Mwanzo respects your right to privacy. We have put in place security measures for your personal data and manage your personal data in accordance with applicable data privacy regulations.
Please note that Mwanzo is the Data Controller of your personal data. The principles set out in this Privacy Notice apply to all instances in which Mwanzo receives your personal data as a Data Controller for the purposes described in this notice.
We asked ourselves a number of key questions that we believe you would like answered about the personal data that you submit to Mwanzo. These answers will, to the extent required by applicable law, inform you of your rights relating to your personal data, the security measures that Mwanzo puts in place with regard to your personal data and the uses to which such personal data is put. We trust you find this information helpful.
If you have any requests concerning your personal data or any queries with regard to these practices please contact Mwanzo using the contact details given in section 15 below.
1. Please read carefully!
2. What information do we collect?
2.1. Visitor and User Information
We collect two types of information regarding our Visitors and Users : Personal Information (which could be used to uniquely identify an individual) and Non-personal Information (which is non-identifying).
- Un-identifying and non-identifiable information pertaining to a Visitor or un-identified User, which may be made available to us, or collected automatically via his/her use of the Services (“Non-personal Information”). Such Non-personal Information does not enable us to identify the Visitor or User from whom it was collected. The Non-personal Information collected by us mainly consists of technical and aggregated usage information, such as Visitors’ and Users’ device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, etc.
- Individually identifiable information, namely information that identifies an individual or may with reasonable efforts cause the identification of an individual, or may be of private or sensitive nature (“Personal Information”). The Personal Information collected by us mainly consists of contact details (e.g., e-mail address or phone number), billing details (name, physical billing address, payment method and transaction details), which are only collected from Users with Paid Services, details regarding a browsing or usage session (IP address, Geo-location and/or device unique identifier), details regarding connected third party accounts (such as the e-mail or username for a connected Google, LinkedIn or Facebook account).
3. How do we collect such information?
There are three main methods we use:
- We collect information through your use of the Services. When you visit or use our Services, including when you browse the Website or register a User Account, edit your User Website and upload information and content, and/or use any Mwanzo web Apps, we are aware of it and will usually gather, collect and record such uses, sessions and related information, either independently or with the help of third-party services including through the use of “cookies” and other tracking technologies.
- We collect information which you provide us voluntarily. For example, we collect the Personal Information you provide us when you register to our Services; when you sign in to our Services via third party services such as LinkedIn or Google; when you place purchases; when you submit or upload such Personal Information as you use any of our Services; and/or when you contact us directly by any communication channel (e.g emails).
- We also collect information from third party sources as described in section 5 below).
4. Why do we collect such information?
We collect such Non-personal and Personal Information for the following purposes:
- To allow you to operate the Services in our platform;
- To further develop, customize and improve our Services, based on Visitors’ and Users’ common or personal preferences, experiences and difficulties;
- To provide our Users with ongoing customer assistance and technical support;
- To be able to contact our Visitors and Users with general or personalized service-related notices and promotional messages;
- To create aggregated statistical data and other aggregated and/or inferred Non-personal Information, which we or our business partners may use to provide and improve our respective services;
- To enhance our data security and fraud prevention capabilities;
5. Mwanzo Security Measures
Mwanzo takes security measures in line with data protection regulations. Mwanzo has security measures in place designed to prevent data loss, to preserve data integrity, and to regulate access to the data. Only authorized Mwanzo employees, and authorized employees of our Third-Party service providers’ processing data on our behalf, have access to your personal data. All Mwanzo employees who have access to your personal data are required to adhere to the Mwanzo Privacy Notice and all third-party service providers are requested by Mwanzo to ensure that any of their employees who have access to your personal data have signed non-disclosure agreements. In addition, contracts are in place with such third-party service providers acting as data processors for Mwanzo that have access to your personal data, to ensure that the level of security required in your jurisdiction is in place, and that your personal data is processed only as instructed by Mwanzo.
Please see section 6 – Who does Mwanzo disclose your personal data to and why?
