Please review this Policy carefully to understand our practices.
This Site is not intended for children (i.e. under 18 years) and we do not knowingly collect data relating to children.
For ease of reference, the terms below as used in the Policy have the following meaning:
[Pigiame] is the data controller and responsible for your personal data (referred to as "we", "us" or "our" in this Policy). If you have any questions about this Policy please send an email to firstname.lastname@example.org
Ringier One Africa Media Ltd is made up of different legal entities, details of which can be found here: https://roam.africa/about-us. This Policy is issued on behalf of Ringier One Africa Media Group ("Group") so when we mention "Pigiame", "we", "us" or "our" in this Policy, we are referring to the relevant company in the Group responsible for processing your data. [We will let you know which entity will be the controller for your data when you purchase a product or service with us.] Pigiame is the controller and responsible for this Site.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out above.
Depending on the Services you are obtaining or accessing, we may collect, store, use and transfer the following different types of information:
Please note that this is not an exhaustive list.
We do collect sensitive personal data about you. This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, information about your health, and genetic and biometric data. We also collect information about criminal convictions and offences.
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 not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We collect personal information:
It is important that the personal data we hold is accurate and current to enable us deliver the Services. As such, please keep us informed if your personal data or any other information changes in the course of your use of the Site.
You guarantee and declare that you are the owner of the information you submit on the Site or share with us, or that you have the rights necessary rights to do so. You also guarantee and declare that it is exact, true and verified, and the use of the information is not contrary to this Policy or applicable laws and will not damage a third party’s reputation. You accept full and complete liability for any information that is contrary to this Policy or any applicable laws.
How we use your personal data depends on the Services you are accessing. We will use you personal data:
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.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
If you are a registered user of the Site, you are entirely responsible for maintaining the confidentiality of your password and login name. Furthermore, you are entirely responsible for any and all activities that occur under your account. You must immediately notify us of any unauthorized use of your login name or any other breach of security known to you.
The security and integrity of your personal data is important to us and we have in place appropriate security measures and take all due care to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Unfortunately, we cannot guarantee its absolute security since there is no method of transmission over the internet or method of electronic storage that is fully secure. We disclaim all liability to you to the greatest extent possible under the law should such a breach of security occur.
Except as specified in this Policy, we will not disclose your personal data to third parties without your consent. Depending on the Services, we may share your personal data with:
Depending on the Services you are accessing, we may share certain personal information with third parties to help us use your personal information. For example, for users of Pigiame, buyers and sellers have access to each other's contacts. 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 and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Your personal information may be transferred outside Kenya either for ease of delivery of Services, storage or other necessary form of processing. When such transfer is necessary and for your benefit, we ensure an appropriate and similar degree of protection is afforded to it by requiring implementation of relevant safeguards by the recipient of the personal data as required by the law in Kenya.
Your sensitive personal data will also be transferred outside of Kenya for the same reasons as described above in this section. By accepting this Policy, you are providing us with your express consent to the transfer of your personal data as laid out above. We will ensure an appropriate degree of protection is afforded to the transfer of sensitive personal data outside of Kenya by requiring implementation of relevant safeguards.
Please contact us if you would like further information on this.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. Your personal data may be retained for a longer period where there has been a complaint or there is a prospect of litigation with respect to your use of the Site.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
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 purchase, product/service experience or other transactions.
In accordance with the applicable laws of Kenya, you may have the right to:
We regularly review and update this Policy in order to reflect changes to our practices, for operational, legal or regulatory reasons, and for any other purpose. Any revisions to this Policy will be uploaded to the Site and such upload will be deemed to be sufficient communication to you. Where you are a registered user, we may elect, in our own discretion, to notify you of any revision through a notice on your account.
Last updated: 24th June 2020