AKILI PARTNERS LTD PRIVACY POLICY

The information on this page contains our "Privacy Policy", which tells you about how we collect, use, and share information you might share with us when you visit and use websites, apps and other internet services offered by Akili Partners Limited (we'll call all of these together the "Akili Partners Sites"). It is important you read through this Privacy Policy, and, if you are below the age of 18 years, please make sure your parent(s) or legal guardian(s) give you their consent to read it, and that they discuss it with you as well.

Akili Partners Limited determines how the information (or 'data') collected about you is used, so we are the "Data Controller".

After you read the Privacy Policy, you will be able to understand:

what information we collect from you when you visit and use Akili Partners Sites;
how we use that information;
when that information may be shared with third parties;
how you or your parent(s) or guardian(s) can control how your information is used; and
how we store and protect your information.

Your privacy is very important to us. Younger visitors should always check with their parent(s) or guardian(s) and get their permission before entering information on any website or mobile application and we encourage them, together with you and the rest of the family or household to discuss how your information should be shared when you are online.

We may change this policy from time to time so when we do, we will post the latest version on the Akili Partners Sites. If we wish to use your information in a way that is different from what we say in this Privacy Policy, we will contact you (and your parent(s)/guardian(s) as needed) to get your consent.

Summary

We would like you to read the entire Privacy Policy which contains all the details, but you might find this quick summary helps to answer some important questions you may have about the Akili Partners Sites.

WHAT INFORMATION DOES AKILI PARTNERS COLLECT?

In general, we collect two types of information:

Information that you actively give to us. For example, when you enter a draw or a raffle; or you send us your photographs, publications or other material, you might give us information so we know who you are and how to contact you.
Information we automatically collect about your computer or other devices connected to the Internet. This might be your IP address, a cookie ID or a device ID – basically, any set of numbers or letters that lets us know your computer or device is the one visiting the Akili Partners Sites).

For more details about the information we collect, please see "The Information We Collect And How We Use It" section below.

HOW DO YOU USE MY INFORMATION?

We might use your information to:

allow you to use certain features and services;
reply to requests you send to us;
personalize your settings and the promotions you see on the Akili Partners Sites;
send special promotions to you when you (or your parent(s) or guardian(s) have given us permission to do this;
determine and measure the way you (and other people) use the Akili Partners Sites (for example, to see which parts of the Akili Partners Sites are the most popular) so that we can manage and improve our services.

We will not always do all these things, but we might use your information in these ways when we are permitted by law.

For more details about how we use your information, please see "The Information We Collect And How We Use It" section below.

HOW DO YOU STORE MY INFORMATION?

We do our best to protect your information against loss and unauthorised access, and keep our security measures up to date as cyber threats change. If you think an unauthorised third party has accessed your information, please contact us immediately. For more details on how to reach us, please see the "Contact Us" section below.

For more details about how we store information, please see the "How We Store the Information We Collect" section below.

WHAT INFORMATION DO YOU SHARE WITH OTHER PEOPLE ("THIRD PARTIES"), AND FOR WHAT PURPOSES?

We share your information with certain others ("third parties") in different situations, but only as permitted by the law. This information may include information you have actively provided us, information we collected automatically from you or your device, and information that does not directly identify you like whether you are a boy or girl, or how you watch our programmes.

As appropriate under the circumstances, and as permitted by law, we may share that information with:

law enforcement officers or others as needed to protect or defend our rights and the rights of others;
companies and people we hire to help us to operate the Akili Partners Sites;
with advertisers and other third parties so that we can provide additional content, products or services;
with our business partners who sponsor a promotion or competition or who offer a service or feature on the Akili Partners Sites; and
in the event of a corporate transaction.

Otherwise, we won't share your information unless it is with the consent of you or your parent(s) or guardian(s).

For more details about the way we share information with other people, please see the "Information We Share with Third Parties" section below.

DO OTHERS COLLECT INFORMATION ON THE AKILI PARTNERS SITES?

In some cases, yes. For example, some third parties (with our permission) may collect and disclose certain device identifiers, like IP address or cookie information, to help to operate the Akili Partners Sites. For example, when we are providing content to you, or allowing features to run on the Akili Partners Sites, or showing adverts, or use analytics and other tools to improve the quality and performance of the Akili Partners Sites, we will need to allow our business partners to collect that information.

