Given name(s), preferred name and photograph.
b) Demographic information
Gender, date of birth and /or age, nationality, title, language preferences.
c) Contact details
Correspondence address, telephone number, email address, messenger app details, online messaging details, social media details.
d) Consent records
Records of any consents you have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent)
e) Information relating to our Sites and Apps
Device type, operating system, browser type, browser settings, IP address, language settings, 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 technical communications information (some of which may constitute Personal Information), username, password, security login details, usage data, aggregate statistical information.
f) Employer details
Where you interact with us in your capacity as an employee of a third party, the name, address, telephone number and email address of your employer, to the extent relevant.
g) Content and advertising information
Records of your interactions with our online content, records of content displayed on pages or App screens displayed to you, and any interaction you may have had with such content (e.g., mouse hover, mouse clicks, any forms you complete in whole or in part) and any touchscreen interactions.
h) Views and opinions
Any views and opinions that you choose to send to us, or publicly post about us on social media platforms.
i) Other interactions with us
Information if you have registered for a newsletter. If you provide us with another individual’s Personal Information, you must ensure that you have the permission of that individual before you provide it to us.
6) PURPOSES OF PROCESSING AND LEGAL BASES FOR PROCESSING
The purposes for which we Process Personal Information, subject to applicable law, and the legal bases on which we perform such Processing, are as follows:
a) Provision of Sites, Apps, products, and services Providing our Sites, Apps, products, or services; providing promotional items upon request; and communicating with you in relation to those Sites, Apps, products, or services.
Legal Basis: The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or we have a legitimate interest in carrying out the Processing for the purpose of providing our Sites, Apps, poducts and services (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or we have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
b) Operating our business
Operating and managing our Sites, our Apps, our products, and our services. Providing content to you; displaying information to you; communicating and interacting with you via our Sites, our Apps, our products, or our services; and notifying you of changes to any of our Sites, our Apps, our products, or our services.
Legal Basis: The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us or the Processing is necessary for compliance with a legal obligation or we have a legitimate interest in carrying out the Processing for the purpose of providing our Sites, our Apps, our products, or our services to you (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms) or we have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
c) Communications and marketing
Communicating with you via any means (including via email, telephone, text message, social media, post or in person) news items and other information in which you may be interested, subject always to obtaining your prior opt-in consent to the extent required under applicable law; maintaining and updating your contact information where appropriate; and obtaining your prior, opt-in consent where required.
Legal Basis: The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us or we have a legitimate interest in carrying out the Processing for the purpose of contacting you, subject always to compliance with applicable law (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or we have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
d) Management of IT systems
Management and operation of our communications, IT and security systems; and audits (including security audits) and monitoring of such systems.
Legal Basis: The Processing is necessary for compliance with a legal obligation or we have a legitimate interest in carrying out the Processing for the purpose of managing and maintaining our communications and IT systems (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
e) Surveys
Engaging with you for the purposes of obtaining your views on our Sites, our Apps, our products, or our services.
Legal basis: We have a legitimate interest in carrying out the Processing for the purpose of conducting surveys, satisfaction reports and market research (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms) or we have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
f) Legal proceedings
Establishing, exercising and defending legal rights.
Legal Basis: The Processing is necessary for compliance with a legal obligation or we have a legitimate interest in carrying out the Processing for the purpose of establishing, exercising or defending our legal rights (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
g) Improving our Sites, Apps, products, and services
Identifying issues with our Sites, our Apps, our products, or our services; planning improvements to our Sites, our Apps, our products, or our services; and creating new Sites, Apps, products, or services.
Legal Basis: The Processing is necessary for compliance with a legal obligation (especially in respect of applicable employment law) or we have a legitimate interest in carrying out the Processing for the purpose of detecting, and protecting against, fraud (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
h) Recruitment and job applications
Recruitment activities; advertising of positions; interview activities; analysis of suitability for the relevant position; records of hiring decisions; offer details; and acceptance details.
