Privacy Policy
Last Modified: 18th August 2020
We at Hazelhoff Consultants are committed to protecting your privacy. This Privacy Policy applies to the information and data collected by Hazelhoff as a controller, including the information collected on our Website (www.hazelhoff-ea.com) or through other channels as described below. This Privacy Notice describes how we collect, receive, use, store, share, transfer, and process your personal information. It also describes your choices regarding use, as well as your rights of access and correction of your personal information. If you do not agree with the data practices described in this Privacy Policy, you should not use the Website.
This Privacy Policy does not apply to the data Hazelhoff processes on behalf of our clients (Client Data) in our capacity as a processor. Your use of the Hazelhoff Subscription Service (the Subscription Service) as a customer of Hazelhoff, including use of our associated mobile applications (Mobile Apps), is covered under the Hazelhoff Product Privacy Policy.
We periodically update this Privacy Policy. We will post any privacy policy changes on this page and, if the changes are material, we will provide a more prominent notice by sending you an email notification, or if you subscribe to the Subscription Service, through the Notification app in your Hazelhoff portal.
While we will notify you of any material changes to this Privacy Policy prior to the changes becoming effective, we encourage you to review this Privacy Policy periodically. We will also keep prior versions of this Privacy Policy in an archive for your review.
If you have any questions about this Privacy Policy or our treatment of the information you provide us, please contact us on info@hazelhoff-ea.com or write to us by mail to Hazelhoff Consultants Ltd., P.O. Box 15542-00503, Nairobi, Kenya.
1. What Information We Collect About You
2. How We Use Information We Collect
3. How We Share Information We Collect
4. How We Transfer Information We Collect Internationally
5. Cookies and Similar Technologies
6. How to Access & Control Your Personal Data
7. Data Protection Officer
1. What Information We Collect About You
Our Use of the Subscription Service
We use our own Subscription Service to build webpages that people can visit to learn more about Hazelhoff. Information that we collect and manage using the Subscription Service for our own marketing belongs to us and is used, disclosed and protected according to this Privacy Policy.
When You Visit our Website
You are free to explore the Website without providing any Personal Information about yourself. When you visit the Website or register for the Subscription Service, we request that you provide Personal Information about yourself, and we collect Navigational Information.
‘Personal Information’
We collect personal information from you when you submit web forms or interact with our Website, for example subscribing to a Hazelhoff blog, signing up for a webinar, or requesting customer support.
‘Personal Information’ refers to any information that identifies you personally, including contact information, such as your name, e-mail address, company name, address, phone number, and other information about yourself or your business. Personal Information can also include information about any transactions, both free and paid, that you enter into on the Website, and information about you that is available on the internet, such as from Facebook, LinkedIn, Twitter and Google, or information that we acquire from service providers.
Personal Information includes Navigational Information or Payment Information where such information can directly or indirectly identify an individual.
Navigational information refers to information about your computer and your visits to the Website such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed. Please see the ‘Use of Navigational Information’ section below.
Payment information includes information we collect and process from you when you subscribe to the Subscription Service, including credit card numbers and billing information, using third party PCI-compliant service providers. Except for this, we do not collect other Sensitive Information from you.
‘Sensitive Information’
This refers to credit or debit card numbers, financial account numbers or wire instructions, government issued identification numbers (such as passport numbers), biometric information, personal health information (or other information protected under any applicable health data protection laws), and any other information or combinations of information that falls within the definition of ‘special categories of data’ under GDPR or nay other applicable law relating to privacy and data protection.
Log Files
When you view content provided by us, we automatically collect information about your computer hardware and software. This information can include your IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g. HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses. This information is used by Hazelhoff to provide general statistics regarding use of the Website. For these purposes, we do link this automatically-collected data to other Personal Information such as name, email address, address, and phone number.
Information We Collect From Third Parties
From time to time, we may receive Personal Information about you from third party sources including partners with which we offer co-branded services or engage in joint marketing activities, and sources such as social media websites.
Information About Children
The Website is not intended for or targeted at children under 16, and we do not knowingly or intentionally collect personal information about children under 16. If you believe that we have collected personal information about a child under 16, please contact us here so that we may delete the information.
2. How We Use Information We Collect
Compliance with Our Privacy Policy
We use the information we collect only in compliance with this Privacy Policy. Clients who subscribe to our Subscription Services are obligated through our agreements with them to comply with this Privacy Policy.
We Never Sell Personal Information
We will never sell your Personal Information to any third party.
