Privacy Policy

Aletheia Foundation Limited (we) are committed to protecting and respecting your privacy.

SCOPE OF POLICY

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it.

INFORMATION WE COLLECT FROM YOU

1.1  We will collect and process the following data about you:

• Information you give us (Submitted information): This is information you give us about you by filling in forms on the Site and the Services Sites (together Our Sites), or by corresponding with us (for example, by e-mail or chat). It includes information you provide when you register to use the Our Sites, download or register an Site, subscribe to any of our Services, search for an Site or Service, make a purchase, share data via social media functions, enter a competition, promotion or survey, other activities commonly carried out in connection with an Site and when you report a problem with an Site, our Services, or any of our Sites. If you contact us, We will keep a record of that correspondence. The information you give us may include your name, address, e-mail address and phone number, the Device’s phone number, age, username, password and other registration information, financial and credit card information, personal description and photograph.

• Information we collect about you and your device. Each time you visit one of our Sites or use one of our Sites we will automatically collect the following information:

• technical information, including the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting;

• information stored on your Device, including contact information, friends lists, login information, photos, videos or other digital content, check ins;

• details of your use of any of our Sites or your visits to any of Our Sites including, but not limited to traffic data, weblogs and other communication data,]whether this is required for our own billing purposes or otherwise and the resources that you access.

• Location information. We also use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any

time.

• Information we receive from other sources (Third Party Information). We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

• Unique application numbers: when you install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.

DISCLOSURE OF YOUR INFORMATION

We will disclose the data we collect from you to the following third parties:

Category of data

Recipient

Purpose

You agree that we have the right to disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.

We will disclose your personal information to third parties:

• In the event that We sell or buy any business or assets, in which case We will disclose your personal data to the prospective seller or buyer of such business or assets.

• If Aletheia Foundation Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

• If We are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.

• In order to:

•enforce or apply the Our Terms of Use, and other agreements or to investigate potential breaches; or

•protect the rights, property or safety of Aletheia Foundation Limited, those interacting with Aletheia Foundation Limited, or others. This includes exchanging

information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

WHERE WE STORE YOUR PERSONAL DATA

The data that We collect from you will be transferred to, and stored at, a destination outside the European Economic Area (EEA). It will also be processed by staff operating outside the EEA who work for us or for one of our suppliers. These staff may be engaged in the fulfilment of your request, order or reservation, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology or Alternative Encryption Technology Used. Where We have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect your personal data, We cannot guarantee the security of your data transmitted to Our Sites; any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access.

Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

YOUR RIGHTS

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if We intend to use your data for such purposes or if We intend to disclose your information to any third party for such purposes.

Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the Site or the Services are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that We do not accept any responsibility or liability for these policies or for any personal data that may be collected

through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.

ACCESS TO INFORMATION

Your right of access can be exercised in accordance with the law. Any access request will be subject to a fee of KES. 1,500.00 to meet our costs in providing you with details of the information We hold about you.

CHANGES TO PRIVACY POLICY

Any changes We may make to our privacy policy in the future will be posted on this page and, where appropriate, you be notified via email. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the Site or the Services.

CONTACT

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to gen@aletheiafdn.org.