Legal Basis: The Processing is necessary for compliance with a legal obligation (especially in respect of applicable employment law) or we have a legitimate interest in carrying out the Processing for the purpose of recruitment activities and handling job applications (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms) or we have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
7) DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES
We may disclose Personal Information to the partners of our network for legitimate business purposes and the operation of our Sites, Apps, products, or services to you), in accordance with applicable law. In addition we may disclose your Personal Information to legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation; accountants, auditors, lawyers and other outside professional advisors to Yelbridges Ltd., subject to binding contractual obligations of confidentiality;third party Processors; any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights; any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties; any relevant third-party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation); any relevant third-party provider, where our Sites and our Apps use third party plugins or content. If you choose to interact with any such plugins or content, your Personal Information may be shared with the relevant third-party provider. We recommend that you review that third party’s privacy policy before interacting with its plugins or content.
If we engage a third-party Processor to Process your Personal Information, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Information in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Information; together with any additional requirements under applicable law.
8) INTERNATIONAL TRANSFER OF PERSONAL INFORMATION
Since our business is international, we transfer Personal Information within our companies network and to third parties as noted in Section 7) above, in connection with the purposes set out in this Policy. Where we transfer your Personal Information from Kenya to recipients located outside Kenya who are not in Adequate Jurisdictions, we do so on the basis of Standard Contractual Clauses. You are entitled to request a copy of our Standard Contractual Clauses using the contact details provided below Please note that when you transfer any Personal Information directly to Yelbridges Ltd. or partner established outside Kenya, we are not responsible for that transfer of your Personal Information. We will nevertheless process your Personal Information, from the point at which we receive the information, in accordance with the provisions of this Policy.
9) INFORMATION SECURITY
We have implemented appropriate technical and organisational security measures designed to protect your Personal Information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law. Since the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Information, we cannot guarantee the security of the information transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Information that you send to us is sent securely.
10) INFORMATION ACCURACY
We take every reasonable step to ensure that Personal Information of yours that we Process is accurate and, where necessary, kept up to date; and any Personal Information of yours that we Process that is inaccurate (having regard to the purposes for which they the information is Processed) is erased or rectified without delay. From time to time we may ask you to confirm the accuracy of your Personal Information.
11) INFORMATION MINIMISATION
We take every reasonable step to ensure that your Personal Information that we Process is limited to the Personal Information reasonably necessary in connection with the purposes set out in this Policy.
12) INFORMATION RETENTION
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.
13) YOUR LEGAL RIGHTS
Subject to applicable law, you may have the following rights regarding the Processing of your Relevant Personal Information:
- The right not to provide your Personal Information to us (however, please note that we will be unable to provide you with the full benefit of our Sites, Apps, products, or services, if you do not provide us with your Personal Information;
- The right to request access to, or copies of, your Relevant Personal Information, together with information regarding the nature, Processing and disclosure of those Relevant Personal Information;
- The right to request rectification of any inaccuracies in your Relevant Personal Information;
- The right to request,on legitimate grounds: erasure of your Relevant Personal Information or restriction of Processing of your Relevant Personal Information;
- Where we Process your Relevant Personal Information on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Information in reliance upon any other available legal bases)
- The right to lodge complaints regarding the Processing of your Relevant Personal Information with a Data Protection Authority
Subject to applicable law, you may also have the following additional rights regarding the Processing of your Relevant Personal Information: the right to object, on grounds relating to your particular situation, to the Processing of your Relevant Personal Information by us or on our behalf and the right to object to the Processing of your Relevant Personal Information by us or on our behalf for direct marketing purposes.
This does not affect your statutory rights. To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Policy, or about our Processing of your Personal Information, please use the contact details provided below. Please note that in some cases, it will be necessary to provide evidence of your identity before we can give effect to these rights; and where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.