Use of Personal Information
In addition to the uses identified elsewhere in this Privacy Policy, we may use your
Personal Information to:
Improve your browsing experience by personalising the Website;
Send information or Hazelhoff content to you which we think may be of interest to you by post, email, or other means and send you marketing communications relating to our business;
Promote use of our services to you and share promotional and information content with you in accordance with your communication preferences;
Provide other companies with statistical information about our users – but this information will not be used to identify any individual user and will only be shared on an aggregate and de-identified basis;
Contact you about billing, account management, and other administrative matters;
Send information to you regarding changes to our Client Terms of Service, Privacy Policy (including the Cookie Policy), or other legal agreements;
Investigate and help prevent security issues and abuse; or
Meet legal requirements.
We may, from time to time, contact you on behalf or external business partners about a particular offering that may be of interest to you. In those cases, we do not transfer your Personal Information to the third party.
Legal Basis for Processing Personal Information (Kenyan Visitors Only)
If you are a visitor located in Kenya, Hazelhoff’s Data Protection Officer can be contacted here.
Our legal basis for collecting and using the personal information described above will de pend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
Use of Navigational Information
We use Navigational Information to operate and improve the Website and to provide you with a better experience when you interact with Hazelhoff. We may also use Navigational Information alone or in combination with Personal Information to provide you with personalised information about Hazelhoff. Navigational Information, such as IP address, is used to approximate your location. For example, we may use your approximate location to provide content that has been translated or send emails at certain times using your local time zone.
You may disable the collection and use of your local data through browser-, operating system- or device-level settings. Consent concerning location data may be withdrawn at any time here.
Client Testimonials and Comments
We post client testimonials and comments on our Website, which may contain Personal Information. We obtain each client’s consent via email prior to posting the client’s name and testimonial.
Use of Payment Information
If you give us Payment Information, we use it solely to as authorised by you in accordance with this Privacy Policy in order for you to use the Subscription Services, including to check your financial qualifications and collect payment from you. We use a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use information you provide except for the sole purpose of credit card processing on our behalf.
Security of your Personal Information
We use a variety of security technologies and procedures to help protect your Personal Information from unauthorised access, use or disclosures. We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorised access, use or disclosure. All Personal Information is protected using appropriate physical, technical and organisational measures.
Social Media Features
Our Website includes Social Media Features, such as the LinkedIn button and Widgets, such as the Share Button or interactive mini-programs that run on our site. These features ma collect your IP address, which page you are visiting on our sites, and may set a cookie to enable the feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Website. This Privacy Policy does not apply to these features. Your interactions with these features are governed by the privacy policy and other policies of the companies providing them.
External Websites
Our Website provides links to other websites of third parties. We do not control, and are not responsible for, the content or practices of these other websites. Our provision of such links does not constitute our endorsement of these other websites, their content, their owners, or their practices. This Privacy Policy does not apply to these other websites, which are subject to any privacy and other policies they may have.
Public Forums
We offer publicly accessible message boards, blogs, and community forums. Please keep in mind that if you directly disclose any information through our public message boards, blogs, or forums, this information may be collected and used by others. We will correct or delete any information you have posted on the Website if you so request, as described in ‘To Unsubscribe from Our Communications’ below.
Retention of Personal Information
How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymise your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.
We retain Personal Information that you provide to use where we have an ongoing legitimate business need to do so (for example, as needed to comply with our legal obligations, resolve disputes and enforce our agreements).
When we have no ongoing legitimate business need to process your Personal Information, we securely delete the information or anonymise it or, if this is not possible, securely store your Personal Information and isolate it from any further processing until deletion is possible. We will delete this information t an earlier date if you so request, as described in the ‘How to Access & Control your Personal Data’ below.
If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services., such as when you last opened an email from us. We retain information derived fromcookies and other tracking technologies for a reasonable period of time from the date such information was created.
The data our clients collect by using the Subscription Service is retained according to the relevant agreements with our clients.
3. How We Share Information We Collect
Service Providers
We employ other third-party service providers to provide services on our behalf to visitors to our Website and our clients and users of the Subscription Service and may need to share your information with them to provide information, products or services to you. We might also share data with third parties but only if the data has been de-identified in a way so it cannot be used to identify you. Examples may include analysing data or performing statistical analysis on yor use of the Subscription Service or interactions on our Website, providing marketing assistance, processing credit card payments, supplementing the information you provide us in order to provide you with better service, developing and improving the product and services, providing customer service or support. These service providers are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information. In all cases where we share your information with such agents, we explicitly require the agent to acknowledge and adhere to our privacy and data protection policies and standards.
