Last Updated: November 1, 2023
When you use our services, you’re trusting us with your information. We understand this is a big responsibility and work hard to protect your information and put you in control.
Kwirel Limited. and its Affiliates (collectively, “Kwirel”, “we” or “us”) know that you care about how the personal data we receive about you is used and shared, and we take your privacy seriously. This Privacy Notice describes Kwirel’s privacy practices in relation to information that we collect through websites operated by us from which you are accessing this Privacy Notice (collectively, the “Domains”), through the software applications made available by us for use on or through computers and mobile devices that link to this Privacy Notice (the “Apps”), through our social media pages and (collectively, the “Social Media Pages”), and other services provided by us both online and offline; as well as through text and email messages that we send to you that link to this Privacy Notice (collectively, including the Domains, the Apps and the Social Media Pages, the “Sites”). “You” or “user” refers to any individual who visits or otherwise uses the Sites.
This Privacy Notice does not apply to the practices of third parties that Kwirel does not own or control, or to individuals that Kwirel does not employ or manage.
This Privacy Notice also does not apply to information that we receive or handle on behalf of our subscribers in our role as a service provider, such as information that we receive through Kwirel’s marketing automation software services or other Kwirel services, including any apps we make available for use by services subscribers (collectively, the “Subscription Services”). Such information is governed by the terms of the applicable subscription services agreement, rather than this Privacy Notice.
When you create an account, place an order at checkout, contact us directly, or otherwise use the Service, you may provide some or all of the following information:
Information from third-party sources
We may combine the personal information that we receive from you with personal information that we obtain from other third-party sources, such as:
Information collected automatically
To enhance your experience with our services and support the other purposes for which we collect personal information, we, our service providers, and our business partners may automatically record information about you, your computer, or mobile device and your interactions with the Service, our communications, and other online services over time, such as:
We and our service providers collect Personal Data and Other Information in a variety of ways, including:
Through the Sites: We collect information through the Sites, e.g., when you signup to use our services, contact us, subscribe to our email newsletter, or download content (e.g. whitepapers).
Offline: We collect information from you offline, such as when you attend one of our events, during phone calls with sales representatives, or when you contact a Kwirel representative.
Through You: Kwirel collects information such as your location or your preferred means of communication when you voluntarily provide it. Unless combined with Personal Data, this information does not personally identify you or any other user of the Sites.
Information From Other Sources: In order to enhance our ability to provide relevant marketing, offers, and services to you, we obtain information about you from other sources, such as public databases, regulatory agencies, joint marketing partners, social media platforms, as well as from other third parties.
Through Your Browser or Device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, and the name and version of the Sites (such as the Apps) you are using. Your “IP Address” is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP Address may be identified and logged automatically in our server log files whenever you access the Sites, along with the time of the visit and the page(s) that you visited. Collecting IP Addresses is standard practice and is done automatically by many websites, applications and other services. Kwirel uses IP Addresses to calculate usage levels of the Sites, help diagnose problems with its servers, administer the Sites, and for monitoring the regions from which you navigate to Kwirel’s Sites.
Through Cookies and Other Similar Technologies: “Cookies” include commonly used pieces of information in the form of small files that are placed on an individual’s device to enable the individual to more easily communicate and interact with the Sites. When you visit our Sites, we may send one or more cookies to your device. They enable us to store information about your device which helps us, amongst other things, to provide you with a good experience when you browse our Sites and enhance the level of services and functions provided. We also use third parties to serve advertisements on other websites that may be of interest to you, based on information collected about your use of our Sites and other websites. To do so, these companies may place or recognize a unique cookie or similar on your browser. Kwirel recognizes automated browser signals regarding tracking mechanisms, which may include ‘do not track’ instructions.
By Aggregating Information: Aggregated Personal Data does not personally identify you or any other user of the Sites (for example, we may aggregate Personal Data to calculate the percentage of our users who have a particular telephone area code).
We use the personal information that we collect for various purposes, including to develop, improve, support, and provide the Service, allowing you to use its features while fulfilling and enforcing our Terms of Service. We may use your personal information for the following purposes:
Create and maintain your account. We use your personal information to create and maintain your user profile on the Service, enable the Service's account security features (e.g. sending security codes via email or SMS).
Orders and delivery of products and services. We use your personal information to receive and process orders, deliver products and services, process payments, and communicate with you regarding orders, products and services, and promotional offers.
Improve and optimize services and troubleshooting. We use your personal information to optimize features, analyze performance metrics, fix errors, and improve the Service and our business. As part of these activities, we may create aggregated or otherwise deidentified data based on the personal information we collect.
