1) By reading this Privacy Notice, it is deemed that you have well read and understood the terms set forth, and that proceeding to read, give or leave your personal data is by consent.

2) M-zawadi Loyalty Group Limited (herein referred to as M-zawadi) is a responsible organization that recognizes the need for treating any information with the utmost care and responsibility it deserves. As such, we give a commitment to treat any and all your personal information with the utmost responsibility and care.

3) Personal information will include any information that helps M-zawadi individually identify you as such. This information may include but not be limited to your name or names (full names or first name and surname), your contact details (phone number, email address or both), location (country, county, town, street, building), personal identification number (national identity number or passport) and date of birth.

4) Personal information will also refer to information that uniquely identifies a legal entity. This will include the trading name of a company, the company registration certificate that bears the company registration number, registered business name certificate with the registration number, KRA PIN certificate and any other official document that may be required.

5) Special personal information may include details of gender, religious, philosophical and conscience beliefs, marital status, or any criminal behavior which relates to alleged criminal offences or proceedings.

6) Personal information may be given to or collected by M-zawadi through electronic means including an electronically filled form on the M-zawadi website (www.mzawadi.com), electronic mail, phone calls, social engagement channels (Twitter, Facebook, Instagram, LinkedIn, YouTube or WhatsApp), or via the M-zawadi App.

7) Processing of personal information includes any initial processing that M-zawadi does when we first collect your personal information. It also includes any further and ongoing processing that M-zawadi is allowed to carry out legitimately in terms of the reasons listed in Item 8 below. The term ‘processing’ includes collecting, using, altering, merging, linking, organizing, disseminating, storing, retrieving, disclosing, erasing, archiving, destroying or disposing of personal information.

8) M-zawadi will only collect and process your personal information for the reason you provided it to us, or to enable us to comply with the requirements of specific laws and/or regulations. M-zawadi may process your personal information to protect you, your or our legitimate business interests. M-zawadi will not collect and process personal information about you that we do not need.

9) The general purposes for which M-zawadi collects and processes your personal information include, but are not limited to:

a) Creating a record of you on our system to verify your identity, provide you with the products and/or services you would like us to provide for you; communicating with and keeping you informed about these products and/or services;

b) Identifying you and/or verifying your business and its physical address;

c) Identifying your needs for the products or services you require;

d) Processing of historical, statistical or research data;

e) For purposes relating to the assignment, sale or transfer of any of our businesses, legal entities or assets, in whole or in part, as part of corporate transactions;

f) Where information is in regards to employment at M-zawadi, we perform applicant screening and background checks;

g) Where one is an M-zawadi employee (permanent or on contractual terms), for creation of an employment record on our system to facilitate continuous monitoring during the period of employment;

h) Where one is an M-zawadi director, for creation of a record as a director on our system;

i) Where one has been identified as a next of kin by an employee or an M-zawadi client, for create of a record as a next of kin on our system; and

j) Where one is a supplier to M-zawadi, for processing of personal information for due diligence, risk assessment, administrative and payment purposes.

Furthermore, M-zawadi will not process your special personal information unless:

a) You have given M-zawadi the consent to process it;

b) It is necessary in order to exercise or defend a legal right or obligation in law;

c) It is necessary and mandatory to comply with a legal and/or regulatory obligation of public interest;

d) It is for certain historical, research or statistical purposes that would not adversely affect your privacy; or

e) Your information has been made public through other means or entities other than M-zawadi, and of which have no affiliation to M-zawadi, are managed independently of M-zawadi and not in control of or controlled by M-zawadi.

10) For the provision of any products or services from M-zawadi, or onboarding an individual or entity as an employee, supplier or job applicant, personal information will be collected. This information can be provided in writing, through electron mail, through phone or through the highlighted social channels, but it must be accurate, complete and provided with the utmost honesty. If M-zawadi does not receive the necessary personal information, we will not be able to continue with your request of provision of products or services. If one is already a customer, an employee, a supplier or a director and M-zawadi asks for this information and is not provided, M-zawadi will have to suspend the provision of the product and/or services until such a time when the information is provided, or as the case may be, even terminate our relationship with you.

