Introduction

This data policy describes our policies and procedures for the collection, use, and disclosure of your information when you use our services and tells you about your privacy rights and how the law protects you.

We use your data to provide and improve our services. By using our services, you agree to the collection and use of information in accordance with this data policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or plural.

Definitions

  • ‘Account’ means a unique account created for you to access our services or parts of our services.
  • ‘Company’ (referred to as either “the company,”, “we,”, “us,” or “our” in this agreement) refers to Private Capital Support, Timau Plaza, Argwings Kodhek Road, Nairobi, Kenya.
  • ‘Cookies’ are small files placed on your computer, mobile device, or any other device by a website, containing the details of your browsing history on that website, among its many uses.
  • ‘Country’ refers to any country across the globe
  • ‘Device’ means any device that can access the service, including a computer, a cellphone, or a digital tablet.
  • ‘Personal data’ is any information that relates to an identified or identifiable individual.
  • ‘Service’ refers to any of our digital platforms including but not limited to websites, call for application platform, academy
  • ‘Person’ means any natural or legal person who processes the data on behalf of the company. It refers to third-party companies or individuals employed by the company to facilitate the service, to provide the service on behalf of the company, to perform services related to the service, or to assist the company in analyzing how the service is used.
  • ‘Usage data’ refers to data collected automatically, either generated by the use of the service or from the service infrastructure itself (for example, the duration of a page visit).
  • ‘Website’ refers to any sites under or related to Private Equity Support, including those accessible from https://www.privateequity-support.com/ and its subdomains.
  • “You” means the individual accessing or using the service, or the company or other legal entity on behalf of which such individual is accessing or using the service, as applicable.

Who We Are

We are Private Equity Support (PES), with our registered office at Timau Plaza, Argwings Kodhek Road, Nairobi, Kenya. We are the data controller in charge of your personal information when you subscribe to, access, or use any of our services, whether you reside in Kenya or another nation. One can subscribe to our services over the phone, on websites, or through personal contact. Our information practices, including the information we process to enable our services, are explained in our data policy (“data policy”). We discuss, for instance, the information we gather and how it impacts you. We also go over the precautions we take to keep your privacy safe. Unless otherwise noted, all PES services are covered by this privacy statement.

Collecting and Using Your Personal Data

Policy Number: PES/ICT/001/2023

Policy Date: 11/2023

Types of Data Collected

Personal Data

While using our services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally, identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Usage Data

Usage Data

Usage data is collected automatically when using such services such as the website. Usage data may include information such as your device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.

Customer Support (Communication Data)

You may provide us with information related to your use of our services, including copies of your messages and how to contact you so we can provide you with customer support. For example, you may send us an email with information relating to our service performance or other issues.

Tracking Technologies and Cookies

We use cookies and similar tracking technologies to track activity on our website and store certain information. The tracking technologies used are scripts to collect and track information and to improve and analyze our services. The technologies we use may include:

  • Cookies or browser cookies. A cookie is a small file placed on your device. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some parts of our service. Unless you have adjusted your browser setting so that it will refuse cookies, our service may use cookies.

Cookies can be “persistent” or “session” cookies. Persistent cookies remain on your personal computer or mobile device when you go offline, while session cookies are deleted as soon as you close your web browser. Learn more about cookies in the Privacy Policies website article.

We use both session and persistent cookies for the purposes set out below:

  • Necessary / Essential Cookies
    Type: Session Cookies
    Administered by: PES
    Purpose: These cookies are essential to provide you with services available through the website and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
  • Cookies Policy / Notice Acceptance Cookies
    Type: Persistent Cookies
    Administered by: PES
    Purpose: These cookies identify if users have accepted the use of cookies on the website.
  • Functionality Cookies
    Type: Persistent Cookies
    Administered by: PES
    Purpose: These cookies allow us to remember choices you make when you use the website, such as remembering your login details or language preference. The purpose of these cookies is to provide you with a more personal experience and to avoid having to re-enter your preferences every time you use the website.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our data policy.

Government Generated Information

  • National ID Number
  • Tax PIN
  • Passport Details
  • NHIF & NSSF Details.

Business Related Data

  • Bank Account: Financial holdings, account
  • Investments: Assets
  • Payment card number: Credit card credentials
  • Bank account number and account details: Account identifier, account specifics
  • Income: Earnings
  • Other financial information

Employment and Educational Information

  • Employment history
  • Educational background
  • Banking information
  • Next of Kin Contact
  • Education certification

 

Our Data Sources

We utilize Personal Information for conducting our business activities. The specific purposes for using your Personal Information will vary depending on our relationship with you (e.g. Members, Employees, Business Partners, Prospective Members, etc.) and the nature of our interactions and the services we offer.