Deidentified information. We may deidentify your information such that it cannot reasonably be used to infer information about you or otherwise be linked to you, and we may use such deidentified information for any purpose. To the extent we possess or process any deidentified information, we will maintain and use such information in deidentified form and not attempt to re-identify the information, except solely for the purpose of determining whether our deidentification process satisfies legal requirements.
Personalize your experience. We use your personal information to recommend features, products, and services that may be of interest to you. Personal information will also be used to determine your preferences and personalize your experience with the Service.
Communicate with you and provide customer support. We use your personal information to communicate with you (e.g. announcements, updates, security alerts, support, and administrative messages) and provide customer support for your requests, questions, and feedback.
Sweepstakes, contests, and other promotions and events. We may use your user profile picture and account information to identify you in related promotions and events, and facilitate your invitations to friends who you want to invite to join the Service.
Marketing. We and our service providers may collect and use your personal information for marketing purposes. We may send you direct marketing communications and abandoned cart reminders (enabled as described via the use of cookies that we collect).
Interest-based advertising. We, our service providers, and our third-party advertising partners may collect and use your personal information for interest-based advertising purposes. In providing interest-based advertising, we follow the Self-Regulatory Principles for Online Behavioral Advertising as set forth by the Digital Advertising Alliance (DAA), which is an advocacy organization for responsible digital marketing and consumer privacy. You can learn more about interest-based advertising and your opt-out choices here.
Fraud prevention and platform security. We use your personal information to prevent, detect, investigate, and respond to fraud, unauthorized access to or use of the Service, violations of the Terms of Use and Policies, or other misconduct.
Compliance and legal obligations: We may use your personal information for compliance purposes and to comply with the law, including any applicable laws, lawful requests, and legal processes (e.g. responding to subpoenas or requests from government authorities); to protect our, yours, and other users' rights, privacy, safety, or property (including introducing and defending legal claims); audit internal processes to ensure compliance with legal and contractual requirements and our internal policies; enforce the terms and conditions that govern the Service; prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activities, including cyberattacks and identity theft.
Legal claims based on your consent. In some cases, we may specifically ask for your consent to collect, use, or share your personal information, where required by law.
Cookies and similar technologies for technical operations, performance enhancement, advertising, analytics, etc.
We do not share your personal information with companies, organizations, or individuals outside of Kwirel except in the following cases:
Subsidiaries and Affiliates:
We disclose Personal Data to our subsidiaries and Affiliates for the purposes described in this Privacy Notice. Kwirel Ltd is the party responsible for the management of the jointly-used Personal Data.
Third-Party Business Partners:
Kwirel partners with a variety of businesses and works closely with them to market or sell products or services. In certain situations, these businesses operate within the Sites. We may disclose Personal Data to our partners for the purposes described above. Some of our third-party business partners co-sponsor events and other offerings with Kwirel. We may share Personal Data with these co-sponsors when you sign up for events or offerings to allow our partners to send you marketing communications and information that may be of interest to you, as permitted under applicable law.
Agents and Service Providers:
We contract with other companies and people to perform tasks on our behalf and share your Personal Data with some of them to provide products or services to you, or to otherwise communicate with you, such as to provide marketing or offers on our behalf. Examples include removing repetitive information from customer lists, analyzing data, providing marketing assistance, conducting billing, processing mobile money and card payments, engaging technical support for our services, providing customer service, and performing analysis related to our products or services. We also provide your Personal Data to agents and service providers to verify or compile aggregate usage data that we provide to our partners. When we share this information in this way, we require the agent or service provider to maintain the privacy, confidentiality and security of the Personal Data.
Kwirel Blog and Social Media Pages:
Personal Data may also be disclosed by you through the Sites, on message boards, chat, profile pages and blogs and other services to which you are able to post information and materials. This information can appear in public ways, such as through search engines or other publicly available platforms and can be “crawled” or searched by third parties. Please do not post any information that you do not want to reveal to the public at large.
Business Transfers:
In some cases, we buy or sell assets or businesses. In these types of transactions, user information is typically one of the business assets that is transferred. Kwirel will disclose Personal Data to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
Profiling and Automated Decision-making:
Kwirel combines data obtained by the methods described in Section 2 to help us determine what products and services might be of interest to you and when you might be ready to make a purchase based on repeated interaction with Kwirel websites, emails, and content. Kwirel marketing and sales personnel are involved in this process and no automated decisions are made that would result in legal effects or similarly significantly affect an individual.
Businesses/Other Users:
We may share with the businesses the product reviews you leave in the corresponding business's store, the return or refund reasons you request a return or refund, and customization information for customized/personalized items. The business will not receive your payment information or your contact information.
Please note that, in using our Services, you may share personal information to others; for example, when other users view items on Kwirel, they may see item reviews you left,. They will not see your profile photo and name if you hide your profile photo and name when leaving reviews.