14) COOKIES AND SIMILAR TECHNOLOGIES
When you visit a Site or use an App we will typically place Cookies onto your device or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We Process Personal Information through Cookies and similar technologies, in accordance with our Privacy Policy.
a) What are cookies?
Cookies are small text files that are placed on your computer, mobile phone or tablet by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to website owners.
- Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to use the site, you are agreeing to our use of cookies in accordance with the terms of this policy.
- More information on all aspects of cookies (including how to disable cookies) can be found on www.allaboutcookies.org. Please note that Yelbridges Ltd. has no affiliation with, and is not responsible for, this third party website.
b) We use the following types of cookies:
- First party cookies – are cookies that are placed by the website you are visiting. Third party cookies – are cookies placed by a website other than the one you are visiting. Please note that we do not control the collection or further use of data by third parties.
- Strictly necessary cookies – these are cookies that are required for the operation of our website, e.g. cookies that enable you to log into secure areas of our website;
- Analytical/performance cookies – these allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, e.g. by ensuring that users are finding what they are looking for easily;
- Functionality cookies – these enable us recognise you when you return to our website and allow us to personalise our content for you and to remember your preferences.
- Targeting cookies – these cookies record your visit to our website, the pages you have visited and the links you have followed, including whether you downloaded a particular whitepaper/campaign material or viewed a video/campaign material on the website. We will use this information to make our website and the advertising displayed on it more relevant to your interests.
C) USAGE OF SNOWPLOW ANALYTICS
We use a tool which bases on the technology of Snowplow Analytics. This tool does not register personal data and will be used by our webhosting-supplier and service-provider only in order to improve the own service.
d) Usage of Script libraries (Google Web Fonts) In order to display our content in every browser correctly and graphically appealing we use website scripts and font libraries like Google Web Fonts (https://www.google.com/webfonts). Google Web Fonts will be transferred in the cache of your browser so that they have to be loaded only once. If your browser does not support Google Web Fonts or denies access, content will displayed in standard font. When loading script- or font libraries there will be automatically started a connection to the provider of the library. Theoretically there exists the possibility that the provider collects data. At this time it is not known, if and to what purpose the provider of libraries actually collect data. Here you find the data protection regulations of the provider of the Google-Library: https://www.google.com/policies/privacy. e) Google Analytics This Site uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help the website analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. For more information please visit http://www.google.com/analytics/ f) Refusing or withdrawing your consent to the use of cookies You can refuse or withdraw your consent to the use of cookies and disable them at any time by changing the settings on your browser. However, please note that if you do so, it may affect your ability to properly use this website.
15) INDEMNIFICATION
You agree to indemnify, defend and hold us harmless from any liability, loss, claim and expense related to your breach of these Terms and Conditions, including, but not limited to by persons, authorised or otherwise, who access this site using your access information.
16) APPLICABLE LAW AND JURISDICTION
Your use, accessed of this website including but not limited to such the data, information, services and materials contained herein the operation of these Terms and Conditions and any dispute or claim arising out of or in connection with such matters, or subject matter or formation contractually or otherwise shall be governed by, construed and interpreted in accordance with the laws of Kenya.
17) MISCELLANEOUS
These Terms and Conditions contain solely all the terms of your agreement with us relating to your use of this website. Moreover any failure to assert whatever rights arising to us under these Terms and Conditions does not constitute a waiver of our right to assert the same or any other right at any other time or against any other person. Further where any provision of these Terms and Conditions is found to be invalid or unenforceable, then such invalidity or unenforceability shall not in any way affect the validity or enforceability of any other provision in the Terms and Conditions.
All use of our Sites, Apps, products, or services is subject to our Disclaimer and Privacy Policy. We recommend that you review our Terms and Conditions regularly, in order to review any changes, we might make from time to time.
18) CONTACT
Our Data Protection Officer is contactable at : [email protected]
T-Plaza, Kenyatta Highway
Thika, Kenya