Last Updated: October 2024

1) Purpose of this privacy policy

Novel Technologies (EA) Limited takes data privacy seriously and is committed to safeguarding the users of our website. This privacy policy explains who we are, how we use, store, disclose, and process personal information that we obtain through our Site, including information that you may provide in connection with an online application that we obtain through the course of our operations. Our website is not intended for children and we do not knowingly collect personal information relating to children. It is important that you read this privacy policy together with any other fair processing policy we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your information. The term 'personal information' as used in this privacy policy shall mean any information that enables us to identify an individual, directly or indirectly, by reference to an identifier such as name, identification number, location data, online identifier or one or more factors specific to the individual.

2) Who we are

This privacy policy is issued on behalf of Novel Technologies (EA) Limited (from now on "we", "us" or "our"). This entity is the controller and responsible for the following website (from now on "Site"):

• Novel Technologies (EA) Limited Web Site

If you have any questions or concerns about this privacy policy or our processing activities, please contact us using the contact details provided on the contacts page.

3) Information we collect

a) Information you provide to us

We may collect certain personal information when you use or access any of our Sites, including but not limited to some or all of the following: name, email address and contact details of organization representatives. When you contact us directly via email, we use the personal information provided in your email to respond to your questions or comments. We may also store your comments for future reference.

b) Information we collect

By accessing the Site certain information about the user, such as Internet Protocol (IP) addresses, navigation through the Site, the software used and the time spent, along with other similar information, will be stored on our servers. These will not specifically identify the user. We also may collect any telephone number from which you contact us.

c) Cookies

We use "cookies" and similar technologies on our Site. A cookie is a piece of data stored on a site visitor's hard drive to help us improve your access to our site and identify repeat visitors to our site. For instance, when we use a cookie to identify you, you would not have to log in a password more than once thereby saving time while on our Site. Cookies can also enable us to track and target the interests of our users to enhance the experience on our Site.

4) How we use information

We use the personal information you choose to provide us on our Site, in the Application or by other means for one or more of the following purposes:

• To register you as the designated contact point for your Application
• To manage our relationship and status with you and/or your organization including notifying you about changes to our policies and/or asking you to take a survey
• To receive bulletins and newsletters
• To receive information on specific engagement opportunities, including events, webinars, etc., that may be made available to you and/or your organization
• To respond to inquiries
• To receive logistic notes about events, webinars, and/or other programmes
• To confirm and administer your participation in online training, self-assessment tools or hubs
• To administer and protect our operations and our Site including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data
• To deliver relevant content to you and measure or understand the effectiveness of that content
• To use data analytics to improve our Site

5) How we share information

Data provided on an Application is only used internally for the intended purpose specified during filling out the form. We do not share or sell your personal information with any third parties, trusted or otherwise, or permit them to process your personal information for any purpose whatsoever. We may disclose personal information in response to a court order, law enforcement proceeding, regulatory inquiry or as otherwise legally required. Such disclosure of personal information will be limited (a) to the extent necessary to comply with national security, public interest, or law enforcement requirements or (b) by statute, government regulation or case law that creates conflicting obligations or explicit authorizations. Also, we may share personal information in order to enforce or apply our terms and other agreements; or to protect the rights, property, or safety of Novel Technologies (EA) Limited. This includes exchanging information with other organizations for fraud protection and credit risk reduction.

6) How long we keep information

We store personal information, in a form which permits us to identify individuals, for no longer than is necessary for the purpose for which the personal information is processed. We use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and rights, or if it is not technically and reasonably feasible to remove it. Otherwise, we will seek to delete personal information within a reasonable time frame upon request.

7) Security

We maintain commercially reasonable security measures to protect personal information against unauthorized access and disclosure and that are consistent with our operations and generally accepted industry standards. These measures include the implementation of technical, physical and administrative security safeguards. We cannot ensure or warrant the security of any personal information that you transmit to us and you agree that you provide this and engage in such transmissions at your own risk. Once we receive personal information from you, we will endeavor to maintain its security on our systems. We have established policies and procedures for securely managing personal information and protecting personal information against unauthorized access.

8) Third parties websites

Our Site may contain links to other websites that are not covered by this privacy policy and where information practices may be different from ours. Our provision of a link to any other website or location is for your convenience and does not signify our endorsement of such other website or location or its contents. Please be aware that the terms of this privacy policy do not apply to these outside websites or content, or to any collection of data after you click on links to such outside websites.

9) Additional disclosures for users based in the European Union

a) General

We are headquartered in the Kenya. By using our Site from outside Kenya, you acknowledge that your personal information may be accessed by us or transferred to us in Kenya and to our affiliates, partners, and service providers who are located around the world; and that your personal information will be transferred to, and stored and processed in, Kenya or elsewhere in the world where our servers are located. If you are based in the EU, we will only process your personal information for a purpose described in this privacy policy if (1) you have provided your consent (which can be withdrawn at any time), (2) the processing is necessary for the performance of a contract we are about to enter into or have entered into with you, (3) we are required by law, or (5) the processing is necessary for the purposes of our legitimate commercial interests (except where such interests are overridden by your rights and interests).

b) Data privacy rights

If you are based in the EU, in certain circumstances you have rights under data protection laws in relation to your personal information that we hold about you—specifically:

• Request access to your personal information. You may have the right to request access to any personal information we hold about you as well as related information, including the purposes for processing the personal information, the recipients or categories of recipients with whom the personal information has been shared, where possible, the period for which the personal information will be stored, the source of the personal information, and the existence of any automated decision making.
• Request correction of your personal information. You may have the right to obtain without undue delay the rectification of any inaccurate personal information we hold about you.
• Request erasure of your personal information. You may have the right to request that personal information held about you be deleted.
• Request restriction of processing your personal information. You may have the right to prevent or restrict processing of your personal information.
• Request transfer of your personal information. You may have the right to request transfer of your personal information directly to a third party where this is technically feasible.

Also, where you believe that we have not complied with our obligation under this privacy notice or European data protection law, you have the right to make a complaint to an EU Data Protection Authority. You can exercise any of these rights by contacting us using the information provided on the contact page.

10) Changes to this privacy policy

We reserve the right to update or modify this privacy policy from time to time, with any such changes to be effective prospectively. Please visit this web page periodically so that you will be apprised of any such changes. Your continued use of our Site after any modification to this privacy policy will constitute your acceptance of such modification.

11) Contact us

If you have any questions or concerns regarding this privacy notice, please contact us via email at: info@novel.co.ke