Privacy Policy
Mylobby.io
(“Mylobby”) respects your privacy and is committed to
protecting your personal data. This privacy policy will inform you as
to how we look after your personal data when you visit our website(s)
(including subdomains of our website(s) and websites through which we
make our services available) and/or our applications for mobile,
tablet, desktop, browser and other smart device systems
(“Applications”) (regardless of where you visit it from)
and use our services, and tell you about your privacy rights and how
the law protects you.
By using the Applications or our
services, you agree to be bound by this privacy policy and that we
proceed to the processing of personal data on the terms outlined
below.
The Privacy Policy last updated on: 23rd
May, 2023
1. Important information and who we are
Purpose of this privacy policy
This privacy
policy aims to give you information on how Mylobby collects and
processes your personal data through your use of the Applications and
our services, including any data you may provide through the
Applications (for example, when you create an account with us,
purchase a service or upload your images etc
The
Applications are not intended for children and we do not knowingly
collect data relating to children.
It is important that
you read this privacy policy together with any other privacy policy
or fair processing policy we may provide on specific occasions when
we are collecting or processing personal data about you so that you
are fully aware of how and why we are using your data. This privacy
policy supplements other notices and privacy policies and is not
intended to override them.
Controller
Mylobby
(collectively referred to as “Mylobby”, "we", "us"
or "our" in this privacy policy) is the controller and
responsible for your personal data, except where we process your
personal data because you use our services as a result of your
relationship with a customer who we supply our services to (for
example, if you use our services as a result of your being our
customer’s employee or client).
We have appointed
a data privacy manager responsible for overseeing questions
concerning this privacy policy. If you have any questions about this
privacy policy, including any requests to exercise your legal rights,
please contact the data privacy manager using the details set out
below.
Where we process your personal data because
you use our services as a result of your relationship with a customer
who we supply our services to, we are not the data controller as we
would be processing personal data on behalf of our customer as a data
processor.
Where we are processing your
personal data on behalf of our customer, the privacy policy that you
should be referring to would be our customer’s privacy policy. Our
customer’s privacy policy should inform you as to how your personal
data will be processed.
Contact details
If you have any
questions about this privacy policy or our privacy practices, please
contact our data privacy manager in the following ways:
Full
name of legal entity: Mylobby
Email address:
hello@Mylobby.io
Postal address: 2058- 00621 Nairobi
Changes to the privacy policy and your duty to inform us of changes
We keep our
privacy policy under regular review. Historic versions (if any) can
be obtained by contacting us.
It is important that the
personal data we hold about you is accurate and current. Please keep
us informed if your personal data changes during your relationship
with us.
Third-party links
The Applications may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the Applications, we encourage you to read the privacy policy of every website you visit.
2. The personal data we collect about you
Personal data, or
personal information, means any information about an individual from
which that person can be identified. It does not include data where
the identity has been removed (anonymous data).
We may
collect, use, store and transfer different kinds of personal data
about you which we have grouped together as follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender and visual and/or audio identifiers.
Contact Data includes billing address, email address and telephone numbers.
Financial Data includes bank account and payment card details this is through our Payment Gateway Provider
Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, other technology on the devices you use to access the Applications, and information in or about the audio or video files you provide (including metadata), such as the location of a video or the date it was created.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use the Applications and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect,
use and share Aggregated Data such as statistical or
demographic data for any purpose. Aggregated Data could be derived
from your personal data but is not considered personal data in law as
this data will not directly or indirectly reveal
your identity. For example, we may aggregate your Usage Data to
calculate the percentage of users accessing a specific website
feature. However, if we combine or connect Aggregated Data with your
personal data so that it can directly or indirectly identify you, we
treat the combined data as personal data which will be used in
accordance with this privacy policy.
We do not ask you for
any Special Categories of Personal Data about you
(this includes details about your race or ethnicity, religious or
philosophical beliefs, sex life, sexual orientation, political
opinions, trade union membership, information about your health, and
genetic and biometric data). Nor do we ask you for any information
about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
apply for our services;
upload files on the Applications;
create an account
subscribe to our service or publications;
request marketing to be sent to you;
enter a survey; or
give us feedback or contact us.
Automated technologies or interactions. As you interact with the Applications, we will automatically collect Technical Data about your equipment, browsing actions and patterns.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
analytics providers;
advertising networks; and
search information providers.
Contact, Financial and Transaction Data from providers of technical and payment services.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.
The types of
lawful bases that we will rely on to process your personal data is
set out in the Glossary.
