This privacy dogma relates to data information captured about you. That of the individuals associated to your corporate by us as records controllers. It explains the information we collect about you, and your business, how and who we’ll share it with, the circumstances when we’ll share it, and what steps we’ll take to make sure it stays secure and confidential.
Anywhere we say “you” or “your” this means you as our client and any personnel associated to your business.
The associated personnel, here-in could be any principal, director, shareholder or employee of a company, associates or affiliates of a partnership, any significant owner, supervisory person, or beneficial owner, your advocate or lawyer, go-between or nominee, or any entities with whom you have an affiliation with that’s relevant to your association with us.
1. Essential information and who we are
The Centric Moving Company Ltd is the controller and accountable for your personal data (collectively referred to as “Centric Moving”, “we”, “us” or “our” in this privacy notice). Contact details
Our contacts are:
Full name of legal entity: The Centric Moving Company Ltd
Postal address: P.O. Box 52048 – 00200
Physical address: Kenya, Nairobi, Kileleshwa – 75, Ole Nguruone
Email address: email@example.com
Telephone number: +254 (0) 720 635 635
It is important that the personal data we hold about you is accurate and current.
Please keep us informed should your personal data change during your interactions with us.
2. The data we accrue about you
Personal information herein means any data about a person from which that individual can be identified. It does not include information where the identity has been removed (anonymous data).
We may accumulate, use, stock and convey different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes name, username, nickname or any identifier.
- Contact Data includes billing address, origin and destination address, physical address, email address, telephone numbers, home and cell phone number.
- Recorded Data includes virtual footages, pre-recorded videos, pictures, clips, GIFs and images.
- Financial Data includes bank account, and payment card details.
- Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
- CCTV data includes images collected of you either at our premises or in the vicinity of our vehicles.
- That you’ve provided to us
We do not intentionally gather the succeeding Special Classifications of Personal information about you: particulars about your religious or philosophical beliefs, sex life, sexual alignment, political beliefs, trade union association, your health, hereditary and biometric information. Neither do we collect any info about criminal convictions, violations nor offences about you.
There is a likelihood that we gather details about your race, ethnicity, culture and traditions when processing your data.
CCTV captured images are necessary for reasons of public notice in order:
- for the individual security of staff, guests, and other members of the public and to act as a deterrent against crime;
- to prevent law-breaking and safeguard properties and assets from interference, damage, disruption, vandalism, sabotage and other crime;
- for assistance in the defiance of any civil litigation; and
- to support law enforcement bodies in the prevention, exposure and prosecution of law-breaking.
Discharging of identification documents will be necessary when you engage our services for an international removal, because this may be a mandatory requirement for customs clearance. In such instances, we will obtain your explicit consent to process these documents.
3. How is your personal data collected?
Different methodologies are used to gather information from and about you including but not limited to:
- Direct exchanges. You may facilitate us with your Identification, Contact and Financial Data and/or other data about you and people connected to your business and/or family by filling in forms or by corresponding with us by WhatsApp, phone, text, email or otherwise.
- CCTV set-ups. We may record and accumulate information about you from CCTV at any of our premises or attached to our vehicles.
- Third parties or publicly available sources. We may obtain personal data about you from various third parties and public sources as listed below:
- Contact, Financial and Transaction Data from other service providers of technical, payment and delivery services.
- Identity and Contact Data from brokerages or intermediaries.
- Identity and Contact Data from public available sources such as Companies registry and the government press
4. How we use your personal information
We will only use your personal information where the law approves. Regularly, we will use your personal information in the below situations:
- Where we need to complete a contract, we are about to enter into or have entered into with you.
- Where we need to conform with a legal or governing obligation.
- 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.
Largely, we do not rely on consent as a legal basis for dispensation of your personal information other than in relation to conveying third party direct marketing communications to you via email, what’s app or text message. You have the right to unsubscribe to marketing content at any time.
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.
We have set out below ways we plan to use your personal data, and which of the legal bases we rely on to do so.
- To register you as a new customer.
- To process and deliver your order and carry out your instructions e.g. manage payments, collect money owed to us and delivery of stored items.
- To administer and protect our business by data analyzing, testing, maintenance, undertaking risk management
Variation of purpose
We will only use your personal data for the purposes for which we collected it, unless we soundly consider that we need to use it for another reason and that reason is compatible with the original purpose.
Please note that we may process your personal information without your awareness or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal information
We may have to share your personal information for the purposes set out above with external third parties such as:
- 3rd parties who we might engage to carry out some or all of the services we provide to you.
- Service providers who provide IT and system support and administrative services.
- Kenya Revenue Authority, Customs and other relevant authorities who require reporting of processing activities in certain circumstances.
- Professional advice-givers including advocates, lawyers, bankers, auditors and insurers who provide legal, banking, accounting and insurance consultancy services.
We shall require all third parties to respect the security of your personal information and to treat it in agreement with the law. We do not a permit our third-party service providers to use your personal information for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. Data safety
We have put in place fitting security measures for security of your personal data from being accidentally lost, stolen, used or accessed in an unauthorized manner, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information knowing that they are subject to a duty of discretion, privacy and confidentiality.
7. Data retention
How long will my personal data used?
We shall keep your personal information for as long as necessary to fulfil the purposes we collected it for. This will include for the purposes of fulfilling any legal requirement should need arise, accounting and auditing, taxes liability or reporting needs.
To determine the suitable custody period for personal information, we put into consideration the nature, amount, and sensitivity of your personal information, the would-be jeopardy of detriment from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can realize these purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for as long as necessary.
8. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data as follows:
- Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Should you wish to enforce any of your rights listed above, please email firstname.lastname@example.org and let us know.