Last updated: May 2022

1. Background
   1. We are committed to safeguarding the privacy of all visitors to our websites as well as the security of any Personal Data (as defined below) that you share with us through this website. All processing of such Personal Data shall be carried out in full compliance with the requirements of all applicable laws. For purposes of this Privacy Policy, the term Personal Data shall mean any information relating to:
      1. an identified natural person; or
      2. an identifiable natural person, that is, a natural person who can be identified directly or indirectly, by reference to an identifier that relates to them such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person.
   2. This Privacy Policy explains that Adili Group member firms, Adili Kenya, Adili Tanzania, Adili Uganda and other Adili offices to be incorporated in future (collectively, separately and any number of which are hereinafter referred to as, ‘we’, ‘us’ or ‘Adili’) may collect, use, share, safeguard and/or otherwise process information (including Personal Data) provided through this website.

• This Privacy Policy may change from time to time. We reserve the right to amend the Privacy Policy at any time, for any reason. The date of the last revision to the Privacy Policy will be indicated by the “Last Updated” date.

2. Collection of Information
   1. In the course of your use of this website or your interaction with us through this website, we may collect Personal Data directly from you save for instances where the law permits us to collect your Personal Data from other sources.
   2. The types of Personal Data that may be collected include your name, business contact details, photo, job title or position and, particularly if you are a client or potential client or employed or engaged by one, your expertise and interests. Where relevant, we may collect other Personal Data– for example, your membership of professional associations or boards or, in rare cases, financial information. We may also collect other Personal Data directly from you (save for instances where the law permits us to collect your Personal Data from other sources) in the course of providing any of the Adili services to you or your employer, or to someone else based on subsequent interactions with you.

• We collect Personal Data when we are (or propose to be) dealing with, or providing or marketing our services to you, a client, or someone employing or engaging you. In accordance with our legal obligations we inform you of the following:
  1. your rights as the subject of the Personal Data which we collect from you (see section 6 below);
  2. the fact that we are collecting your Personal Data from you (see sections iv – vii below);

• the purpose for which we intend to collect your Personal Data including why we are collecting your Personal Data and how we plan to use it (see section 3 below);

1. the third parties to whom your personal data will be shared or transferred, including details of safeguards adopted (see sections 4 and 5 below);
2. the contacts of the data controller or data processor who will process your Personal Data (see section 7 below);
3. a description of the technical and organizational security measures taken to ensure the integrity and confidentiality of the data (see section 5 below);

• whether the data being collected pursuant to any law and whether such collection is voluntary or mandatory (see section VI below); and
• the consequences where the data subject fails to provide all or any part of the requested data (see section IX below).

1. If you apply for a job with us we may collect certain Personal Data from you such as your name and contact details and information about your working history. We may also collect your Personal Data from relevant records checks, from any recruitment consultant and from your previous employers, universities and others who may be able to provide information to us to assist us in our decision on whether or not to make you an offer of employment. As part of the job application process and in every other instance where we intend to collect your Personal Data from other sources besides you, we will, in so far as practicable, notify you of the fact that we intend to collect such Personal Data. In instances where you apply for any employment position with us, you agree that by so doing, you are validly consenting to our collection of your relevant Personal Data from other sources for purposes of evaluating your application.
2. Should we ever collect your Personal Data from sources other than you, in any other context besides where you have applied for employment with us, we will, in so far as it is practicable, notify you before we collect such Personal Data from such other sources.2.6 We generally only collect Personal Data from this website when it is provided voluntarily by you – for example, when you fill in a form on the careers section or subscribe to our publications or register to attend a seminar. If the Personal Data is intended to be collected pursuant to any law or where the collection of such Personal Data is mandatorily required, we will notify you of this directly prior to collecting such data.2.7 We also obtain Personal Data from your IP address, operating system and web browser that you use to access our website. We use cookies on our website.2.8 When you visit our website, our server will record your IP address together with the date, time and duration of your visit. An IP address is an assigned number, similar to a telephone number, which allows your computer to communicate over the Internet. It enables us to identify which organisations have visited this website. We use this information to compile statistical data on the use of our website to track how users navigate through our site in order to enable us to evaluate and improve our site.2.9 Please note that the provision of your Personal Data to us may be necessary for enabling the use or functioning of certain features of this website or the provision of certain services through this website. To that extent, any such features or services may not be functional or available for use or capable of being used in the absence of the provision of your Personal Data.