For more details about third parties and the information they collect, please see the "What Information Others May Collect" section below.

WHAT RIGHTS DO I HAVE?

Under the law, you may be entitled to:

complain about or ask us to change the way we use your information;
ask to see the information we store about you;
correct any mistakes in your information that is stored by us;
request us to delete the information we store about you; and
request for a copy of the information we hold about you to take to another website, application or interactive service.

If we obtained your or your parents' or guardians' consent to collect your information, you or your parent(s) or legal guardian(s) may withdraw that consent for the future collection of your data at any time.

For more details about your rights and choices concerning your information, please see the "Your Rights" section below.

WHO ARE YOU AND HOW CAN I CONTACT YOU?

The Akili Partners Sites are made available by Akili Partners Limited, which is the 'Data Controller' in charge of the way all personal information is used under this Privacy Policy. If you have any questions about the use of your information when you visit or use the Akili Partners Sites, please contact us at:

The CEO
Akili Partners Limited
P. O. Box 2852 – 00606
Nairobi, Kenya

dataprotection@akilinetwork.com

Full Policy

1. The Information We Collect and How We Use It

In this section, we explain what personal information we collect about you and how we collect it when you visit the Akili Partners Sites. You provide some of this information to us, and other types of information we may collect automatically. You will only be required to share information that is reasonably necessary to participate in the particular activity, so when information is required in order to participate in activity, we will let you know.

2. Information you provide to us

You may be required to provide us information, for example, in order to receive a service from our website, or participate in a promotion or competition. The information required varies by Site, but may include: (a) first name and surname; (b) birth date; (c) gender; (d) country; (e) state; (f) postal code; (g) user name and password; (h) mobile telephone number; (h) email address; or (i) other profile information such as avatar preferences, communications preferences, and interests.

3. Information we automatically collect from your computer or device

When you come to one of our Sites, we may automatically collect certain information about your use of the Site, including information about the websites you visited before and after visiting the Site, the web pages and advertisements you viewed and any links you clicked on or within the Sites, information collected through the use of unique identifiers such as cookies (see below), information regarding your Internet Service Provider, and other standard server log information. We also automatically collect information about your computer or mobile device, such as the type of operating system (e.g., Windows, Mac, iOS, or Android), your IP address (a number assigned by your Internet Service Provider that can identify your device), the type of web browser (e.g., Internet Explorer, Safari, Chrome, and Firefox), unique device identifiers (or UDID, a permanent identifier for certain mobile devices) or advertising identifiers (a resettable identifier that is assigned to your mobile device by your operating system provider, such as Apple or Google) and crash data), ("Computer Information").

4. Cookies and Tracking Technologies

We and our advertising and analytics service providers use cookies, which are small text files that help store user preferences and activity, and similar technologies such as web beacons, pixels, and ad tags to recognize you when you visit the Akili Partners Sites ("Tracking Technologies"), and to collect information such as the number of visits, which features or pages are popular, measurements about an advertising campaign's success, and other information about how you use our services. This allows us to ensure our services are functioning properly, to improve our services, and to provide and measure advertisements. For more information about cookies and how to disable them, please visit our Cookies Policy.

4. How we use your information

We will only collect, store, or otherwise process your personal information in the following situations:

When we have your consent or the consent of your parent or guardian (such as allowing you to register for an account on one of our sites or to provide you with advertising or marketing materials). You or your parent or guardian can withdraw consent at any time, but keep in mind that withdrawing consent does not affect the legality of the processing of your data before the consent was withdrawn.
We need to use your personal information to perform our responsibilities under a contract with you (e.g., providing the products or services you have requested, or allowing you to enter a promotion or a competition, or inform you that you've won).
We have a legitimate interest in processing your personal information. For example, we may process your personal information to figure out what is most popular on the Akili Partners Sites so we can make more things like it; to communicate with you about our services; and to prevent fraud or unlawful behaviour.
We are required by law to process the information.

If you have questions about our processing or if you wish to withdraw consent you have previously given us, please contact us via our "Contact Us" section below.