6. Who does Mwanzo disclose your personal data to and why
Mwanzo may share your Personal Information with third parties (or otherwise allow them access to it) only in the following manners and instances:
6.1. Third Party Services:
Mwanzo will never share your personal data with any Third-Party (i.e., a party other than an entity within the Mwanzo Group) business organisation that intends to use it for their own purposes, other than as required by law. Mwanzo, as part of a worldwide group, may transfer or disclose your personal data to another data controller in the Mwanzo to be used for similar purposes, at its discretion, and you hereby consent to such transfer or disclosure. If your personal data is transferred or disclosed to another data controller within the Mwanzo , that other data controller shall have the same rights and obligations with regard to your personal data as Mwanzo.
With your consent, Mwanzo may share your personal data with Third-Parties (i.e. parties other than entities within the Mwanzo ) such as those who assist us in providing the products and services and who perform technical operations, but only in the strictly limited circumstances set out below:
- Our "Third-Party Data Processors" (service providers such as our fulfilment and activation partners, and digital agencies, hosting providers, data storage providers and other technical partners) who help us administer this website, or process the data submitted to it, may have access to your data. Some of these business partners may be located outside the country where you accessed this website.
6.2 Law Enforcement, Legal Requests and Duties:
Where permitted by local data protection laws, Mwanzo may disclose or otherwise allow others access to your Personal Information pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have good faith belief that the law requires us to do so, with or without notice to you.
6.3. Social Media Features and Framed Pages:
Our Services include certain Social Media features and widgets, single sign on features, such as the “LinkedIn Connect” or “Google Sign-in”. These Social Media Features may collect information such as your IP address or which page you are visiting on our Website, and may set a cookie to enable them to function properly. Social Media Features are either hosted by a third party or hosted directly on our Services. Your interactions with these third parties’ Social Media Features are governed by their policies and not ours.
This type of information obtained through cookies will not be disclosed outside Mwanzo or our authorized Third-Party Data Processors. It will not be used for unsolicited communications.
Cookies located on your computer do not contain your name but an IP address. In many cases, after the user's session is cancelled the information contained in the cookies is no longer available to Mwanzo.
Please ensure that your computer setting reflects whether you are happy to accept cookies or not. You can set your browser to warn you before accepting cookies, or you can simply set it to refuse them, although you may not have access to all the features of the website if you do so. See your browser "Help" button for how you can do this. Some Flash Cookies may not be affected by such settings. You do not need to have cookies on to use or navigate through many parts of this and other Mwanzo websites. Remember that if you use different computers in different locations you will need to ensure that each browser is adjusted to suit your cookie preferences.
For further information about Cookies including how to refuse them, please visit www.allaboutcookies.org
8. Communications from Mwanzo
8.1. Promotional Messages:
We may use your Personal Information to send you promotional content and messages by e-mail, text messages, marketing calls and similar forms of communication from Mwanzo.
If you do not wish to receive such promotional messages or calls, you may notify Mwanzo at any time or follow the “unsubscribe” or STOP instructions contained in the promotional communications you receive.
We take steps to limit the promotional content we send you to a reasonable and proportionate level, and to send you information which we believe may be of interest or relevance to you, based on your information.
8.2. Service and Billing Messages:
Mwanzo may also contact you with important information regarding our Services, or your use thereof.
For example, we may send you a notice (through any of the means available to us) if a certain Service is temporarily suspended for maintenance; send you reminders or warnings regarding upcoming or late payments for your current or upcoming subscriptions; forward abuse complaints regarding you; or notify you of material changes in our Services.
It is important that you are always able to receive such messages. For this reason, you are not be able to opt-out of receiving such Service and Billing Messages unless you are no longer a Mwanzo User (which can be done by deactivating your account).
