ThinkBusiness Privacy Policy

1. About Us

Think Business Limited and our subsidiaries (hereby referred to as “we,” “us” or “Think Business”) are a leading financial sector research, consulting and information and powerhouse in Kenya.

We also organize awards, workshops and conferences for the banking, insurance and investment sectors among others.

Our brands include publications like Think Business Banking Survey, Think Business Banking Awards, Think Business Insurance Survey, Think Business Insurance Awards, Think Business Investment Survey, Think Business Investment Awards, Think Business Private and Wealth Management Forum, thinkbusinessafrica.com, bankingsurvey.co.ke, bankingawards.co.ke, insurancesurvey.co.ke, insurance awards.co.ke among other.

We care about protecting the personal information of our customers & visitors who use our websites, products or services (collectively, our “Users”). This privacy policy provides details about how we collect, share and use your personal information.

If you have any questions about this privacy policy or the practices described herein, you may contact info@thinkbusiness.co.ke or Visit us at our offices.

2. Information covered by our privacy policy

This privacy policy covers personal information, including any information we collect, use and share from you, as described further below. This privacy policy applies to all websites in the Think Business corporate family, our products and services, and our mobile applications (collectively, the “Services”).

This privacy policy does not cover how our Users may use or share data that they collect using our services.

When you purchase a Service from us, your personal information will be collected, used, and shared consistent with the provisions of this privacy policy.

3. Information collected from you

In the course of your use of the Services, we obtain the following information about you as described below. We collect this data for the purposes described under “How We Use Your Information”.

4. Signing up for services, User information

Information that you provide(d) during any registration process, including in connection with a co-branded offer (such as your name, company name, email address, phone number, billing address or Mpesa Payment information, credit card information, geographic location and industry), when you call or email us (for support or otherwise) or when you use our products or services; and the payment information that you provide to us (by way of our Services or otherwise) when you purchase some of our products and services, including credit card data.

5. Use of services, website visits and support

We collect and use data relating to your online activity on our websites with respect to our Services, including, the device, IP address, browser type and version, geographic location, pages you view, how you got to our Services and any links you click on to leave our Services ,when you update your information, communicate with us, or order new Services, metadata about your use and your contacts’ use of our Services and your emails you send (including clicks and opens),your interactions with any videos we offer

We store some of this data that we collect in a variety of places within our infrastructure, including system log files, back end databases and analytics systems.

Your telephone conversations with us (which we may monitor or record).

6. Social Media

Information from social networking websites e.g. facebook, twitter e.t.c, including information that these social networking sites provide to us, if you use your credentials at such social networking websites to log into some of our Services (such as your name and email address to pre-populate our sign-up form).

The information you allow us to access depends on the particular social networking website, and also depends on your privacy settings at the social networking website. You can control and find out more about these privacy settings at the respective websites.

7. Other Sources

Information you provide to us at surveys, seminars, to our partners;

8. How we use your information

We use the information we collect for the following purposes:

• To provide and improve on the services that you have requested
• To communicate with you, provide support;
• To diagnose problems with our servers and/or our Services;
• To assist us in offering you a personalized experience 
• To provide you with useful content;
• For advertising and marketing our Services (as per applicable law);
• We also use recorded telephone conversations for quality control purposes, to train our employees and for our own protection.

9. Sharing of information

We will only share certain personal information within our company, with our partners; third party service providers and vendors; in connection with a sale, merger, acquisition or corporate reorganization and for legal reasons.

10. Sharing of information within ThinkBusiness

We share personal information within the company to allow our affiliates to contact you with offers, services or products that may be of interest to you and to provide you with their products and services. Any such corporate affiliate may use your information only according to the terms of this privacy policy. If you are located in a jurisdiction where such sharing requires your permission, we will only do so with your consent.

11. Sharing of information with partners

When we share personal information with certain third-party partners, including marketing and advertising partners enabling partners to assist you in using our products and services, contact you with offers, services or products that may be of interest to you, and provide you with their products or services.

If you are located in a jurisdiction where such sharing requires your permission, we will only do so with your consent. Please note that if you access our services through a tool that hides your location, such as through a virtual private network, you may not receive our request for permission because we were not able to identify you as being located in a jurisdiction where your permission is required.

Further, our partners are prohibited from using your contact information for any purpose beyond those set forth above without your consent.

In the event we collect information from you in connection with an offer that is jointly presented by us and a partner, we will let you know who is collecting the information and whose privacy policy applies, as well as any options you may have regarding use of your information

12. Sharing of information within 3rd Party vendors

We may enter into contracts with third parties so that they can assist us in better serving you (e.g. providing us with Technology e.t.c.) or to assist us in our own marketing / advertising (e.g. analytics)

Our contracts with such third parties prohibit them from using any of your personal information for any purpose beyond the purpose for which it was shared.

If you purchase a product or service from a third party through one of our brands, we will pass your personal information to such third party in order for them to fulfill your order.

We also share non-personal information with certain third parties e.g. we disclose mobile search trends, email open rates by industry, campaign best practices or the number of users that have been exposed to, or clicked on, our websites or evaluated or purchased our products and services.

