Privacy Policy
Your privacy is of utmost importance to us, and we promise to safeguard it by adhering to this privacy policy (“Policy”). This Policy lays out the nature of information we might gather from you or you might offer (“Personal Data”) when you visit the liveeasy.co.ke platform (“Platform” or “Feature”) and its associated products and services (together, “Services”). It also details our methods of collecting, using, safeguarding, and disclosing that Personal Data. Moreover, it elucidates the options you have concerning our handling of your Personal Data and the means to update and access it.
This Policy forms a binding contract between you (“End-User”, “you”, or “yours”) and LiveEasy Products Limited (“LiveEasy Products Limited”, “our”, “we”, or “us”). If you’re representing a company or other legal entity, you assure us that you have the rights to commit such an entity to this contract. In such instances, “End-User”, “you”, or “your” refers to that entity. If you lack this authority or disagree with this Policy’s terms, you shouldn’t agree to this Policy and must refrain from accessing and using the Platform and Services. By interacting with the Platform and Services, you confirm your understanding and acceptance of this Policy’s terms. Note: This Policy doesn’t extend to practices of companies we don’t own or control, or people we don’t employ or oversee.
Information Gathering – Automated
When you access the Platform, our systems automatically log information sent by your browser. Such information can include your device’s IP, browser details, OS details, language preferences, the webpage you visited before ours, the pages you visit on our site, time spent on them, search queries on our site, access times, dates, and more.
This auto-collected data helps us pinpoint potential misuse cases and gather statistics about the Platform and Services’ utilization. Such statistics won’t be aggregated in ways that might identify any specific Platform user.
Gathering Personal Data
You can browse our Platform and Services without disclosing who you are or revealing any information that can pinpoint you as a distinct individual. However, to utilize some of our Platform’s features, we might ask you for specific Personal Data like your name and email. We collect and store data you consciously share with us when you register, purchase, or fill out Platform forms. This data can be:
- Account details (username, user ID, password, etc.)
- Contact info (email, phone number, etc.)
- Basic details (name, country of residence, etc.)
- Payment details (credit card info, bank info, etc.)
- Device geolocation (latitude, longitude)
While some data comes directly from you via our Platform and Services, we might gather Personal Data from other places like public databases, social platforms, third-party data providers, and joint marketing partners. This data might include demographics, device info, location, online behavior data, and more. Although you can opt not to share Personal Data, this might limit your use of certain Platform features. Users unsure about mandatory data can reach out to us.
Children’s Privacy
We don’t intentionally gather Personal Data from children below 13. If you’re under 13, avoid sharing any Personal Data on our Platform and Services. If we learn that a child below 13 has shared Personal Data with us, we’ll take steps to delete it from our Services. We urge parents and guardians to supervise their children’s online activities and ensure they never share Personal Data on our Platform and Services without parental consent.
Handling Collected Data
We serve both as a data custodian and processor when managing Personal Data. Our role varies based on the context of the Personal Data. We’re the data custodian when we request Personal Data essential for accessing and using the Platform and Services. Here, we decide the purpose and method of processing Personal Data. We act as a data processor when you share Personal Data via our Platform and Services. Here, we don’t dictate the decisions regarding submitted Personal Data, which is processed as per your directives. In such cases, the user sharing Personal Data acts as the data custodian.
To offer you our Platform and Services or meet legal requirements, we might need to gather and utilize certain Personal Data. If you don’t provide the necessary data, we might not be able to offer you the desired products or services. We might use the data we gather from you for purposes like:
- Managing user accounts
- Order processing
- Delivering products or services
- Enhancing our offerings
- Sending administrative and promotional communications
- Answering queries and providing support
- Getting user feedback
- Enhancing user experience
- Administering contests
- Ensuring policy and term compliance
- Safeguarding against misuse
- Meeting legal requirements and preventing harm
- Operating the Platform and Services
We might process your Personal Data based on your interaction with our Platform and Services, your location, and various other criteria: (i) your explicit consent; (ii) the necessity for fulfilling an agreement; (iii) compliance with legal obligations; (iv) public interest tasks or exercising official authority; (v) our legitimate interests or those of a third party. We might also combine or aggregate some of your Personal Data to serve you better and enhance our Platform and Services.
In some jurisdictions, we might process data until you object by opting out, without needing consent or other legal bases. In any scenario, we’re here to clarify the specific legal base relevant to the processing. Particularly, we’ll clarify whether sharing Personal Data is a legal or contractual requirement or needed for entering a contract.
Payment Handling
For paid Services, you might have to share payment details, used exclusively for payment processing. We employ third-party payment processors (“Payment Handlers”) to securely handle payment details.
Payment Handlers stick to the latest security norms set by the PCI Security Standards Council, a collaborative effort of brands like Visa, MasterCard, American Express, and Discover. Data exchanges are secured via SSL and encrypted with digital signatures, ensuring a secure environment for users. We only share payment data with Payment Handlers to process payments, handle refunds, and address related complaints and queries.
Please realize that Payment Handlers might gather some Personal Data to process your payments and manage the payment process, including data collection. When required for processing future payments, and with your prior consent, your financial details will be securely stored on our Payment Handlers’ servers. Their privacy policies might differ from ours, so we recommend checking them.
Managing Your Data
You have the right to erase specific Personal Data we hold about you. The erasable Personal Data might change as our Platform and Services evolve. When you erase Personal Data, we might keep an unedited copy in our records for purposes outlined below.
Data Sharing
To offer certain Services or complete transactions you request, we might share your data with our reliable subsidiaries, affiliates, joint venture partners, contracted companies, and service providers, all collectively termed “Service Vendors”, who assist us in running the Platform and Services. Your data won’t be shared with unaffiliated third parties.