5. How We Store the Information We Collect

We maintain reasonable technical and organizational steps to help ensure that information collected is secure, including limiting the number of people who have physical access to our database servers and use of electronic security systems and password protections which guard against unauthorized access. We limit access to visitor's information to employees and contractors who are authorized for the proper handling of such information. We also take reasonable steps to help make sure our third-party agents protect the security of your personal data. Information collected at the Akili Partners Sites will not be stored for longer than is necessary for the purposes described in this Privacy Policy, or to otherwise meet legal requirements.

6. Information We Share with Third Parties

Sometimes we need third parties to carry out services for us. For example if you win a competition, we may need to pass your information to a third party to arrange delivery of your prize, or we may need advice from an auditor or legal adviser. We currently use the online service Mailchimp to send out regular email newsletter. We will make sure that these third parties keep your information secure; only keep the information for so long as is necessary; and will comply with all applicable laws and regulations.

Apart from the above, we may pass on your information to third parties in the following circumstances:

we have reason to believe that disclosing this information is necessary to comply with legal obligations;
if disclosing the information is necessary to perform our responsibilities under a contract with you;
in the context of any sale or transaction involving all or a portion of the business, or as may be required or permitted by law or required for the purposes of any regulatory audit to which we may be subject from time to time; and
with your (or your parents'/guardians') consent.

Finally, we share information that is generic and doesn't identify you, such as whether you're male or female and how you watch our programmes. We may use such information (in whole or in part) to identify trends and may pass this to third parties, such as advertisers and business partners to give them a better understanding of our business.

7. What Information Others May Collect

In accordance with applicable law, and with your consent or your parents' or guardians' consent, where required, third parties may collect, use or disclose cookie information, IP addresses, or other identifiers from devices and/or browsers of users who visit Akili Partners Sites for the purposes of supporting the operations of the Akili Partners Sites, which can include, for example:

providing content or allowing features to run on the Sites;
serving advertising; and
using analytics and other tools to improve the quality and performance of the Akili Partners Sites.

Our corporate affiliates may also collect or maintain information through the Akili Partners Sites to the extent they provide any support for the Akili Partners Sites or any of the services we offer you.

The Akili Partners Sites also use a variety of third-party service providers such as advertising networks, data exchanges, traffic measurement service providers, and marketing analytics service providers. While these third parties or advertisers, cannot access the Tracking Technologies that we set, they may themselves set and access their own Tracking Technologies on your device if you choose to have Tracking Technologies enabled in your browser. The use of such technology by these third parties is within their control and not the Akili Partners Sites. Even if we have a relationship with the third party, we do not control those sites or their policies and practices regarding your information and those sites may use the information they collect from you consistent with their own privacy policies. For more information on how to disable Tracking Technologies, please see our Cookies Policy.

8. Your Rights

You have rights in relation to your personal data. In accordance with the Data Protection Act, 2019 these include the right to:

Request access to your personal data;
Request correction of your personal data;
Request deletion of your personal data;
Object to processing of your personal data;
Request restriction of processing your personal data; and
Request a copy of certain personal data for reuse elsewhere.

If you wish to exercise any of these rights, please see the 'Contact Us' section below for details. We may need to request limited information from you to help us confirm your identity in order for you to exercise any of your rights.

We generally do not charge a fee to exercise your rights. Nevertheless, if your request is clearly unfounded, repetitive or excessive, in accordance with the law, we may charge a reasonable fee or refuse to comply with your request.

If you believe that our processing of your personal data infringes applicable law, please see the 'Contact Us' section below for details. If we are not able to address your concern, you have the right to lodge a complaint with the Office of the Data Commissioner.

9. International Transfers of Personal Data

We and our service providers transfer your personal information to, or store or access it in, other countries where the laws may not provide levels of protection for your personal information equivalent the protection provided by the laws of Kenya. When we do this, we take steps to ensure that your personal information receives an appropriate level of protection through contractual requirements imposed on the recipient of the information (you can obtain a copy of these clauses by contacting us; please see the "Contact Us" section).

10. Contact Us

If you have any other questions about our information handling practices, including our practices with respect to children's personal data, or would like further information regarding the Akili Partners Sites, please contact Akili Partners Limited (which is the data controller of the information you supply to the Akili Partners Sites):