9. Your rights in relation to your personal information
You have the right to ask Mwanzo to provide you with all the information it stores on you. If you wish to access your personal data you can click on “My Account” where you will have the opportunity to update your personal data or preferences. You have the right to ask Mwanzo to rectify, block, complete and delete your personal data, to restrict its use, and to port your data to another organization. You have the right to request additional information about the handling of your personal data. You also have the right to object to the processing of your data by Mwanzo in some circumstances and, where we have asked for consent to process your data, to withdraw this consent. Additionally, you may contact our Data Protection Officer at [email protected] if you would like assistance with any of the aforementioned rights.
There are exceptions to these rights, however. For example, access to personal data may be denied in some circumstances if making the information available would reveal personal information about another person or if Mwanzo is legally prevented from disclosing such information. In addition, Mwanzo may be able to retain data even if you withdraw your consent, where Mwanzo can demonstrate that it has a legal requirement to process your data.
10. Countries your personal data will be sent to and why
Mwanzo is a global company and your personal data may be transferred across international borders. It may be transferred to countries that have different levels of data protection laws to the country from where you submitted your personal data. Mwanzo (as Data Controller and Data Exporter) has, where local data protection regulations so require, put in place security measures for the export of personal data from its jurisdiction.
Where local data protection regulations so require, Mwanzo has made arrangements with entities receiving your personal data such as Mwanzo or Third-Party Data Processors, that they shall ensure that security measures are in place, and that your personal data is processed only in accordance with EU Data Protection laws.
If data is transferred from within the EEA to a jurisdiction outside the EEA, it is done so under a Data Transfer Agreement, which contain standard data protection contract clauses. The European Commission has adopted standard data protection contract clauses (known as the Model Clauses) which provide safeguards for personal information that is transferred outside of Europe. We use Model Clauses when transferring personal data outside of Europe. If you wish to know more about international transfers of your personal data, you may contact our Data Protection Officer at [email protected]
The server that makes this website available may be located outside the country from which you have accessed this website. The provider of this website is bound by a contract that ensures your data is managed in accordance with EU Data Protection laws and that it acts only on Mwanzo instructions and implements all technical measures necessary on an ongoing basis to keep your personal data secure.
11. Questions and Complaints
Our Data Protection Officer team will investigate the complaint and determine whether a breach has occurred and what action, if any, to take.
We take every privacy complaint seriously and will make all reasonable efforts to resolve your complaint promptly. Our target response time is 10 days.
We expect our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also make a complaint with your local supervisory authority for data protection.
12. Data Retention
Mwanzo will retain your information only for as long as is necessary for the purposes set out in this policy. Mwanzo will retain and use your information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your information to comply with applicable tax/revenue laws), resolve disputes, and enforce our agreements. We also retain log files for internal analysis purposes. These log files are generally retained for a short period of time, except where they are used for website security, to improve website functionality, or we are legally obligated to retain them for longer time periods.
13. Public forums and user content
Our Services offer publicly accessible blogs, communities and support forums. Please be aware that any information you provide in any such areas may be read, collected, and used by others who access them. To request removal of your Personal Information from our blogs, communities or forums, feel free to contact us at: [email protected]. In some cases, we may not be able to remove your Personal Information from such areas. For example, if you use a third party application to post a comment (e.g., the Facebook social plugin application) while logged in to your related profile with such third party, you must login into such application or contact its provider if you want to remove the Personal Information you posted on that platform.
In any event, we advise against posting any information (or use any posting means to post information) you don’t wish to publicize on these platforms.
If you upload any User Content to your User Account or post it on your User Website and provide it in any other way as part of the use of any Service, you do so at your own risk.
We have put adequate security measures in place to protect your Personal Information. However, we cannot control the actions of other Users or members of the public who may access your User Content, and are not responsible for the circumvention of any privacy settings or security measures you or we may have placed on your User Website (including, for instance, password-protected areas on your User Website). You understand and acknowledge that, even after its removal by you or us, copies of User Content may remain viewable in cached and archived pages or if any third parties (including any of your Users-of-Users) have copied or stored such User Content. To clarify, we advise against uploading or posting any information you do not wish to be public.
15. Contacting us
Email: [email protected]