Privacy Policy

PRIVACY POLICY

1. Important Information and Who We Are

Last updated: May 30th, 2023.

Please read this Privacy Policy ("Privacy Policy”) carefully before using the https://www.teleeza.africa website (the “Service”) operated by Teleeza Africa Limited of Post Office Box Number 2270 - 00621 Nairobi, Kenya.

Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how Teleeza collects and processes your personal data through your use of this website, including any data you may provide through this website when you use the app.

This app is not intended for use by children, and we do not knowingly collect data relating to children.

It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Teleeza Africa Limited (“Teleeza”, “we”, “us” or “our”) is the controller and responsible for your personal data.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise data protection rights, please contact the data privacy manager using the details set out below.

Contact Details

If you have any questions about this Privacy Policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: Teleeza Africa Limited Email address: support@teleeza.africa , info@teleeza.africa Telephone No: (+254) 706 122 122, (+254) 714 627 627

Changes to the Privacy Policy and your Duty to Inform us of Changes

We keep our privacy policy under regular review and we shall send you updated versions as and when changes are made.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party Links

This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The Data we Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymized or pseudonymized data).

We may collect, use, store, and transfer different kinds of personal data about you, which we have grouped together as follows:

• Identity Data includes first name, last name, username, or similar identifier, marital status, title, date of birth, and gender.
• Contact Data includes email address and telephone numbers.
• Transaction Data includes details about payments, including details received from making a reward payment to you.
• Technical Data includes 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 this website.
• Profile Data includes your username and password, your interests, preferences, feedback, and survey responses you have provided to Teleeza.
• Usage Data includes information about how you use the application and our services.
• Marketing and Information Communications Data includes your preferences in receiving marketing information from us and our third parties and your communication preferences.
• Partners include but are not limited to the Teleeza World partners, i.e., Zuri Health, Turaco.
• My Wallets are Powered by respective providers eg Vuma , M-Pesa, Airtel Money etc
• Daktari Mkononi is Powered by Zuri Health
• Bima is Powered by Turaco

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.

If You Fail to Provide Personal Data

Where we need to collect personal data by law or under the terms of a contract we have with you, and you fail to provide that data when requested, we may have to disallow or discontinue your use of the Teleeza App or access to the Teleeza website.

How is Your Personal Data Collected?

We use different methods to collect data from and about you, including through:

• Direct interactions. You may give us your Identity, Contact, and Financial Data by filling in forms or by corresponding with us. This includes personal data you provide when you:
• create an account on our application or website;
• subscribe to our services;
• request marketing to be sent to you;
• enter a competition, promotion, or survey; or
• give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar mechanisms.

We may also receive Technical Data about you if you visit other websites employing our cookies.

• Third parties or publicly available sources. We will receive personal data about you

from various third parties and public sources as set out below:

Technical Data from the following parties:

(a) analytics providers;

(b) advertising networks;

(c) search information providers;

(d) Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

• Identity and Contact Data from data brokers or aggregators
• Identity and Contact Data from publicly available sources.

4. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: For a better understanding of these terms, please see the glossary of terms below.

• Where we need to enable your use of the Teleeza App or Website and our service

delivery.

• Where it is necessary for our legitimate interests (or those of a third party) and your

interests and fundamental rights do not override those interests.

• Where we need to comply with a legal obligation.

For a better understanding of these terms, please see the glossary of terms below.

Purposes for Which we Will use Your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

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 data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

5. How We Use your Passport Size photo Image

We only use your passport size photo image, uploaded either as a selfie or gallery image, to display in the settings section of the Teleeza App The same image is used to display in the todays top performers section of Teleeza World

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest

To register you as user

• Identity
• National identity card particulars
• Contact

Enabling our service delivery To process and deliver your order including:

(a) Manage payments (b) Collect and recover money owed to us (c) Making or processing reward payments (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (a) Enabling our service delivery (b) Necessary for our legitimate interests (to recover debts due to us) To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey (a) Identity (b) Contact (c) Profile (d) Marketing and Communications (a) Enabling our service delivery (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) To enable you to partake in a prize draw, competition or complete a survey (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (a) Enabling our service delivery (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity (b) Contact (c) Technical (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) (b) Necessary to comply with a legal obligation To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical Necessary for our legitimate interests (to study 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 (a) Technical (b) Usage 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 (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications Necessary for our legitimate interests (to develop our products/services and grow our business)

Promotional Offers from Us and Third-Party partners

We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you both from us and our third-party partners. This is how we decide which products, services, and offers may be relevant for you.

Cookies

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that the Teleeza App or Website may not function properly.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

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 do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality.

We have put in place procedures 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.

Data Retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfill 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 if required by law.

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.

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 unauthorized 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, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances we will anonymize or pseudonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to Comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above please contact us through support@teleeza.africa or info@teleeza.africa.

No Fee Usually Required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could 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.

Glossary of Terms

LAWFUL BASIS

Enabling our service delivery means processing your data where it is necessary for the performance of the Teleeza App and Website and delivery of the Teleeza services and user experience.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.