We gather Personal Data from a variety of sources, which may include (depending on your location):

  • Individuals and their family members, through: Online, telephone, or written communication
  • Experts (including financial experts)
  • Our partners
  • Application forms, Proposal Forms, and other forms that you complete
  • Software applications (apps) provided by us
  • Our Website (https://www.privateequity-support.com/)
  • Meetings, telephone conversations, and other types of communication
  • Social media applications and/or tools

Use of Your Personal Data

Policy Number: PES/ICT/002/2023

Policy Date: 11/2023

The company may use personal data for the following purposes

  • To provide and maintain our service, including monitoring the usage of our services.
  • To manage your account so as to manage your registration as a user of the service. The personal data you provide can give you access to different functionalities of the service that are available to you as a registered user.
  • To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products, or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To provide you with news, special offers, and general information about other goods, services, and events that we offer that are similar to those that you have already purchased or inquired about, unless you have opted not to receive such information.
  • To manage your requests to us.
  • For business transfers. We may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us about our service users is among the assets transferred.
  • For other purposes such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and evaluating and improving our service, products, services, marketing, and your experience.
  • Communicating with customers, business partners, and employees
  • Assessing and making determinations on providing financial products or services
  • Enhancing and improving product and service offerings
  • Fulfilling regulatory requirements
  • Responding to feedback, queries, and complaints

We may share your personal information in the following situations:

  • With Service Providers: We may share your personal information with service providers to monitor and analyze the use of our service and to contact you.
  • For business transfers: We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • With Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honour this data policy. Affiliates include our parent company and any other subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
  • With business partners: We may share your information with our business partners to offer You certain products, services, or promotions.
  • With other users: When you share personal information or otherwise interact in public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
  • With your consent: We may disclose your personal information for any other purpose with Your consent.

 

Retention of Your Personal Data

Policy Number: PES/ICT/003/2023

Policy Date: 11/2023

The company will retain your Personal Data only for as long as is necessary for the purposes set out in this data policy. We will retain and use your data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The company will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer periods.

Transfer of Your Personal Data

Policy Number: PES/ICT/004/2023

Policy Date: 11/2023

Your information, including Personal Data, is processed at the company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to and maintained on computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

Your consent to this data policy followed by your submission of such information, represents your agreement to that transfer.

The company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this data policy and no transfer of your personal data will take place to an organization or a country unless there are adequate controls in place, including the security of your data and other personal information.

Deleting Your Personal Data

Policy Number: PES/ICT/005/2023

Policy Date: 11/2023

You have the right to delete or request that we assist in deleting the personal data that we have collected about you. Our service may give you the ability to delete certain information about you from within the service.

You may update, amend, or delete your information at any time by signing in to your Account, if you have one, and visiting the account settings section that allows you to manage your personal information. You may also contact us to request access to, correct, or delete any personal information that you have provided to us.

Please note, however, that we may need to retain certain information when we have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

Policy Number: PES/ICT/006/2023

Policy Date: 11/2023

Business Transactions

  • If the company is involved in a merger, acquisition, or asset sale, your personal data may be transferred. We will provide notice before your personal data is transferred and becomes subject to a different data policy.
  • Performance of our contract with client
  • To establish, defend or prosecute legal claims

Law enforcement

Under certain circumstances, the company may be required to disclose your personal data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

Security of Your Personal Data

Policy Number: PES/ICT/007/2023

Policy Date: 11/2023

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect Your Personal Data, we cannot guarantee its absolute security.

How The General Data Protection Regulation And Data Protection Act, 2019 (Laws Of Kenya) Apply to you

Our Lawful Foundations for Information Processing

We gather, use, and disclose the information we have as previously mentioned:

  • as required to carry out our obligations under the terms of our agreement;
  • following your consent, which you may withdraw at any time; as required to meet our legal requirements;
  • on occasion to safeguard your or others’ vital interests;
  • as required in the public interest; and
  • as required for our (or others) legitimate interests, including our interests in offering our users and partners a cutting-edge, pertinent, safe, and lucrative service, unless those interests are superseded by yours or fundamental rights and freedoms that demand the protection of personal data.

Your Data Protection Rights

Description

Applicability

Right to object to processing of personal data

You have the right to object to the processing of your personal data. This right is not absolute, and we may reject the request if we have justifiable reasons for processing that override your interests. However, this right is absolute in relation to direct marketing.

Right to restrict processing of personal data

You have the right to request the suspension of processing of your personal data in certain circumstances, such as when you contest the accuracy of your personal data or when your personal data has been unlawfully processed.

Right to access personal data

You have the right to access your personal data and obtain information about how it is used and processed. You may access your personal data through our Self-Service Portals or use a provided form for access in other formats, subject to availability and notice.

Right to rectification of personal data

You have the right to request correction of your personal data if it is inaccurate or incomplete.

Right to data portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format and transmit it to another third party, provided it is technically feasible for us to provide the data in the required format.

Right to erasure

You have the right to request deletion or removal of your personal data from our records, with some exceptions such as for freedom of expression and information, compliance with legal obligations, public interest, or defense of legal claims.

