INTRODUCTION

Thank you for choosing to be part of our community at Spring on the Go. We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this policy or our practices regarding your personal information, please contact us at help@springonthego.co.ke

When you visit our website www.springonthego.co.ke (the "Site") and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy notice, we describe our privacy policy, aiming to explain clearly what information we collect, how we use it, and what rights you have in relation to it. We encourage you to read through this policy carefully. If you do not agree with any terms in this policy, please discontinue use of our Site and services.

This privacy policy applies to all information collected on or through our website and any related services, sales, marketing, or events (collectively referred to in this policy as the "Sites").

We are a “data controller” in relation to the processing activities described below. This means that we determine the purpose and means of processing your personal information (or personal information you provide).

WHAT INFORMATION DO WE COLLECT?

Personal Information You Disclose to Us

“Personal information” means any information that can be used to identify an individual natural person. Please note that there are "special categories" of personal information that are more sensitive and require a higher level of protection. The personal information we collect will vary according to the circumstances surrounding our relationship with you.

We collect personal information that you voluntarily provide to us when you register on the Site, express interest in obtaining information about us or our products and services, participate in activities on the Site (such as entering competitions, contests, or giveaways), permit third parties to provide information to us, or contact us.

The personal information we collect may include the following:

• Name and Contact Data: First and last name, email address, postal address, phone number, and other similar contact data.
• Communications Data: Information contained in voice, messaging, letter, email, and other communications we have with you. We may also keep records of our meetings and conversations whether with you or with other third parties about you or the good or services that they provide. Please note that as required and/or permitted by law, we also may monitor and record your telephone, email, instant messaging, and other online communications with us in connection with our operations.
• Monitoring Data: (i) Information about your use of our information and communications systems, including your website and system interaction (cookies, internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and similar technologies). (ii) Information received in response to any surveys or complaint claims. (iii) Information gathered through CCTV and building access information.
• Marketing Data: Such as your preferences for receiving marketing from us and our third parties and your communication preferences.

All personal information you provide must be true, complete, and accurate, and you must notify us of any changes to such information.

If you do not provide us with the requested personal information needed for our operational purposes, we may not be able to appropriately provide you with the services you require or adequately assist you.

If parental consent is required in respect of our use in relation to a user’s personal information (who is below the age of 18 years), when using our Site, the child must provide their parent’s email address. We use that email address to contact the child’s parent to ask for their consent as required – we also explain to the parent:

•          what personal information we collect about their child;

•          how we use it and why; and

•          how the parent can revoke their consent and/or ask that we delete their child’s account and personal information.

Parental consent can be limited to restricting disclosure of the child’s personal information to third parties by contacting us.

Information Automatically Collected

We automatically collect certain information when you visit, use, or navigate the Sites. This information does not reveal your specific identity (like your name or contact details) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, and other technical information. This data is primarily used to maintain the security and operation of our Sites and for internal analytics and reporting.

Like many businesses, we also collect information through cookies and similar technologies.

Information Collected from Other Sources

To the extent permitted by law, we may obtain limited data from public databases, marketing partners, social media platforms, and other outside sources. Examples include:

• Social media profile information (your name, gender, birthday, email, current city, user identification numbers for your contacts, profile picture URL, and any other information you choose to make public)
• Marketing leads and search results, including paid listings (such as sponsored links)

HOW DO WE USE YOUR INFORMATION?

We use personal information collected via our Sites for various purposes, including:

• Registration and verification:  we may use your personal information to enable you to use the services available through the Sites, including registering you for our services and verifying your identity and authority to use our services.
• Payment and billing: We may use your information to process billing and payment including sharing with third-party payment gateways and payment service providers in connection with the Sites;
• Marketing and Promotional Communications: We and/or our third-party marketing partners may use your personal information for marketing purposes, in line with your preferences. You can opt out of marketing emails at any time (see "Your Privacy Rights" below).
• Administrative Information: We may use your information to send you product, service, and feature updates or changes to our terms, conditions, and policies.
• Testimonials: With your consent, we may post testimonials on our Sites that contain personal information. To update or delete a testimonial, please contact us.
• Targeted Advertising: We may use your information to develop and display content and advertisements tailored to your interests and to measure their effectiveness.
• Competitions and Giveaways: Your information may be used to administer prize draws and competitions.
• Feedback Requests: We may use your information to request feedback and contact you about your experience with our Sites.
• Site Security: Your data helps us keep our Sites safe and secure (for example, for fraud monitoring and prevention).
• Legal Obligations: We may use your information to comply with legal requests and prevent harm.
• Business Purposes: We may use your data for data analysis, usage trend identification, promotional campaign effectiveness, and overall service improvement.