Service Vendors only get the essential information for their designated tasks and aren’t allowed to use it for other purposes. We’ll only share your data with the following Service Vendor categories:
- Order completion services
- Payment processors
- Performance monitors
- Marketing and sales services
- User authentication services
- Website hosting providers
We might also reveal any Personal Data if mandated by law, like to adhere to a subpoena or similar legal procedure. If we believe in good faith that revealing data is essential for our rights’ protection, ensuring your safety or others, probing fraud, or responding to government requests, we might do so.
Should our business undergo transitions like mergers, acquisitions by another company, or asset sales, your user account and Personal Data might be among the transferred assets.
Data Retention
We’ll keep your Personal Data for the time required to meet our legal duties, as long as your user account is active, to enforce agreements, and settle disputes, unless a longer retention period is mandated or allowed by law.
After the retention period, Personal Data will be deleted. Consequently, rights like access, erasure, rectification, and data portability cannot be exercised post the retention period expiry.
Cookies
Our Platform and Services use “cookies” to enhance your online experience. Cookies are text files stored on your computer by a web server. They can’t run programs or spread viruses. Each cookie is unique to you and can only be read by the issuing domain’s web server. If you decline cookies, you might not fully experience our Platform and Services’ features. You can learn more about cookies in this guide.
Cookies might be used for security, personalization, Platform and Services operation, and statistics. For more details on our cookies and their purpose, refer to our cookie policy. Note that you can adjust your browser settings to accept or decline cookies.
Data Analytics
We might use third-party analytics tools on our Platform and Services that utilize cookies or similar technologies to collect standard internet activity and usage details. The gathered info helps us generate statistical reports on user activity. We use this data to monitor our Platform and Services’ performance and make improvements. We don’t use third-party analytics to track or collect identifiable user information. We won’t associate any info from these reports with any individual user.
Do Not Track Signals
Some browsers have a Do Not Track feature that signals to sites you visit about your wish not to be tracked online. Tracking isn’t the same as collecting info. For our purposes, tracking means collecting identifiable info from users as they navigate different sites over time. Our Platform and Services don’t track users across third-party sites. However, some third-party sites might track your browsing when serving content, helping them tailor their offerings.
Advertisements
We might allow specific third-party companies to help us customize ads we believe might interest Users and gather and use data about User activities on our Platform. These companies might deliver ads that might set cookies and track user behavior.
Social Media Features
Our Platform and Services might feature social media functionalities like Facebook and Twitter buttons and Share This buttons, termed “Social Media Features”. They might collect your IP, the page you visit on our site, and set a cookie to function correctly. These features might be hosted by their providers or directly on our site. Your interactions with these features are governed by their providers’ privacy policies.
Email Marketing
We offer e-newsletters that you can subscribe to voluntarily. We pledge to keep your email address confidential and won’t share it with third parties except as allowed in the information use and processing section or for utilizing a third-party provider for sending such emails. All emails from us will clearly state the sender and offer clear contact details. You can choose to unsubscribe from our newsletters or marketing emails by following the provided instructions or reaching out to us. Nonetheless, essential transactional emails will continue.
Push Notifications
We also offer push notifications that you can opt into. To ensure notifications reach the right devices, we use a third-party push notifications provider relying on device tokens unique to your device. These tokens won’t reveal your identity, unique device ID, or contact details to us or our third-party push notifications provider. If you wish to stop receiving push notifications, adjust your device settings.
Links to External Sources
Our Platform and Services might contain links to other resources not under our control. Understand that we aren’t accountable for the privacy practices of such external resources or third parties. We urge you to be cautious when leaving our Platform and Services and to read the privacy policies of every resource collecting Personal Data.
Data Security
Your data is kept on secure computer servers in a controlled environment shielded from unauthorized access, use, or disclosure. We employ reasonable administrative, technical, and physical measures to protect Personal Data under our control and custody. However, internet data transmission or wireless networks can’t be guaranteed to be 100% secure. While we aim to shield your Personal Data, you must recognize that (i) the internet has inherent security and privacy limits; (ii) the security, integrity, and privacy of data exchanged between you and our Platform and Services can’t be assured; (iii) third parties might view or tamper with such data despite our best efforts. Since Personal Data’s security partly depends on your device’s security and your credentials’ protection, ensure you take measures to safeguard this information.
Data Breach
Should we discover that our Platform and Services’ security has been compromised or users’ Personal Data has been disclosed to unrelated third parties due to external activities like security breaches or fraud, we reserve the right to take reasonably suitable measures, including reporting and cooperating with law enforcement. In case of a data breach, we’ll make reasonable efforts to notify affected individuals if we believe there’s a reasonable harm risk to the user as a result of the breach or if the law mandates notification. Should this happen, we’ll post a notice on the Platform.
Updates and Changes
We reserve the right to alter this Policy or its terms related to the Platform and Services anytime at our discretion. When we do, we’ll update the date at the bottom. We might also notify you in other ways, like through the contact information you’ve shared.
The revised Policy will become effective immediately upon posting unless stated otherwise. By continuing to use the Platform and Services post the revised Policy’s effective date, you agree to the changes. However, without your consent, we won’t use your Personal Data differently from what was stated when it was collected.
Accepting this Policy
By accessing and using the Platform and Services and sharing your data, you consent to and agree with all terms in this Policy. If you don’t agree to these terms, please refrain from using the Platform and Services.
Contacting Us
For any questions, concerns, or complaints about this Policy, the data we have on you, or if you wish to exercise your rights, please contact us:
We promise to address complaints and disputes and make every reasonable effort to honor your wish to exercise your rights promptly and within the timescales set by relevant data protection laws.
This document was last updated on 5th September 2023.