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KENCHIC LIMITED

WEBSITE DATA PROTECTION AND PRIVACY POLICY

Last updated 19:07:2023

1. INTRODUCTION

1.1. Kenchic Limited (“we” or “us” or “our”) respects the privacy of our users (“user” or “you”). This Privacy Policy explains how we collect, use, disclose, and protect your information when you visit our website https://www.kenchic.com. as well as any other media form, media channel, mobile website, or mobile application related to it (collectively, the “Site”). Please carefully read this Privacy Policy. Please do not access the Site if you do not agree with the terms of this Privacy Policy.

1.2. We reserve the right, at any time and for any reason, to modify this Privacy Policy. We will notify you of any changes by updating the “Last Updated” date on this Privacy Policy. Any changes or modifications will take effect as soon as the updated Privacy Policy is posted on the Site, and you waive your right to specific notice of each such change or modification.

1.3. You should review this Privacy Policy on a regular basis to stay up to date on any changes. By continuing to use the Site after the date such revised Privacy Policy is posted, you will be deemed to have been made aware of, subject to, and understood the changes in such revised Privacy Policy.

2. COLLECTION OF YOUR INFORMATION

In addition to clause 3, we may collect and use information about you if it is necessary for our legitimate interests, and we will ensure that it is used in accordance with the Kenyan Data Protection Act and its regulations. On the Site, we may collect the following information:

2.1. Personal Data

2.1.1. The types of information we collect include personally identifiable information such as your name, address, email address, and phone number, as well as demographic information such as your age, gender, hometown, and interests, which you voluntarily provide to us or when you choose to participate in various Site-related activities such as online chats.

2.1.2. You are not required to provide us with any personal information; however, you may be unable to use certain features of the Site if you do not.

2.2. Derivative Data

When you access the Site, our servers automatically collect information such as your IP address, browser type, operating system, access times, and the pages you have viewed directly before and after accessing the Site, as well as other interactions with the website and other users through server log files, as well as any other information you choose to provide.

2.3. Data from Social Networks

Information can be gleaned from social networking sites, such as Facebook, Twitter and Instagram. If you grant us access to your account, we may collect user information from social 2 networking sites such as your name, social network username, location, gender, birth date, email address, profile picture, and public data for contacts.

2.4. Data from Mobile Devices

If you access the Site using a mobile device, we may collect device information such as your mobile device ID, model, and manufacturer, as well as information about your device’s location.

2.5. Third Party Data

The Site may access information from third parties, such as personal information or network friends, if you connect your account to the third party and grant the Site permission to access this information.

3. USE OF YOUR INFORMATION

We can provide you with a smooth, efficient, and customized experience if we have accurate information about you. In particular, we may use information collected about you through the Site for the following purposes:

3.1. processing products and services that you have bought from us or from our affiliated companies.

3.2. responding to any of your queries or concerns;

3.3. verifying your identity information through publicly available and/or restricted government databases in order to comply with applicable regulatory requirements.

3.4. keeping you informed generally about new products and services and contacting you with offers or promotions based on how you use our or third-party products and services unless you opt out of receiving such marketing messages (you may contact us at any time to opt out of receiving marketing messages);

3.5. to comply with any legal, governmental or regulatory requirement or for use by our lawyers in connection with any legal proceedings;

3.6. in business practices including to quality control, training and ensuring effective systems operations;

3.7. preventing and detecting fraud or other crimes and for debt recovery;

3.8. for research, statistical, survey and other scientific or business purposes;

3.9. providing aggregated data (which do not contain any information which may identify you as an individual) to third parties for research and scientific purpose; and 3.10. administering any of our online platforms/websites.

4. DATA SUBJECT RIGHTS

As a data subject, you are entitled to the following rights:

a) You have a right to be informed by us the use to which your personal data is to be put.

b) You have a right to request us for copies of your personal data at any time, free of charge, as well as what your personal data is used for. We reserve a right to charge a reasonable fee if 3 your request is unfounded or excessive. Where we decline to respond to your request we shall provide you with written reasons.

c) You have a right to request in writing for correction of any information you believe is inaccurate, untrue, outdated, misleading or complete information you believe is incomplete.

d) You have a right to request in writing deletion or destruction of your personal data where: (i)the personal data is no longer necessary for the purposes of processing; (ii)where processing is unlawful; (iii)you have withdrawn consent which was the lawful basis for retaining personal data; (iv) processing of personal data is unlawful ;or (v) you object to processing of your personal and there is no overriding legitimate interest.

e) You have a right of opposition against the processing of all or part of your personal data for serious and legitimate reasons.

f) You have a right to withdraw consent where processing of personal data is based on consent.

g) You have a right to restrict, by notice in writing, the processing of your personal information under certain legitimate conditions.

h) You have a right to request that for your personal data processed by us to be transferred to another data controller/ data processor or directly to you. If you wish to exercise any of the above rights, please reach out to us via the contact details in clause 11 of this Privacy Policy. Please note that we shall endeavor to act on any of your requests within the statutorily prescribed timelines. Where there are any delays in responding to your request, you will be notified of the reasons for the delay and the period within which your request will be processed.

