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1. Introduction Linkd values your privacy and is committed to safeguarding your personal information. This statement outlines how we collect, use, and protect your data in relation to our internet services.

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2. Data Collection We collect the following personal data:​

• Your preferences for particular products and services, based on information provided by you or from your use of Linkd'd (or third party) network, products and services.

• Name, family details, age, profiling information such as level of education, bank account status, income brackets, etc. collected as part of surveys conducted by Linkd and their agents on behalf of Linkd.

• Your contact with us, such as when you: call us or interact with us through social media, our chatbot, ‘snail mail’, email (we may record your conversations, social media or other interactions with us), register your biometric information such as your voice, finger prints.

• We use Closed Circuit Television (CCTV) surveillance recordings. CCTV Devices are installed at strategic locations to provide a safe and secure environment in all Linkd premises as a part of our commitment to community safety, security and crime prevention.

• We maintain a register of visitors in which we collect and keep your personal data such as names, company/institution details, telephone number, vehicle registration details and National ID number. This information is collected for health, safety and security purposes.

• When you use Linkd WIFI for guest and visitors, we collect email IDs and will provide user name and password. We record the device address and also log traffic information in the form of sites visited, duration and date sent/received.​

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This data is collected solely for business purposes, including account creation, service provision, billing, and responding to queries.

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3. Use of Data Linkd uses your personal data for the following purposes:

• Processing products and services that you have bought from Linkd or from third parties on our e-commerce platforms

• Billing you for using our or third-party products or services or taking the appropriate amount of credit from you;

• Responding to any of your queries or concerns;

• Verifying your identity information through publicly available and/or restricted government databases in order to comply with applicable regulatory requirements;

• Carrying out credit checks and credit scoring;

• 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 Linkd at any time to opt out of receiving marketing messages);

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

• In business practices including to quality control, training and ensuring effective systems operations;

• To protect our network including to manage the volume of calls, texts and other use of our network;

• To understand how you use our network, products and services for purposes of developing or improving products and services;

• Preventing and detecting fraud or other crimes and for debt recovery;

• For research, statistical, survey and other scientific or business purposes;

• Provide aggregated data (which do not contain any information which may identify you as an individual) to third parties for research and scientific purpose;

• Administer any of our online platforms/websites.

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3.4 Categories of Data

The categories of data collected include personal identification information (name, phone number, email address, physical address), contact information, and any correspondence between you and Linkd.

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3.5 Lawful Basis for Processing

Your Information Linkd processes your personal data based on the necessity to fulfill contractual obligations with you, to comply with legal obligations, and for legitimate business interests, such as improving our services and responding to your inquiries.

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4.0 Disclosure of Information

Any disclosure of your information shall be in accordance with applicable law and regulations. Safaricom shall assess and review each application for information and may decline to grant such information to the requesting party. We may disclose your information to:

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• law-enforcement agencies, regulatory authorities, courts or other statutory authorities in response to a demand issued with the appropriate lawful mandate and where the form and scope of the demand is compliant with the law.

• our subsidiaries, associates, partners, software developers or agents who are involved in delivering Linkd  products and services you order or use;

• Fraud prevention and Anti-money laundering agencies, credit-reference agencies;

• publicly available and/or restricted government databases to verify your identity information in order to comply with regulatory requirements;

• debt-collection agencies or other debt-recovery organisations;

• Survey agencies that conduct surveys on behalf of Linkd;

• Any other person that we deem legitimately necessary to share the data with.

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We shall not release any information to any individual or entity that is acting beyond its legal mandate. We will get your express consent before we share your personal data with any third party for direct marketing purposes.​

 

5. Data Security

We implement strict security measures to protect your data from unauthorized access, loss, or misuse.

 

6. Data Sharing

We do not share your personal data with third parties, except as required by law or for processing your service requests.

 

7. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, the need to comply with our internal policy and the applicable legal, regulatory, tax, accounting or other requirements.

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Anonymised information that can no longer be associated with you may be held indefinitely.

 

8. Your Rights

Subject to legal and contractual exceptions, you have rights under data protection laws in relation to your personal data. These are listed below: -

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• Right to be informed that we are collecting personal data about you;

• Right to access personal data that we hold about you and request for information about how we process it;

• Right to request that we correct your personal data where it is inaccurate or incomplete;

• Right to request that we erase your personal data noting that we may continue to retain your information if obligated by the law or entitled to do so;

• Right to object and withdraw your consent to processing of your personal data. We may continue to process if we have a legitimate or legal reason to do so;

• Right to request restricted processing of your personal data noting that we may be entitled or legally obligated to continue processing your data and refuse your request;

• Right to request transfer of your personal data in [an electronic format]

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If you wish to exercise any of the rights set out above, please contact us on info@linkd.co.ke.

 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

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We try to respond to all legitimate requests within reasonable time. Occasionally it could take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

9. Changes to this Statement

Linkd reserves the right to update this privacy statement. We will notify you of significant changes through our website or direct communication.

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10. Direct Marketing

You may be required to opt in or give any other form of explicit consent before receiving marketing messages from us.

 

You can ask us to stop sending you marketing messages at any time by writing to us or logging into our website. 

 

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product, service already taken up, warranty registration, product or service experience or other transactions].

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11. The Use of Cookies

We may store some information (using "cookies") on your computer when you visit our websites. This enables us to recognise you during subsequent visits. The type of information gathered is non-personal (such as: the Internet Protocol (IP) address of your computer, the date and time of your visit, which pages you browsed and whether the pages have been delivered successfully.

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We may also use this data in aggregate form to develop customised services - tailored to your individual interests and needs. Should you choose to do so, it is possible (depending on the browser you are using), to be prompted before accepting any cookies, or to prevent your browser from accepting any cookies at all. This will however cause certain features of the web site not to be accessible.

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12. The Use of Hyperlinks

Our websites may provide hyperlinks to other locations or websites on the Internet. These hyperlinks lead to websites published or operated by third parties who are not affiliated with or in any way related to us and have been included in our website to enhance your user experience and are presented for information purposes only.

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We do not endorse, recommend, approve or guarantee any third- party products and services by providing hyperlinks to an external website or webpage and do not have any co-operation with such third parties unless otherwise disclosed. We are not in any way responsible for the content of any externally linked website or webpage.

 

By clicking on a hyperlink, you will leave the Linkd webpage and accordingly you shall be subject to the terms of use, privacy and cookie policies of the other website that you choose to visit.

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13. International Data Transfers

From time to time we may need to transfer your personal information outside the Republic of Kenya. Where we send your information outside Kenya, we will make sure that your information is properly protected in accordance with the applicable Data Protection Laws.

 

14. Contact Us

If you would like to contact us on any topics in this privacy policy, you can email us at info@linkd.co.ke . 

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15. Right to Lodge Complaint

You have the right to lodge a complaint with the relevant supervisory authority that is tasked with personal data protection within the Republic of Kenya

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16. Non-Compliance with this Statement

Linkd shall have the right to terminate any agreement with you for failure to comply with the provisions of this statement and reject any application for information contrary to this statement.

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17. Amendments to this Statement

Linkd reserves the right to amend or modify this statement at any time. If Linkd amends this statement, You can access the most current version of the privacy statement by clicking this link Linkd Privacy Statement so that you will always know how your personal information is being used or shared.

 

Any amendment or modification to this statement will take effect from the date of notification on the Linkd website.

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18. Statement Effective Date

1st January 2023

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