This policy was last updated July 20, 2022.
We’re committed to protecting your rights and freedoms with regards to your personal data. In this document, we will explain how we collect, use and protect your personal data and also explain what rights you have with regards to your personal data and how you can exercise those rights.
This Policy applies as between you, the User of this Web Site and Cyinetmax Cybersecurity Solutions Ltd. the owner and provider of thisWeb Site. This Policy applies to our use of any and all data collected by us in relation to your use of the Web Site and any Services or Systems therein.
1.1 Our website is not intended for children and we do not knowingly collect data relating to children.
1.3 CyiGlobal Ltd. is the controller and responsible for your personal data (we, us or our).
1.6 You have the right to make a complaint at any time to the ICO). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
1.7 It is important that the data we hold about you is accurate and current, therefore please keep us informed of any changes to your personal data.
2.1 We may collect, use, store and transfer the types of personal data about you listed in Part 1 of Schedule 1.
2.2 We may also collect, use and share aggregated data. However, if we combine aggregated data with your personal data so that it can directly or indirectly identify you, we treat this as your personal data.
2.3 We do not collect any special categories of personal data.
2.4 If we are required by law, or under the terms of a contract we have with you, to collect your personal data and you fail to provide it, we may not be able to enter into, perform the contract with you and, we may have to cancel a product or service. We will notify you of this at the relevant time.
We collect personal data in the following ways:
|Direct Interactions||You may provide personal data when you complete online forms, request products/services, subscribe to our services, create a user account, join our mailing list or otherwise or correspond with us (by post, phone or email)|
|Automated Technology||We automatically collect personal data (technical and usage) when you browse or interact with our website, by using cookies and other similar technologies. We may also receive technical data about you if you visit other websites which use our cookies.|
|Publicly Available Sources||We may collect personal data from publicly availably sources such as credit reference agencies|
|Third Parties||We may receive personal data from: (a) analytics providers based outside the EU (such as Google); (b) advertising networks inside or outside EU; and (c) search information providers inside or outside EU; (d) our suppliers such as payment providers, delivery services, website support and maintenance providers.|
4.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data:
4.1.1 To perform the contract, we are to enter into or have entered into with you;
4.1.2 To comply with a legal obligation; and ;
4.1.3 Where it is necessary to carry out our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
4.2 Part 2 of Schedule 1 sets out the lawful basis we will rely on to process your personal data.
4.3 We do generally only rely on consent as a legal basis for processing your personal data to send email and SMS marketing communications and you have the right to withdraw your consent at any time by contacting us. Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your information.
4.4 We may analyse your personal data to form a view on what products and or services we think may be of interest to you. You will only receive marketing communications from us, if you have requested information from us or purchased services from us, if you consent to marketing at the time we collect your personal data and you have not subsequently opted out or withdrawn your consent or if we have another basis to send you the marketing communications.
4.5 We will not share your personal data with third parties for their marketing purposes.
4.6 You can opt out of email marketing by clicking the unsubscribe button within the marketing email. You can also withdraw your consent to marketing at any time by writing to us at email@example.com
4.7 Even if you opt out of receiving marketing, we may still use your personal data for other purposes provided we have a lawful basis to do so.
4.8 We will only use your personal data for the purpose that we originally collected it for, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
4.9 If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to use your personal data in this manner.
4.10 We may process your personal data (without your knowledge or consent) where this is required or permitted by law.
5.1 We may have to share your personal data with third parties further details of which are set out in Part 4 of Schedule 1. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes. They can only process your personal data for specified purposes and in accordance with our instructions.
6.1 We have no locations outside of the Kenya, and the personal information that we collect may be stored on servers located in the Kenya or in any other country in which Cyinetmax Cybersecurity Solutions Ltd., its affiliates, partners, service providers, or agents maintain facilities. This means that your personal information may be collected, processed, and stored in such locations which may have data protection laws that are different from (and sometimes less protective than) the laws of your country or region, such as the General Data Protection Regulation (“GDPR”).
