PRIVACY POLICY

We respect your privacy and are committed to safeguarding your personal information. This privacy policy (“Policy”) applies to your use of www.estate254.com (referred to as the “Site” or “Sites” depending on the context). This Policy outlines how we collect, store, protect, share, and use any personal data that we may collect from you when you use or otherwise interact with the Site or the services offered through our Site. Our treatment of your personal data complies with the Data Protection Act of Kenya 2019 (as amended or varied from time to time).

Please review this Policy carefully to understand our practices.

This Site is not intended for children under 18 years, and we do not knowingly collect data relating to children.

TERMS

For ease of reference, the terms below as used in this Policy have the following meanings:

• Account: The account you create when registering as a user on the Site to enable you to access some of the Services.
• Personal data: Information relating to you and which can identify you as an individual (whether on its own or taken with other information). It does not include aggregated or anonymized data, which is information that can no longer identify you.
• Site: Refers to www.estate254.com.
• Services: The services made available, accessed, published, or otherwise offered through the Site.

DATA CONTROLLER

Estate254.com is the data controller and responsible for your personal data (referred to as “we,” “us,” or “our” in this Policy). If you have any questions about this Policy, please send an email to admin@estate254.com.

DATA COLLECTED

Depending on the services you are obtaining or accessing, we may collect, store, use, and transfer the following types of information:

• Identity information: Such as your first name, last name, username, marital status, nationality, date of birth, or gender.
• Contact information: Such as your email address, telephone numbers, and location.
• Financial information: Such as bank account details or payment card details.
• Verification information: Such as your national ID, passport, or business permits.
• Account information: Related to the use of the Site, including username, password, orders, and preferences.
• Automatic information: Including technical data such as IP address, browser type, and version, and operating system.
• Marketing and communications data: Such as your preferences in receiving marketing from us and your communication preferences.

We may also collect and use statistical or demographic information for any purpose. This data is anonymous and is not personal information, as it will not directly or indirectly reveal your identity. However, if we combine or connect statistical/demographic information with your personal data, we will treat the resulting information as personal data in accordance with this privacy policy.

WHAT IF I DON’T WANT TO PROVIDE ANY PERSONAL DATA?

Where we need to collect personal data by law or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

HOW DATA IS COLLECTED

We collect personal information:

• That you provide to us directly through the Site, on the phone, or through any other communication channel.
• We obtain from other sources.
• Using cookies, logs, web beacons, tags, pixels, and other internet technologies, for example, technical data.

ACCURACY OF THE DATA

It is important that the personal data we hold is accurate and current to enable us to deliver the Services. Please keep us informed if your personal data or any other information changes in the course of your use of the Site.

You guarantee and declare that you are the owner of the information you submit on the Site or share with us, or that you have the necessary rights to do so. You also guarantee and declare that it is exact, true, and verified, and that the use of the information is not contrary to this Policy or applicable laws and will not damage a third party’s reputation. You accept full and complete liability for any information that is contrary to this Policy or any applicable laws.

USE OF THE COLLECTED DATA

How we use your personal data depends on the services you are accessing. We will use your personal data:

• To provide you with the Services.
• To connect you to a buyer or seller, as the case may be.
• To run targeted marketing campaigns.
• To contact you about the Services, events, and promotions (where you have agreed to us doing so).
• To comply with our legal obligations.
• Where necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where the personal data is required for statistical or research purposes.

SHARING YOUR PERSONAL DATA

Except as specified in this Policy, we will not disclose your personal data to third parties without your consent. Depending on the services, we may share your personal data with:

1. Internal third parties such as companies within our group.
2. External third parties such as service providers (for example, Amazon Web Services, MailChimp), Kenya Revenue Authority, and Facebook Analytics.
3. Third parties to whom we may choose to sell, transfer, or merge parts of our business or assets.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

RETENTION OF DATA

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. Your personal data may be retained for a longer period where there has been a complaint or there is a prospect of litigation with respect to your use of the Site.

MARKETING

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving these communications.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

WEB ANALYTICS

Our website uses Google Analytics, a web analytics service provided by Google, Inc. Such use includes the 'Universal Analytics' mode of operation. This makes it possible, if a user is logged into a Google service, to assign data, sessions, and interactions across multiple devices to a pseudonymous user ID and thus analyze the user's activities across such devices.

Google Analytics uses cookies. The non-personal information generated by such cookies about your use of our website is usually transferred to a Google server in the USA and stored there. However, the corresponding IP addresses are anonymized beforehand using IP anonymization. The anonymized IP address transmitted by your browser under Google Analytics will not be merged with other Google data.

YOUR LEGAL RIGHTS

In accordance with the applicable laws of Kenya, you may have the right to:

1. Be informed of the use to which your personal data is being put.
2. Access your personal data.
3. Object to the processing of your personal data.
4. Request restriction of the processing of your personal data.
5. Request correction of false or misleading personal data.
6. Request the transfer of your personal data.
7. Request erasure of false or misleading personal data.
8. Withdraw consent at any time where we are relying on consent to process your personal data.

DATA SUBJECT ACCESS REQUEST

Right of access to your personal data: As a data subject, you are allowed to confirm the accuracy of your data and exercise your right of correction. You can request to see any personal data that we hold about you. To exercise your right to rectification, go to your Estate254 profile and edit your information. To request your data from Estate254, kindly reach out to admin@estate254.com, and we will respond to your request within 30 days.

Data Deletion Request (Right to be forgotten): As a data subject, you can request the deletion of your personal data from our system or withdraw consent to the processing of your personal information. If you wish to delete your data from the Estate254 website, kindly reach out to admin@estate254.com.

Data Retention: In any event, to the extent required or allowed by applicable law, the Data Processor, as defined as Estate254.com, may retain one copy of the Personal Data for evidence purposes and/or for the establishment, exercise, or defense of legal claims and/or to comply with applicable laws and regulations.

CHANGES TO THE PRIVACY POLICY

We regularly review and update this Policy to reflect changes to our practices, for operational, legal, or regulatory reasons, and for any other purpose. Any revisions to this Policy will be uploaded to the Site, and such upload will be deemed sufficient communication to you. Where you are a registered user, we may elect, at our discretion, to notify you of any revision through a notice on your account.