5. CONFIDENTIALITY OF PERSONAL DATA

The information we collect will be kept private. Employees process or use information based on a “need to know” basis. Employees may only have access to information that is necessary for the task at hand. Employees are not permitted to use information for personal or commercial gain, to disclose it to unauthorized parties, or to make it available in any other way.

6. STORING YOUR INFORMATION

We will keep personal information for as long as it is required to fulfill the purpose for which you have provided and in accordance with our data retention policy. We will not keep personal information if it is no longer needed or if the purpose for which it was collected has been met. In some cases, we may retain personal information for longer periods if it is authorized by law, it is reasonably necessary for a lawful purpose, authorized or consented by you or it is necessary historical, statistical, journalistic literature and art or research purpose.

7. DISCLOSURE OF YOUR INFORMATION

In certain circumstances, we may share information we have gathered about you. We are committed to ensuring that any third parties to whom we grant data access in the course of business have appropriate privacy policies. Your information may be disclosed in the following ways:

7.1. By Law

If we believe it is necessary to respond to legal process, investigate or remedy potential violations of our policies, or protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other organizations in order to combat fraud and lower credit risk. 4

7.2. Third Party Service Providers

We may share your information with third-party service providers who provide services to us or on our behalf, such as payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance. Every action taken by an external service provider is strictly governed by a contract and the terms and conditions of this privacy policy. Personal information provided by us will be used only for the purposes specified and will be processed in accordance with data protection legislation.

7.3. Marketing

We may share your information with third parties for marketing purposes with your prior consent in which case we will provide you with an opportunity for you to withdraw consent, as permitted by law.

7.4. Third Party Advertisers

When you visit the Site, we may use third-party advertising companies to display ads. These companies may use information contained in web cookies about your visits to the Site and other websites to provide advertisements about goods and services of interest to you.

7.5. Business Partners

We may share your information with our business partners in order to provide you with specific products, services, or promotions.

8. TRACKING TECHNOLOGIES

8.1. Cookies and Web Beacons

On the Site, we may use cookies, web beacons, tracking pixels, and other tracking technologies to help customize and improve your experience. Please see our Cookie Policy, which is incorporated into this Privacy Policy, for more information on how we use cookies. You agree to be bound by our Cookie Policy by using the Site.

8.2. Internet-Based Collection

Cookies or similar tracking technology may be used by this third-party software to help manage and optimize your online experience with us.

8.3. Web Analytics

We may also collaborate with carefully selected third-party vendors, to allow tracking technologies and remarketing services on the Site via first-party cookies and third-party cookies, to analyze and track users’ use of the Site, determine the popularity of certain content, and better understand online activity. By using the Site, you agree to these third-party vendors collecting and using your information. You are encouraged to read their privacy statement and contact them directly with any questions. We do not provide any personally identifiable information to these third-party vendors. You should be aware that purchasing a new computer, installing a new browser, upgrading an existing browser, or erasing or otherwise modifying your browser’s cookie files may result in the deletion of certain opt-out cookies, plug-ins, or settings.

9. SECURITY OF YOUR INFORMATION

To help protect your personal information, we employ administrative, technical, and physical security measures. While we have taken reasonable precautions to protect the personal information you provide to us, please be aware that no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against interception or other types of misuse. Any information disclosed online is vulnerable to unauthorized interception and misuse. As a result, if you provide personal information, we cannot guarantee complete security.

10. COMMUNICATIONS AND EMAILS

10.1. If you no longer want to receive correspondence, emails, or other communications from us, you can opt-out by contacting us via the information provided below.

10.2. If you no longer want to receive correspondence, emails, or other communications from third parties, you must contact them directly.

11. CONTACT US

If you have questions or comments about this Privacy Policy or how we process your personal data, please contact us at:

Tel: +254 703056 000

Email: dpo@kenchic.com