Protection of Kwirel and Others:
We release Personal Data as we believe necessary and appropriate to law enforcement, tax, fraud prevention, credit risk agencies and other companies and organizations for the reasons given in the last bullet point under Section 3 above.
We use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Data under applicable law, then we would use or disclose it in the same way that we use and disclose Personal Data.
In some instances, we may combine Other Information with Personal Data (such as combining your name with the name of your organization). If that combination permits you to be identified, we will treat the combined information as Personal Data for as long as it is combined.
We have implemented appropriate organizational, technical, and administrative measures to protect Personal Data within our organization, including security controls to prevent unauthorized access to our systems.
We work hard to protect you and Kwirel from unauthorized access, alteration, disclosure, or destruction of information we hold, including:
While we take reasonable steps to secure your Personal Data from loss, misuse, interference and unauthorized access, modification and disclosure, you should be aware no security procedures or protocols are ever guaranteed to be 100 percent secure from intrusion or hacking, and there is therefore always some risk assumed by sharing Personal Data online. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Questions, Concerns and Complaints” section below.
You have the right to access, correct, amend, or remove any personal information about you that has been collected and stored by Kwirel. Additionally, you can limit the use or disclosure of your data. You can exercise these rights through the user interface (UI) provided within our Service.
If you wish, you can request the transfer of your personal data to another organization. For any requests or inquiries related to accessing, correcting, amending, or removing your information, or for data portability, please contact our Privacy Team at [email protected]. We will respond to your request in accordance with applicable data protection laws.
Please note that we need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such access, change or deletion.
There are other ways to control the information Kwirel collects whether or not you’re signed in to a Kwirel Account, including:
We will retain your Personal Data for a period of time consistent with the original purpose of collection, including to pursue our legitimate business interests, comply with our legal obligations, resolve disputes and enforce applicable agreements.
You can always opt not to disclose information. However, if you elect to do so, we will likely be limited in responding to your inquiry or providing services to you.
You can opt-out of receiving marketing messages from Kwirel or our Affiliates by unsubscribing through the unsubscribe or opt-out link in an email, or by unsubscribing via our platform while logged in or by simply sending us an email notice via the contact details provided at the end of this document. We will comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages.
The Sites are not intended for minors under the age of 13. Kwirel does not knowingly or specifically collect information about minors under the age of 13 and believes that children of any age should get their parents’ or legal guardians’ consent before providing any Personal Data. If you believe that we have mistakenly or unintentionally collected such information, please send us an email notice via the contact details provided at the end of this document so that we can delete the information from our servers.
The Sites permit you to link to other websites on the Internet through direct links or through applications such as “share” or “like” buttons, and other websites likewise may contain links to the Sites. The information practices or content of such other websites is governed by the privacy statements of those websites and not by this Privacy Notice. We encourage you to review the privacy policies found on such other websites, services, and applications to understand how your information is collected and used by them.
Similarly, please note that we are not responsible for the collection, use and disclosure policies and practices (including the data security practices) of other organizations, such as Google, Digital Ocean, AWS, Africa’s Talking, Safaricom, Meta, Microsoft or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including any Personal Data you disclose to other organizations through or in connection with the Apps or the Social Media Pages.
We ask that you not send us or disclose any sensitive Personal Data (e.g., political opinions, criminal background, or trade union membership) on or through the Sites or via other means.
Kwirel may amend this Privacy Notice from time to time. The “Last Updated” legend at the top of this page indicates when this Privacy Notice was last revised. Any changes to this Privacy Notice will become effective when we post the revised Privacy Notice on the Sites.
Your Personal Data may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Sites or disclosing information to us you consent to the transfer of information to countries outside of your country of residence, including Kenya, Nigeria, South Africa, United States, Australia, Germany, Ireland, and the United Kingdom, which could have different data protection rules than those of your country or the country in which you were located when you initially provided the information. Where required, we put in place a solution to ensure that Personal Data transferred outside of the EEA is subject to adequate protection, namely the European Commission Standard Contractual Clauses.
Your privacy is important to us. If you have any questions, concerns, or complaints regarding the way we collect and handle your information as a data Controller, please contact our designated privacy policy Data Protection Officer (DPO) using the following details:
Title: Data Protection Officer (DPO)
Subject: Privacy Policy
Email: [email protected]
Because email communications are not always secure, please do not include credit card information or other sensitive information in your emails to us.
Kwirel will take any privacy complaint seriously and any complaint will be assessed by an appropriate person with the aim of resolving any issue in a timely and efficient manner. We request that you cooperate with us during this process and provide us with any relevant information that we may need.
You may have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority.