Right to complain to the Office of the Data Commissioner

You have the right to lodge a complaint with the Office of the Data Commissioner.

Right to withdraw consent to processing of personal data

You have the right to withdraw consent to the processing of your personal data, where applicable.

Rights relating to automated decision making and profiling

You have the right not to be subjected to a decision based solely on automated processing that significantly affects you, with exceptions for contractual necessity, legal authorization, or consent.

Exercising Your Rights

You have the right to restrict and object to specific processing of your information, as well as the right to access, rectify, port, and erase it in accordance with the General Data Protection Regulation and other applicable local laws. This covers the ability to object to the use of your information for direct marketing purposes as well as the ability to object to the use of your information where we are processing it to further our legitimate interests or the interests of a third party, or to carry out a duty in the public interest.

You have the right to object to the processing of your information if it is processed for our legitimate interests, the legitimate interests of a third party, or the public interest. In such case, we shall stop processing your information unless processing is required by law or is based on compelling valid grounds. By going to https://applications.privateequity-support.com/privacy/ , you may also learn more about your options for limiting how we use your information and object to the way we treat it. If we use your information for direct marketing related to our services, you always have the option to object and use the unsubscribe link in such communications to stop receiving future marketing messages.

Transfer of Your Personal Data

Private Equity Support may transfer your personal information to facilitate the implementation, administration, and security of any product or service you have applied for or for other purposes outlined in this privacy statement. We may transfer or disclose the personal data we collect to regulatory or supervisory authorities, third-party contractors, subcontractors, and/or their subsidiaries and affiliates who provide support to Private Equity Support in delivering its services. The third-party providers may employ their own subcontractors with access to personal data (sub-processors). Our policy is to engage third-party providers who are obligated to uphold appropriate levels of security and confidentiality, process personal information as directed by Private Equity Support, and extend these same obligations to their sub-processors.

Cross-border Transmission of Your Personal Data

Your data is mainly stored in our data centers accessed through our Kenyan offices. Occasionally, there may be a necessity to transfer your personal information outside of your country. This may involve countries that do not have specific laws offering protection for your personal data.

When we transmit your information to a different country, we will ensure that there are adequate data protection measures in place in the receiving country or obtain your consent for the transfer of your personal information. Before transferring personal data outside your country, we will ensure that the transfer complies with the applicable legal and regulatory standards. The circumstances under which we may transfer your personal data outside are outlined as follows:

 

  • Ensuring appropriate data protection measures in the jurisdiction to which the data is transferred, ensuring security and protection of personal data. Storing your personal data in a cloud with data servers located in a European country that has implemented the General Data Protection Regulation (GDPR).
  • An adequacy decision made by the Office of the Data Commissioner When the Data Commissioner has listed countries with suitable data protection measures and we choose to store your data in such a jurisdiction in line with our legitimate interest.
  • Upon receiving your explicit consent, we move your personal data to a different legal jurisdiction.

Retention of Personal Data

Private Equity Support retains Personal Data for the duration necessary to fulfill the purpose for which it was collected and to meet legal, regulatory, and operational obligations. The retention periods may vary for each financial product purchased. Following the retention period, anonymized data is retained for management information purposes. Private Equity Support has established a Data Retention policy to align with Data Protection laws.

Private Equity Support may also retain your contact information to send you notifications about various products, renewal notices, and product updates.

You are responsible for maintaining the confidentiality of any password used to access specific products or services. Please be aware that our customer service agents will never ask you to divulge your password.

 

Our Global Partners

By virtue of this Privacy Policy, PES can share information worldwide, both internally inside the organization and externally with our partners and individuals you connect with globally. For the purposes outlined in this Privacy Policy, information under PES’s control may be moved, communicated, kept, or processed in the Republic of Kenya or other nations outside of your home country. These data transfers are required for us to function globally and offer our services to you, as well as for the services described in our Terms. When we process personal data from another jurisdiction where there isn’t as much protection for it, we’ll make sure it’s appropriately safeguarded by putting in place the necessary precautions, such as contractual obligations. We make sure your personal information is safe by enforcing uniform guidelines on all of our partners regarding the processing of your personal information.

Children’s Privacy

Our service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and know that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from anyone under the age of 13 without verification of parental consent, we will take steps to remove that information from our servers.

If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent’s consent before we collect and use that information.

Links to Other Websites

Our service may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third-party’s site. We strongly advise you to review the data policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Changes to this data policy

We may update our data policy from time to time. We will notify you of any changes by posting the new data policy on this page.

We will let you know via email and/or a prominent notice on our service prior to the change becoming effective and update the “Last updated” date at the top of this data policy.

You are advised to review this data policy periodically for any changes. Changes to this data policy are effective when they are posted on this page.

 

 

Contact Us

If you have any questions about this data policy, you can contact us: