- How we collect or obtain information about you:
- when you provide it to us (e.g. by contacting us, placing an order on our website, sign up for our email newsletter, take a quiz, or create an account).
- from your use of our website, using cookies and similar technologies, and
- occasionally, from third parties.
- Information we collect: name, contact details, payment information e.g. your M-Pesa number (for M-Pesa payments), credit or debit card details, IP address, information from cookies, information about your computer or device (e.g. device and browser type), information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on, the geographical location from which you accessed our website (based on your IP address), your answers to quizzes or surveys, and information about your internet connection.
- How we use your information: for administrative and business purposes (particularly to contact you and process orders you place on our website), to improve our business and website, to fulfill our contractual obligations, to advertise our goods and services, to analyze your use of our website, and in connection with our legal rights and obligations.
- Disclosure of your information to third parties: only to the extent necessary to run our business, to our service providers, and to fulfill any contracts we enter into with you, and where required by law or to enforce our legal rights.
- Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): No.
- How long we retain your information: for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business). For specific retention periods in relation to certain information which we collect from you, please see the main section below entitled How long we retain your information.
- How we secure your information: using appropriate technical and organizational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology, encrypting payments you make on or via our website using Secure Sockets Layer (SSL) technology, only granting access to your information where necessary and by only trusted individuals that have been trained and briefed on appropriate handling of personal information.
- Sensitive personal information: we collect what is commonly referred to as ‘sensitive personal information’ in only two instances on the site: birthday data and skin tone preferences in your account on our website. Both instances are completely optional and only accepted upon the provision of explicit consent from users and are securely stored on our web servers for use in personalizing our correspondence with you via email or on site. This data is not used in any way, shape, or form to perform automated decision making other than to customize the website or email content which we may think is most compelling to you. Any information stored can be viewed and removed directly on your account page or by contacting us via customer service. Please do not submit other sensitive personal information about you to us. For more information, please see the main section below entitled Sensitive Personal Information. This information is only collected if you provide it to us and our legal basis for collecting it is that you provide consent to us having this information by granting us this information in your account. This information can be deleted using the same mechanism that it is provided to us in your account page or by contacting us HERE
Information we collect when you visit our website
We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.
Web server log information
Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system.
Use of website server log information for IT security purposes
Our third party hosting provider collect(s) and store(s) server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analyzing log files to help identify and prevent unauthorized access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.
Unless we are investigating suspicious or potential criminal activity, We/we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.
Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.
Legitimate interests: we and our third-party hosting provider have a legitimate interest in using your information for the purposes of ensuring network and information security.
Cookies and similar technologies
You can reject some or all of the cookies we use on or via our website by changing your browser settings or non-essential cookies by using our cookie control tool, but doing so can impair your ability to use our website or some or all of its features.
Information we collect when you contact us
We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.
Email and Contact Form
When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).
Legitimate interest(s): responding to inquiries and messages we receive and keeping records of correspondence.
Transfer and storage of your information
Information we collect when you interact with our website
We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.
When you sign up for our e-newsletter on our website or opt to receive news, offers, updates on out-of-stock items from us by entering your name and email address and clicking subscribe or ticking a box at checkout indicating that you would like to receive our e-newsletter, we collect your email address , information about your browser, information about the page you signed up on, and any other additional information you may provide to us.
Transfer and storage of your information
Use of web beacons and similar technologies in emails
We use technologies such as web beacons (small graphic files) in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates which our emails achieve. We will only use web beacons in our emails if you have consented to us doing so.
Registering on our website
When you register and create an account on our website, we collect the following information: Email address, IP address, and any other information you provide to us when you complete the registration form.
If you do not provide the mandatory information required by the registration form, you will not be able to register or create an account on our website.
Information we collect when you place an order on our website
We collect and use information from individuals who place an order on our website in accordance with this section and the section entitled Disclosure and additional uses of your information.
Information collected when you place an order
When you place an order for goods or services on our website, we collect your name, email address, billing address, shipping address, company name (if applicable), billing name, phone number, and information about your browser.
If you do not provide this information, you will not be able to purchase goods and/or services from us on our website or enter into a contract with us.
We also collect optional information from you, such as how your experience was in the form of a survey. We also ask you if you would like to receive marketing communications from us.
Processing your payment
After you place an order on our website you will need to make payment for the goods or services you have ordered. In order to process your payment we use a third party payment processors (Safaricom M-Pesa and PayPal). Your payment will be processed by either of the two depending on your selection at checkout.
At checkout and upon first arriving on the site you will have the option of receiving marketing communications from us.
Our similar goods and services
You can opt-out from receiving marketing communications in relation to our goods and which are similar to those which you purchase from us, by ticking a box to opt out or clicking ‘unsubscribe’ in any email from us.
We will send you marketing communications in relation to similar goods and services if you do not opt out from receiving them.
Use of web beacons [and similar technologies] in emails
We use technologies such as web beacons (small graphic files in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates which our emails achieve. We will only use web beacons in our emails if you have consented to us doing so.
Our goods and services
You can opt in to receiving marketing communications from us in relation to our goods and services by email ticking a box indicating that you would like to receive such communications during checkout or at any time while browsing the site by entering your email address into our newsletter sign-up form.
We will send you marketing communications in relation to our goods and services only if you opt-in to receive them.
Information collected or obtained from third parties
This section sets out how we obtain or collect information about you from third parties.
Information received from third parties
Generally, we do not receive information about you from third parties. The third parties from which we receive information about you will generally include partner companies who we are doing a joint promotion with..
It is also possible that third parties with whom we have had no prior contact may provide us with information about you.
Information we obtain from third parties will generally be your name and contact details, but will include any additional information about you which they provide to us.
Consent: where you have asked that a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass on your information to us.
Legitimate interests: where a third party has shared information about you with us and you have not consented to the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances.
For example, we would have a legitimate interest in processing your information to perform our obligations under a sub-contract with the third party, where the third party has the main contract with you. Our legitimate interest is the performance of our obligations under our sub-contract.
Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.
Where we receive information about you in error
If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.
Our use of automated decision-making and profiling
We use automated decision making and profiling on our website. We do not consider that this has any legal effect on you or similarly significantly affects you.
You have the right to object to our use of automated decision making and profiling described in this section. You can do that by opting-out of cookies and similar technologies in accordance with the method described in the relevant section below. If you do not want us to process your actual IP address (usually the IP address assigned to you by your Internet Service Provider) when you visit our website, you can use a Virtual Private Network (VPN) or a free service such as Tor.
Automated decision making
Automated decision making is decision making by technological means (i.e. by a machine) without human involvement.
Use of automated decision making for display advertising]
We automate the display advertisements containing our products and services on other websites you visit, you based on the fact that you have visited our website using cookies.
Logic involved: automatically displaying advertisements to individuals who have visited our website results in increased efficiencies and costs savings for us than manually displaying advertisements or displaying advertisements by different means.
Significance and envisaged consequences: cookies will be used to recognize the fact that you have visited our website in order to display advertisements to you (unless you have blocked such cookies) and will collect information about your online behaviour.
How to object: you can block these cookies by using the cookies control management tool on our site or by opting out of seeing personalized ads by following the instructions here: https://support.google.com/ads/answer/2662922?hl=en-GB].
Profiling is any form of automated processing of your information to evaluate personal aspects about you, in particular to analyse or predict things like your performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
Use of profiling for web analytics
Our web analytics services, Google Analytics and Facebook Pixel, use collects information such as your location (based on your IP address) and your behavior (based on cookies) when you access our website (such as the pages you visit and what you click on) and how much you are spending on our site. We will only process information from cookies if you have consented to us setting cookies on your computer. Information collected about you, once collected is anonymized and stored on an aggregate basis. IP addresses are anonymized at the point of collection on our site.
Logic involved: by automatically analyzing and categorizing information such as the location (based on IP address) as well as the behavior and devices of visitors to our website (using cookies), we are able to gain a better understanding of what our website visitors want (in terms of the content of our website and our products), how to improve our website and how to advertise and market our services to them.
Significance and envisaged consequences: cookies will be used to track and store information about your behavior and device on our website (unless you have opted out from receiving such cookies by using our cookie control tool and your location will be analyzed based on your IP address. We may target advertisements or content on our site based on the level of interest we receive from certain visitors and their behavior on our website.
Legitimate interest: improving our website for our website users and getting to know our website users’ preferences so our website can better meet their needs and desires. Also to serve advertisements to you which seem most relevant to the visitor.
Use of profiling in marketing emails
We use web beacons in our marketing emails to analyze who opens our emails and what actions they take (for example, what they click on). We will only process information from web beacons if you have consented to their use.
Logic involved: by analysing how our email recipients respond to our emails, we are able to improve the content and effectiveness of our emails and gauge who is most interested.
Significance and envisaged consequences: your behaviour when you open our emails will be tracked using small gif files (web beacons), including open rates, click through rates, and what items you clicked on in an email.
How to object: You may object to this by contacting us HERE or you may opt out by using our cookie control tool.
Legitimate interest: analyzing the level of engagement and effectiveness of our marketing emails and content
Disclosure and additional uses of your information
This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.
Disclosure of your information to service providers
We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business and who process your information for us on our behalf. These include the following:
Our third party service providers are located in the United State and Lithuania.
Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us.
We do not display all the identities of all of our service providers publicly by name for security and competitive reasons. If you would like further information about the identities of our service providers, however, please contact us directly via our contact form and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such service providers, for example).
Legitimate interest relied on: where we share your information with these third parties in a context other than where is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.
Reason why necessary to perform a contract: we may need to share information with our service providers to enable us to perform our obligations under that contract, or to take the steps you have requested before we enter into a contract with you.
Disclosure of your information to other third parties
We disclose your information to other third parties in specific circumstances, as set out below.
Providing information to third parties such as Facebook Inc and Google Inc. Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Facebook and Google on an aggregated and anonymized basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/]
Legitimate interest(s): meeting our contractual obligations to Google under our Google Analytics Terms of Service (https://www.google.com/analytics/terms/us.html)
You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout
Reason why necessary to perform a contract: we need to share your information with other companies in order to be able to meet our contractual obligations to you or to take steps at your request prior to entering a contract., for example because of the services or information you have requested.
Sharing your information with a prospective or actual purchaser or seller in the context of a business or asset sale or acquisition by us, a merger or similar business combination event, whether actual or potential.
Legitimate interest(s): sharing your information with a prospective purchaser, seller or similar person in order to allow such a transaction to take place.
Disclosure and use of your information for legal reasons
Indicating possible criminal acts or threats to public security to a competent authority
If we suspect that criminal or potential criminal conduct has occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that fraud or a cybercrime has been committed or if we receive threats or malicious communications towards us or third parties.
We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.
Legitimate interests: preventing crime or suspected criminal activity (such as fraud).
In connection with the enforcement or potential enforcement our legal rights
We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).
Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.
In connection with a legal or potential legal dispute or proceedings
We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.
Legitimate interest(s): resolving disputes and potential disputes.
For ongoing compliance with laws, regulations and other legal requirements
We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one.
Legal obligation(s): legal obligations to disclose information which are part of the laws of the Republic of Kenya.
Legitimate interest: where the legal obligations are part of the laws of another country and have not been integrated into the Kenyan Republic legal framework, we have a legitimate interest in complying with these obligations.
How long we retain your information
This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.
Order information: when you place an order for goods and services, we retain that information indefinitely or until you request that we delete unless this conflicts with our compliance of a legal responsibility.
Correspondence and inquiries: when you make an inquiry or correspond with us for any reason, whether by email or via our contact form, we will retain your information for as long as it takes to respond to and resolve your inquiry and indefinitely afterward unless it is requested to be deleted AND it does not interfere with our compliance with laws and our legitimate business interest.
E-Newsletter: we retain the information you used to sign up for our e-newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our e-newsletter service, whichever comes earlier.
Criteria for determining retention periods
In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:
- the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
- whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
- whether we have any legal basis to continue to process your information (such as your consent);
- how valuable your information is (both now and in the future);
- any relevant agreed industry practices on how long information should be retained;
- the levels of risk, cost and liability involved with us continuing to hold the information;
- how hard it is to ensure that the information can be kept up to date and accurate; and
- any relevant surrounding circumstances (such as the nature and status of our relationship with you).
How we secure your information
We take appropriate technical and organiational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:
- only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
- using secure servers to store your information;
- verifying the identity of any individual who requests access to information prior to granting them access to information;
- using Secure Sockets Layer (SSL) software to encrypt any information you submit to us via any forms on our website and any payment transactions you make on or via our website;
- only transferring your information via closed system or encrypted data transfers
Transmission of information to us by email
Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.
We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.
Server log information
Country of storage: The United States and Lithuania
Country of storage: United States of America.
Information you submit to us by our third-party payment processors, Safaricom M-Pesa and PayPal, is transferred and stored on their servers.
Country of storage: The United States and Kenya.
Your rights in relation to your information
Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by contacting us HERE
- to request access to your information and information related to our use and processing of your information;
- to request the correction or deletion of your information;
- to request that we restrict our use of your information;
- to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
- to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and
- to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.
Further information on your rights in relation to your personal data as an individual
Verifying your identity where you request access to your information
Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.
These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorized access to your information.
How we verify your identity
Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.
If it is not possible to identify you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.
We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.
Your right to object to the processing of your information for certain purposes
You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by contacting us HERE
- to object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e. analyzing or predicting your behaviour based on your information) based on any of these purposes; and
- to object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing).
You may also exercise your right to object to us using or processing your information for direct marketing purposes by:
- clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;
Sensitive Personal Information
‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.
We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.
If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information. We will use and process your sensitive personal information for the purposes of deleting it.
We will provide you with information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.
Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.