7.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We also limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know and they can only process your personal data on our instructions and will be subject to a duty of confidentiality.
7.2 We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
8.2 We are legally required to keep basic information about our customers (including contact, identity, financial and transaction data) for six years after they cease being customers, for tax purposes.
8.3 Additionally, we cannot delete information when it is needed for the establishment, exercise, or defense of legal claims (also known as a “litigation hold”). In this case, the information must be retained as long as needed for exercising respective potential legal claims.
8.4 In some instances, we may choose to anonymize your personal data instead of deleting it, for statistical use, for instance. When we choose to anonymize your personal data, we make sure that there is no way that the personal data can be linked back to you or any specific user.
9.1 You have certain rights in certain circumstances under data protection law. These are set out in full in Part 3 of Schedule 1. If you wish to exercise any of your rights, please contact us at firstname.lastname@example.org
9.2 You will not have to pay a fee to exercise any of your rights. However, if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee for this information or refuse to comply with your request.
9.3 We may request specific information from you to help us confirm your identity when you contact us and ensure. This is a security measure to ensure that personal data is not disclosed to any person who does not have the right to receive it.
9.4 We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month 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.
|Contact Data||Billing information including address, delivery address, email address and telephone number|
|Financial Data||Bank account details or other payment information as required|
|Identity Data||First name, maiden name, last name, username or similar identifier|
|Marketing and Communication Data||Your communication preferences to receive updates or marketing information from us and/or our third parties|
|Profile Data||Your username and password, information required to complete a purchase or orders made by you, contact preferences, feedback and survey responses|
|Technical Data||Internet Protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website|
|Transaction Data||Details about payments to and from you and other details of products and services you have purchased from us|
The lawful basis upon which we may rely on to process your personal data are:
|Consent||You have given your express consent for us to process your personal data for a specific purpose|
|Contract||The processing is necessary for us to perform our contractual obligations with you under our contract, or because you have asked us to take specific steps before entering into a contract with you|
|Legal Obligation||The processing is necessary for us to comply with legal or regulatory obligation.|
|Legitimate Interests||The processing is necessary for our or a third party’s legitimate interest e.g. in order for us to provide the best service to you via our website. Before we process your personal data on this basis we make sure we consider and balance any potential impact on you, and we will not use your personal data on this basis where such impact outweighs our interest|
Set out below are specific details of the processing activities we undertake with your personal data and the lawful basis for doing this.
|Purpose/Activity||Types of Data||Lawful Basis for Processing|
|To register you as a new customer||Identity & contact||To perform our contract with you|
|To process and deliver your order, manage payments, fees and charges and debt recovery||Identity, contact, financial, transaction and marketing & communications||(i) To perform our contract with you; (ii) As necessary for our legitimate interest in recovering debts due to us.|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||Identity, contact & technical||(i) as necessary for our legitimate interests in running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise (ii) as necessary to comply with any legal obligations|
|To deliver relevant website content/advertisements to you and measure or understand the effectiveness of our advertising||Identity, contact, profile, usage, marketing & communications & technical||As necessary for our legitimate interests in studying how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||Technical & usage||As necessary for our legitimate interests to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy|
|To make suggestions and recommendations to you about goods or services that may be of interest to you, including promotional offers||Identity, contact, technical, usage & profile||As necessary for our legitimate interests to develop our products/services and grow our business|
You have the following legal rights in relation to your personal data:
|Access Your Data||You can ask for access to and a copy of your personal data and can check we are lawfully processing it|
|Correction||You can ask us to correct any incomplete or inaccurate personal data we hold about you|
|Erasure||You can ask us to delete or remove your personal data where: (a) There is no good reason for us continuing to process it; (b) You have successfully exercised your right to object (see below); (c) We may have processed your information unlawfully; or (d) We are required to erase your personal data to comply with local law. (e) We may not always be able to comply with your request for specific legal reasons, which will be notified to you at the time of your request|