11) In most cases, personal information will be collected directly from you, but there may be other instances when M-zawadi will collect personal information from other sources. These may include legal public records, places where you may already have made your personal information public (for example, on social media), or individuals/entities whom you have appointed as your representative, in the event of a corporate entity. M-zawadi will only collect your personal information from other sources where we are legally entitled or obliged to do so, and you are entitled to ask M-zawadi which sources they used to collect your personal information.

12) For the purposes outlined in Item 8 above, M-zawadi will, in most instances, collect and process your personal information internally. However, there are times when M-zawadi needs to outsource these functions to third parties, either within, affiliated to or controlled by M-zawadi, or external to M-zawadi, including parties in other countries. Where this personal information is shared internally within M-zawadi, such sharing will be carried out only for the purposes outlined in Item 8 above. M-zawadi may also need to share your personal information with external organizations, such as government or other regulatory or industry bodies, for the purposes of carrying out of due diligence or regulatory requirements. M-zawadi may also need to share your personal information with our business partners or counter-parties, where we are involved in corporate transactions relating to the sale or transfer of any of our businesses, legal entities or assets. M-zawadi will not share your personal information with third parties who do not need your personal information, or where M-zawadi is not legally permitted to do so. When M-zawadi decides to transfer your personal information to third parties, we will only provide it to organizations that have the same data privacy policies as M-zawadi or those who are subject to laws relating to the processing of personal information that are similar to those that apply to M-zawadi. 

13) There may be instances where M-zawadi will process your personal information through a secure automated tool, or perform profiling resulting in a decision that may affect you significantly. If you are unhappy about the outcome of such a decision, please contact:

a) Our Customer Service Centre (for customers);

b) Our Resourcing Consultant (for job applicants);

c) Our Management Staff (for employees and/or suppliers);

d) M-zawadi Head Office (for directors of M-zawadi and M-zawadi owned or affiliated companies).

14) As a customer, if you have not opted in to receiving electronic marketing communications (on different media including but not limited to SMS, email, social engagement channels outlined in Item 6 or automated calling machines), M-zawadi will not market to you using electronic media. If you have opted in to receiving marketing communication via electronic media, you have the right to opt out at any time by following the instructions on the marketing communication received.

15) As a non-customer, if you would like to receive marketing information from M-zawadi through electronic media, please submit your details to M-zawadi via electronic mail, using info@mzawadi.com.

16) To the extent that local legislation permits or if one is a resident of the European Union or United Kingdom, they have the following rights regarding their personal information:

a) The right to access your personal information that we have on record.

b) You have the right to ask M-zawadi to correct any of your personal information that is incorrect. This request must be sent via electronic mail using the email address provided in Item 15.

c) One can request M-zawadi to delete or destroy their personal information, via the same electronic mail address provided in Item 15.

d) One can also object to M-zawadi processing their personal information, via the same electronic mail address provided in Item 15. The result of such a request however, will be that M-zawadi may have to suspend the provision of products or services requested, or terminate the relationship.

e) M-zawadi’s records are subject to regulatory retention periods, which means that M-zawadi may not be able to delete or destroy personal information immediately upon request.

f) An individual is allowed to request M-zawadi to port their personal information to another party in terms of applicable European Union and United Kingdom data privacy legislation.

17) For any complaints relating to the protection of personal information, including the manner in which it has been collected or processed by M-zawadi, please contact us using the contact details listed here.

M-zawadi Loyalty Group Limited
P.O. Box 14222 – 00100, Nairobi, Kenya
+254 732 514958
info@mzawadi.com

18) If you feel that your complaint has not been dealt with satisfactorily, you may lodge a complaint with our local privacy regulator in terms of applicable privacy laws.

19) M-zawadi reserves the right to change this statement at any time and without any prior notice. All changes to this statement will be updated on the website. Unless otherwise stated, the current version shall supersede and replace all previous versions of this statement.