Hazelhoff Partners
In addition, we may share data with trusted partners to contact you based on your request to receive such communications, help us perform statistical analysis, or provide customer support. Such third parties are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information.
We partner with trusted third parties to provide you with co-marketing content that we think may be relevant to you. When you engage with these co-marketing partners, we will tell you who we are sharing data with, and provide a link to the co-marketing partner’s privacy policy so you can learn more about how to opt-out of the partner’s communications. These co-marketing partners are required to adhere to our privacy and data protection policies. If you do not want us to share your personal information with these companies, please contact us here.
Corporate Events
If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by Hazelhoff on the Website and Subscription Service. In this event, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Information, and choices you may have regarding your Personal Information.
Compelled Disclosure
We reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.
4. How We Transfer Information We Collect Internationally
International Transfers to Third Parties
Some of the Third Parties described in this Privacy Policy, which provde services to us under contract, are based in other countries that may not have equivalent privacy and data protection as to the country in which you reside. When we share information of clients in the EEA or Switzerland, we maek use of the variety o flegal mechanisms to safeguard the transfer, including the European Commission-approved standard contractual data protection clauses, or other appropriate leal mechanisms. For transfers to or from the United Kingdom, we make use of the standard contractual clauses. Please contact us if you need more information about the legal mechanisms we rely on to transfer Personal Information outside the EEA, Switzerland and the United Kingdom.
5. Cookies and Similar Technologies
Cookies
Hazelhoff and our partners use cookies or similar technologies (such as web beacons and JavaScript) to analyse trends, administer the Website, track user’s movements around the Website, and to gather demographic information about our user base as a whole. To find out more about how we use cookies on our Website and how to manage your cookie preferences, please see our Cookie Policy.
Flash Cookies and Other Third Party Tracking Technologies
The Adobe Flash Player (and similar applications) use technology to remember settings, preferences and usage similar to browser cookies but these are managed through a different interface than the one provided by your Web browser. This technology creates locally stored objects that are often referred to as ‘Flash Cookies’. Hazelhoff does not use Flash Cookies. For more information on ‘Flash Cookies’ and how you can manage them, please visit our Cookie Policy.
Advertising
We might partner with a third party ad network to either display advertising on our Website or to manage our advertising on other sites. Our ad network partner might use cookies and web beacons to collect information about your activities on this and other websites to provide you targeted advertising based on your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking here: http://optout.aboutads.info/ or http://optout.networkadvertising.org// (or if located in the European Union, by clicking here: http://www.youronlinechoices.eu/). Please note this does not opt you out of being served advertising. You will continue to receive generic ads.
Third Party Tracking Technologies
The use of cookies and web beacons by any tracking utility company is not covered by our Privacy Policy or Cookie Policy.
6. How to Access & Control Your Personal Data
Reviewing, Correcting and Removing Your Personal Information
You have the following data protection rights:
You can request access, correction, updates or deletion of your personal information.
You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conduct prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
You have the right to complain to a data protection authority about our collection and use of your personal information. Contact details for data protection authorities in the EEA, Switzerland and certain non-European countries (including the US and Canada) are available here.)
To exercise any of these rights, please contact us here or by mail to Hazelhoff Consultants Ltd, P.O. Box 14452 -00503 Nairobi, Kenya, Attention: Privacy. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.
If you would like to access or control your data with one of our customers or users of the Subscription Service, please contact the customer or user directly. Hazelhoff acts as a processor for our clients and will work with our clients to fulfil these requests when applicable.
To Unsubscribe from Our Communications
You may unsubscribe from our marketing communications by updating your communication preferences, or by contacting us here or postal mail to Hazelhoff Consultants Ltd, P.O. Box 15542 – 00503 Nairobi, Kenya, Attention: Privacy. Clients cannot opt out of receiving transactional emails relating to their account with us or the Subscription Service.
7. Data Protection Officer
If you have any questions about this Privacy Policy or our privacy practices, please contact us here or by mail at:
Mahdi Zemmouchi
Hazelhoff Consultants Ltd.
P.O. Box 15542 – 00503 Nairobi, Kenya
Welcome to the Hazelhoff Privacy Webform
You can use this form to submit a request regarding your personal information that is processed by Hazelhoff. Please complete this form and we will respond as soon as possible.
For more details and information about how we use and protect your personal information, please visit our Privacy Policy.
Thank you!