|Object||You can object to the processing of your personal data where: (a) Where we are relying on our legitimate interest (or those of a third party) as the basis for processing your personal data, if you feel it impacts on your fundamental rights and freedoms; (b) Where we are processing your personal data for direct marketing purposes. (c) In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms, and, in such circumstances, we can continue to process your persona data for such purposes|
|Request a Transfer||You can request a transfer of your personal data which is held in an automated manner and which you provided your consent for us to process such personal data or which we need to process to perform our contact with you, to you or a third party. We will provide your personal data in a structured, commonly used, machine-readable format|
|Withdraw Your Consent||You can withdraw your consent at any time (where we are relying on consent to process your personal data). This does not affect the lawfulness of any processing carried out before you withdraw your consent|
|Service Providers||Acting as processors or controllers based in the EEA but also around the world who provide IT and systems administration as well as services that supporting our business.|
|Professional Advisors||Including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services|
|HM Revenue & Customs, Regulators and Other Authorities||Based in the EEA who require reporting of processing activities in certain circumstances|
|Others||Include market researchers, fraud prevention agencies|
|Aggregated Data||Information such as statistical or demographic data which may be derived from personal data, but which cannot by itself identify a data subject|
|Controller||A body that determines the purposes and means of processing personal data|
|Data Subject||An individual living person identified by personal data (which will generally be you)|
|Personal Data||Information identifying a data subject from that data alone or with other data we may hold but it does not include anonymised or aggregated data|
|Processor||A body that is responsible for processing personal data on behalf of a controller|
|Special Categories of Personal Data||Information about race, ethnicity political opinions, religious or philosophical beliefs, trade union membership, health, genetic, biometric data, sex life, sexual orientation.|
|ICO||Information Commissioner’s Office, the UK’s supervisory authority for data protection issues|
11.2 The following types of cookies may be used when you visit our Site:
11.2.1 Advertising Cookies. Advertising cookies are placed on your computer by advertisers and ad servers in order to display advertisements that are most likely to be of interest to you. These cookies allow advertisers and ad servers to gather information about your visits to the Sites and other websites, alternate the ads sent to a specific computer, and track how often an ad has been viewed and by whom. These cookies are linked to a computer and do not gather any personal information about you.
11.2.2 Analytics Cookies. Analytics cookies monitor how users reached our Sites and how they interact with and move around once on the Sites. These cookies let us know what features on our Sites are working the best and what features on the Sites can be improved.
11.2.3 Our Cookies. Our cookies are “first-party cookies” and can be either permanent or temporary. These are necessary cookies without which the Sites won’t work properly or be able to provide certain features and functionalities. Some of these cookies may be manually disabled in your browser but may affect the functionality of the Sites.
11.2.4 Personalization Cookies. Personalization cookies are used to recognize repeat visitors to our Sites. We use these cookies to record your browsing history, the pages you have visited, and your settings and preferences each time you visit our Sites.
11.2.5 Security Cookies. Security cookies help identify and prevent security risks. We use these cookies to authenticate users and protect user data from unauthorized parties.
11.2.6 Site Management Cookies. Site management cookies are used to maintain your identity or session on our Sites so that you are not logged off unexpectedly and so that any information you enter is retained from page to page. These cookies cannot be turned off individually, but you can disable all cookies in your browser.
11.2.7 Third-Party Cookies. Third-party cookies may be placed on your computer when you visit the Sites by companies that run certain services we offer. These cookies allow the third parties to gather and track certain information about you. These cookies can be manually disabled in your browser.
11.3 Before the Web Site sets Cookies on your computer, you will be presented with a prompt requesting your consent to set those Cookies.
11.4 You can choose to enable or disable Cookies in your web browser. By default, your browser may accept Cookies, however this can be altered. For further details please consult the help menu in your browser.
11.5 Disabling Cookies may prevent you from using the full range of Services available on the Web Site.
11.6 You may delete Cookies at any time however you may lose any information that enables you to access the Web Site more quickly.
11.7 It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your browser if you are unsure as to how to adjust your privacy settings.