13. Merges, Acquisitions

If we are involved in a merger, acquisition, a sale of all or a substantial portion of our assets, or other similar sale transaction, your information will be transferred as part of that transaction. We will notify you by email and/or a prominent notice on our website of any such transfer and any choices you may have regarding your information.

14. Account Hierarchy

You have a right to have a secondary user access to your account, hereby referred to as sub account

A primary account holder can view personal information saved in sub-accounts to which they have authorized access. We share information about authorized users only for legitimate purposes consistent with this privacy policy, including servicing your account and marketing products and services to you.

15. Legal Process

We reserve the right to disclose your personally identifiable information to courts of law, law enforcement authorities and other relevant third parties, such as ISPs to conduct an investigation, respond to a third party or law enforcement subpoena or court order, bring legal action, prevent harm to others or pursue other relief when you or a third party are or may be violating our terms and conditions of use;causing injury or other harm to, or otherwise violating the property or other legal rights, of us, other users, or third parties; or violating other applicable laws.

This disclosure can include transferring your information to the U.S. and other countries outside the European Economic Area. To the extent we are legally permitted to do so, it is our policy to notify you in the event that we are required to provide your personal information to third parties in connection with a subpoena.

16. Security

The transmission of information via the internet, email or text message is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted through the Services or over email; any transmission is at your own risk. Once we have received your information, we will take appropriate technical and organizational measures to safeguard your personal information against loss, theft and unauthorized use, access or modification.

17. Cookies

We use cookies, pixels, tags, scripts and other similar technologies in the course of our business.

18. Marketing Communication

You always have the opportunity to opt out of our marketing communications with you or change your preferences by following a link in the footer of all non-transactional email messages from us or by emailing us at info@thinkbusiness.co.ke.

Some communications from us are considered transactional (e.g. billing information), and your account(s) for our products and services are provided to you upon the condition that you receive these communications from us.

You must cancel your account with our products and services, as applicable, if you do not wish to receive any transactional.

To cancel your accounts please send us an email at info@thinkbusiness.co.ke

You may still receive marketing communications from us even after you cancel your account unless you also opt-out of our marketing communications, as described above.

19. Phone Contacts

We may contact you by telephone, with your consent where applicable, for marketing purposes (including by automatic dialer and/or prerecorded message). If you do not want to receive marketing calls, please contact customer support at the brand from which you purchased your Services. You do not need to agree to receive automated marketing phone calls or texts from us to use the Services.

20. Unauthorized Access

If an account or profile was created without your knowledge or authorization, please contact customer support at the brand on which the account or profile is located to request removal of the account or profile.

21. Retention of personal information

We retain your personal information to provide you with services, to comply with our legal obligations. We will retain your personal information for no more than seven years following the later of (i) the date on which you terminate your use of the Services or (ii) May 25, 2018, unless we are otherwise required by law or regulation to retain your personal information for longer.

22. Your rights

Where the European Union’s General Data Protection Regulation 2016/679, or GDPR, applies, in certain circumstances and subject to data processing agreements, you have rights in relation to the personal information we hold about you. We set out below an outline of those rights and how to exercise those rights. Please note that we will require you to verify your identity before responding to any requests to exercise your rights by providing details only known to the account holder.

You have the right to know whether we process personal information about you, and if we do, to access data we hold about you and certain information about how we use it and who we share it with.

You have the right to receive a subset of the personal information you provide us if we process it on the legal bases of our contract with you or with your consent in a structured, commonly used and machine-readable format and a right to request that we transfer such personal information to another party. If you wish for us to transfer the personal information to another party, please ensure you detail that party and note that we can only do so where it is technically feasible.

You have the right to require us to correct any personal information that we hold about you that is inaccurate, misleading or have incomplete data . You will put this request in writing.

You may request that we erase the personal information we hold about you.

Please provide as much detail as possible on your reasons for the request.

You have a right to require us to stop processing the personal information we hold about you.

You also have the right, at any time, to object to our processing of data about you.

You can withdraw your consent at any time by writing us at info@thinkbusiness.co.ke

23. Third Party Links

Some of our Services provide links to other websites. We do not control the information policies or practices of these third party sites. Therefore you should review their privacy policies to learn about how they collect and use personal information.

24. Children

Our Services are not directed to persons under 18. We do not knowingly collect personal information from children under 18. If a parent or guardian becomes aware that his or her child has provided us with personal information without such parent or guardian’s consent, he or she should contact us. If we become aware that a child under 18 has provided us with personal information, we will delete such information from our files.

25. Data Transfer

In order for us to provide the Services to you, your personal information will be transferred to, and stored at/processed in the Kenya, United States. We take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this policy.

You can contact us to obtain a copy of the data transfer agreement or more information regarding the relevant safeguard we put in place.

26. Complaints

In the event that you wish to make a complaint about how we process your personal information, please contact us at will try to deal with your request.

27. Notification of changes

We reserve the right to modify this privacy policy at any time, so please review it frequently. If we decide to change this privacy policy in any material way, we will notify you by email, or by means of a notice on our website www.bankingsurvey.co.ke or the relevant website of the Think Business product /service you use prior to the change becoming effective.

Your continued use of our Services constitutes acceptance to any such changes.

Last modified 20th February, 2019