WHAT IS THE LEGAL BSIS FOR PROCESSING YOUR PERSONAL INFORMATION?

We will only collect, use, and share your personal information (or personal information you provide) where we are satisfied that one of the following legal grounds apply to a specific processing activity:

• The processing is necessary for the performance of a contract to which you are a party or to take steps, at your request, prior to entering such contract.
• The processing is necessary for the legitimate interests pursued by us or those of a third party to whom personal information is disclosed, except where such interests are overridden by your interests or rights and freedoms which require protection of personal information. We believe that we have a legitimate interest in processing personal information for the purposes set out above, and to support the achievement of our immediate and long-term business goals and outcomes.
• The processing is necessary for us to comply with a legal obligation to which we are subject, for example, providing information on request to government entities or regulatory authorities; and conducting compliance activities such as audit and reporting, maintenance of accounting and tax records or anti-money laundering.
• The processing is based on your consent. We will rely on your consent as a lawful basis for processing personal information, as appropriate, including the processing of personal information relating to a child, processing sensitive personal information outside Kenya, processing your personal information for the purpose of direct marketing to you and where you have provided us with your consent.

Where you have provided your consent to the processing of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Please note that by withdrawing your consent, the withdrawal will not render unlawful our prior processing of your personal information or the processing which is based on other legal bases for processing of your personal information.

• The processing is necessary to protect your interests (or someone else’s interests).

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information (or personal information you provide).

 

WILL YOUR INFORMATION BE SHARED WITH ANYONE?

We only share your information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations. We may share your data in the following situations:

• Compliance with Laws: If legally required, we may disclose your information to comply with legal processes or governmental requests.
• Legal Rights and Vital Interests: We may disclose your information to investigate violations of our policies, prevent fraud, or respond to potential threats.
• Third-Party Service Providers: Your data may be shared with vendors and contractors who perform services for us, such as payment processing, email delivery, and marketing.
• Business Transfers: In the event of a merger, sale of company assets, or acquisition, your data may be transferred.
• Third-Party Advertisers: We may use third-party companies to serve ads on our Sites, collecting data through cookies and tracking technologies.
• Affiliates: We may share your information with affiliates, ensuring they comply with this privacy policy.
• Business Partners: We may share your data to offer certain products, services, or promotions.
• Consent: Your information may be shared for other purposes with your explicit consent.
• Public Interaction: Any personal information shared in public areas of our Sites may be visible to other users and may be publicly distributed.

Please note that if you request us, in writing, to share your personal information (or personal information you provide) with third parties, we will follow your request to share the relevant information. However, we do not have control over how those third parties will use your information. Before you make your request, we recommend that you (or the person acting on your behalf) consider the data protection practices of that third party by reading their privacy policies or contacting them.

COOKIES

Please note that in order to improve our internet service to you, we will occasionally use a “cookie” and/or other similar technologies which may place certain information on your computer’s hard drive when you visit our website or any of our affiliated websites.

A cookie is a small amount of data that our web server sends to your web browser when you visit certain parts of our site.

We may collect cookies through, inter alia:

• information about your use of our services and about the device you use to access our services,
• the pages you request and visit and any posts you submit,
• information on your interaction with other pages,
• information obtained during maintenance or support of our website,
• information about your device such as MAC and IMEI numbers, your IP address, and the URLs of sites from which you arrive or leave our website, and
• your type of browser, your operating system, your mobile or internet service provider and the make and size of your device (such as for page displays and interoperability).