Generally, we do not rely on
consent as a legal basis for processing your personal data, save for
the processing of Special Categories of Personal Data (where
applicable) and our making automated decisions (where applicable),
although we will get your consent before sending third party direct
marketing communications to you via email or text message. You have
the right to withdraw consent to marketing at any time by contacting
us.
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
UTM Tags: We may use UTM (Urchin Tracking Module) tags on our website to track the effectiveness of our marketing campaigns and to understand user behavior. UTM tags are small code snippets appended to the URLs of our website pages. These tags collect information such as the source, medium, and campaign name associated with the link that brought you to our website. The data collected through UTM tags is used for internal analytics and marketing purposes only.
Facebook Pixels: We utilize Facebook pixels on our website. A Facebook pixel is a small piece of code that allows us to track and measure the effectiveness of our advertising campaigns on Facebook. The pixel collects information about your browsing session, including pages viewed and actions taken on our website. This information is used to optimize our Facebook ad campaigns and deliver more relevant content to our website visitors. The data collected through Facebook pixels is handled in accordance with Facebook's Data Policy.
Promotional offers from us
We may use your
Identity, Contact, Technical, Usage and Profile Data to form a view
on what we think you may want or need, or what may be of interest to
you. This is how we decide which services and offers may be relevant
for you (we call this marketing).
You will receive
marketing communications from us if you have requested information
from us or purchased from us and you have not opted out of receiving
that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us or
third parties to stop sending you marketing messages at any time by
following the opt-out links on any marketing message sent to you
(where such links are available) or by contacting us at any
time.
Where you opt out of receiving these marketing
messages, this will not apply to personal data provided to us as a
result of a service purchase, service experience or other
transactions.
Change of purpose
We will only use
your personal data for the purposes for which we collected it, unless
we reasonably consider that we need to use it for another reason and
that reason is compatible with the original purpose. If you wish to
get an explanation as to how the processing for the new purpose is
compatible with the original purpose, please contact us.
If
we need to use your personal data for an unrelated purpose, we will
notify you and we will explain the legal basis which allows us to do
so.
Please note that we may process your personal data
without your knowledge or consent, in compliance with the above
rules, where this is required or permitted by law.
challenge such a decision by asking us to reconsider a decision or take a new decision on a different basis; or
request and obtain from the Owner human intervention on such processing.
Please contact us if you want to find out more about the purposes, the third-party services we use which makes automated decisions (if any), and any specific rationale for automated decisions used within the Applications.
Email Notifications
You may
also, in most cases (except where we send you email notifications for
the purposes set out in the table in section 4 above), opt-out of the
email notifications we send by contacting us, clicking the
“Unsubscribe” button at the end of our emails or by managing your
communication preferences on the Applications.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table under the “purposes for which we will use your personal data” section above.
Third Parties as set out in the Glossary.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
7. Data security
We have put in
place appropriate security measures to prevent your personal data
from being accidentally lost, used or accessed in an unauthorized
way, altered or disclosed. In addition, we limit access to your
personal data to those employees, agents, contractors and other third
parties who have a business need to know. They will only process your
personal data on our instructions and they are subject to a duty of
confidentiality.
We have put in place procedures to
deal with any suspected personal data breach and will notify you and
any applicable regulator of a breach where we are legally required to
do so.
8. Data retention
How long will you use my personal data for?
We will only
retain your personal data for as long as reasonably necessary to
fulfil the purposes we collected it for, including for the purposes
of satisfying any legal, regulatory, tax, accounting or reporting
requirements. We may retain your personal data for a longer period in
the event of a complaint or if we reasonably believe there is a
prospect of litigation in respect to our relationship with you.
To
determine the appropriate retention period for personal data, we
consider the amount, nature and sensitivity of the personal data, the
potential risk of harm from unauthorised use or disclosure of your
personal data, the purposes for which we process your personal data
and whether we can achieve those purposes through other means, and
the applicable legal, regulatory, tax, accounting or other
requirements.
You can request details of our retention
periods for different aspects of your personal data by contacting
us.
In some circumstances you can ask us to delete
your data; see “your legal rights” section below for further
information.
Where we use universally unique
identifiers (“UUID”) for analytics purposes. UUID is
generated upon your opening of an account with us. The UUID persists
between opening an account up and till you close the account.
In
some circumstances we will anonymize your personal data (so that it
can no longer be associated with you) for research or statistical
purposes, in which case we may use this information indefinitely
without further notice to you.
9. Your legal rights
Under certain
circumstances, you have rights under data protection laws in relation
to your personal data.
Broadly, you have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you want us to establish the data's accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.