3. Purpose of Collection and Use of Personal Data
   1. Once collected, we may use your Personal Data in a variety of ways including, but not limited to:
      1. providing you with service communications such as bill reminders, order confirmations, programme registrations and client service messages,
      2. responding to your emails or online requests for products, services or information,

• delivering and processing surveys,

1. personalising and improving the usability of this website,
2. fulfilling and/or delivering our products and services,
3. tailoring content, advertising, and marketing to you,

• sharing your Personal Data with certain third parties to fulfil any express service requests which you make to us. We may also share such information with service providers that perform business functions for us.

4. Sharing your information
   1. We may on occasion be required to share your information with Adili Group members, offices and affiliates and any associated firms in Africa and any third parties, who provide services on our behalf. In relation to any such disclosure of your Personal Data, we will only disclose your Personal Data where you have given your consent or where we are required or otherwise permitted to do so by any applicable law, or where it is necessary for the purpose of, or in connection with, legal proceedings or to exercise or defend legal rights.
   2. We may also share e-mail addresses with third parties as necessary for them to perform certain services on our behalf, such as packaging, mailing, and delivering products to you and processing event registrations and responding to your service requests.4.3 Some of your Personal Data may be stored in a cloud located within or outside Kenya and managed by a third-party service provider. Where we transfer your Personal Data outside Kenya, we will take reasonable steps to ensure that your Personal Data is treated securely and that the means of transfer provides adequate safeguards.

• We implement commercially reasonable security measures to help protect against unauthorised access to or unauthorised alteration, disclosure, or destruction of data. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. Accordingly, and despite our efforts, we cannot guarantee or warrant the security of any information you transmit to us, or to or from our online products or services.

5. IT Security
   1. We use up to date data storage and security systems to hold your Personal Data securely in electronic and physical form to protect your personal information from unauthorized access, improper use or disclosure, unauthorised modification or unlawful destruction or accidental loss. Our IT usage and security policy is supported by various security standards, processes, and procedures. Our premises are access controlled and our electronic databases require logins and password authentication.
   2. All our partners, staff and third-party service providers who have access to confidential information (including Personal Data) are subject to confidentiality obligations.
6. Your Rights
   1. You have certain rights that you can exercise in relation to any of your Personal Data that we process. These are:
      1. the right to be informed of the use to which your Personal Data is to be put,
      2. the right to access your Personal Data,

• the right to object to the processing of all or part of your Personal Data,

1. the right to the correction of any false or misleading parts of your Personal Data,
2. the right to the deletion of any false or misleading parts of your Personal Data,
3. the right to receive your personal Data in a structured, commonly used and machine-readable format and to transmit it from us to another data controller or data processor without hindrance (the right to data portability),

• the right not to be subjected to a decision based solely on automated processing which produces legal effects that concern or significantly affect you, and
• the right to the rectification of any inaccurate, outdated, incomplete or misleading portions or parts of your Personal Data and to the erasure or destruction of any portions or parts of your Personal Data that are irrelevant, excessive, unlawfully obtained or that we are no longer authorised to retain.

1. In the limited circumstances where you may have provided your consent to the collection, processing, and transfer of your Personal Data for a specific purpose, you have the right to withdraw your consent for that specific purpose at any time. Once the firm has received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

• If you would like to exercise any of these rights, please contact us in writing by emailing [info@adili.africa] or by letter to:
  Adili Management Team,
  ALN House, Eldama Ravine Close, Off Eldama Ravine Road
  P.O. Box 200-00606,
  Westlands
  Nairobi, Kenya

7. Contact Information
   1. If you would like more information concerning this privacy policy and how it affects you, please contact the Adili team at info@adili.africa.
   2. Adili Management Team
      ALN House, Eldama Ravine Close, off Eldama Ravine Rd., Westlands,
      Nairobi.
      Tel: +254 203 640 000