We use cookies to do many different jobs, like letting you navigate between pages efficiently, identifying you after you have logged in by storing a temporary reference number in the cookie, allowing you to access stored information if you register for any of our online platforms, and generally improving your online experience.

Cookies do not enable us to gather personal information about you unless you give the information to our server. Most Internet browser software allows the blocking of all cookies or enables you to receive a warning before a cookie is stored.

CROSS BORDER TRANSFER OF PERSONAL INFORMATION

We may transfer your personal information (or personal information you provide) to regulatory, prosecuting, tax and governmental authorities, courts and other tribunals, and other entities located in countries outside Kenya including countries which have different data protection standards to those which apply in Kenya.

THIRD-PARTY WEBSITES

Our Sites may contain advertisements from third parties that are not affiliated with us. We cannot guarantee the safety of information you provide to third parties, and their data collection is not covered by this privacy policy. You acknowledge that any third party links or websites provided on our Site is only as a convenience to you, and further agree that we are not responsible for the content of such external websites or the protection and privacy of information you provide while visiting such external third party websites.  Please review their terms of use and privacy policies or notices directly.

This Policy does not govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device you use to access the Sites by non-affiliated, third-party ad technology, ad servers, ad networks or any other non-affiliated third parties. Those parties that use these technologies may offer you a way to opt out of targeted advertising as described below. Please review those parties' terms of use and privacy policies for information about the personal information that they collect when registering for an account with them.

HOW WE PROTECT PERSONAL INFORMATION

We maintain physical, technical, and organisational safeguards to secure your personal information from unauthorized access, use, alteration and destruction. However, we cannot be held responsible for unauthorised or unintended access to your personal information that is beyond our control but we will inform you and/or any relevant authority of any unauthorised or unintended access to your personal information within a reasonable time and we will seek to remedy the situation to the extent possible and within the possible timelines.

HOW LONG DO WE KEEP YOUR INFORMATION?

We retain your personal information only as long as necessary to fulfill the purposes outlined in this policy and to comply with the applicable record retention legal requirements. When deciding how long to keep your personal information after our relationship with you has ended, we take into account our legal obligations and regulators' expectations.

We may retain your personal information (or personal information you provide) for a longer period if the retention is:

·       required or authorised by law,

·       reasonably necessary for a lawful purpose,

·       authorised or consented by you,

·       for personal information that has been anonymised, or

·       for historical, statistical, journalistic, literature and art or research purposes.

In some circumstances we may anonymise your personal information (or personal information you provide) so that it can no longer be associated with you, in which case we may use such information without further notice to you.

YOUR PRIVACY RIGHTS

You have the right to:

• Be informed of the use to which your personal information (or personal information you provide) is to be used.
• Request access to the personal information we hold about you and receive a copy of the personal information we hold about you.
• Correct or delete your personal information.
• Withdraw consent to process your personal information .
• Lodge a complaint with a data protection authority.
• Request the restriction of processing of your personal information (or personal information you provide). This enables you to ask us to suspend the processing of your personal information (or personal information you provide).
• Request us to transfer personal information either to you or to another company in a commonly used electronic format. This is known as the right to data portability.
• Object to the processing of your personal information (or personal information you provide).
• Object and opt-out of our direct marketing services.
• Request not to be subject to automated decision making. This enables you to ask us not to make a decision about you that affects your legal position (or has some other significant effect on you) based purely on automated processing of your information.

To exercise any of these rights, please contact us at help@springonthego.co.ke

We will respond to your request without undue delay and no later than the time periods stipulated by the applicable Data Protection Legislation.

UPDATES TO THIS POLICY

We may update this privacy policy from time to time to reflect changes in our practices, legal requirements, or other operational reasons. The updated version will be indicated by a "Revised" date and will be effective as soon as it is accessible. We encourage you to review this policy frequently. Use of the Sites following such changes constitutes your acceptance of the revised privacy policy then in effect.

CONTACT US

If you have any questions or comments about this policy, please contact us at:

Spring on the Go
Email: help@springonthego.co.ke
Website: www.springonthego.co.ke

By using our Sites, you consent to this Privacy Policy.

This Privacy Policy ensures your personal information is respected and protected. Thank you for trusting Spring on the Go.