1        Africa Risk Management Advisors Limited – Privacy Statement 

Africa Risk Management Advisors Limited (ARMA) respects the privacy of our stakeholders (be they clients, partners, and website visitors). We aim to protect the personal data that are provided to us. “Personal Data” refers to data, whether true or not, about an individual who can be identified from that data; or from that data and other information to which the organization has or is likely to have access. This is as per defined in the Personal Data Protection Act 2019 in Kenya as well as international data protection protocols.

​ We may update the Privacy Policy from time to time and will post all such updates to this webpage. You are encouraged to check it regularly for the latest version. Subject to your rights at law, you agree to be bound by the prevailing terms of our Privacy Policy as updated from time to time. 

2        ARMA Privacy Policy 

Unless permitted by applicable laws, ARMA will not collect your personal data without your consent. We value your privacy and will collect, use or disclose your personal data only in accordance with this Privacy Policy. 

​When you consent to provide your personal data to us, you warrant and represent to us that the personal data which you disclose to us is accurate and complete; and where you volunteer personal data of another person to us, that you are authorized by such other person to disclose such personal data to us, and that such personal data is accurate and complete. 

​By registering for any events, membership programs, services, promotions, and campaigns at ARMA by submitting your information to or otherwise communicating with us, you agree and consent to ARMA as well as our respective representatives and/or agents to collect, use and disclose your Personal Data in accordance with ARMA Privacy Policy. 

​This policy does not supersede or replace any other consents you may have previously or separately provided to us in respect of your personal data. 

This set of Policies and your use of this website shall be governed in all respects by the laws of Kenya. 

Collection & Consent of Personal Data 

We will collect your personal data in one or more of the following ways: 

1. When you register for any events, membership programs, or services with us; 
2. When you post feedback or interact with our customer service officers, e. via emails, telephone calls, or at our centers; 
3. When you interact with our online advisory services, including various Robo Advisors.

When we are required to validate as our visitors; 

1. When you use some of our services including establishing any online accounts with us; 
2. When you request that we contact you, be included in an email or other mailing list; 
3. When you respond to our promotions, campaigns or other initiatives or attend our events; 
4. When you test or subscribe to our Online Advisory services, including Robo Advisor Services.

​When we receive references from third parties, e. business partners, where you have been referred by them as per their Privacy Policy in accordance with PDPA; 

​When you visit our websites, we may automatically collect standard information tracked by most other websites (Eg. Your IP address) for cybersecurity record purposes; 

1. When you take part in any contest, survey, or promotion conducted by us and/or our business partners (including submission of photographs); 
2. When you visit our offices which are fitted with live CCTV recording for security purposes or photo taking or video recording at events; 
3. When we receive information about you from third-party social networking services when you choose to connect with those services; and 

When you submit your Personal Data to us for any other reasons; and/or when we collect your Personal Data by other lawful means. 

1. The purpose for Collection, Use & Disclosure of your personal data 

Your Personal Data may be collected, used, and/or disclosed for the following purposes: 

1. To verify accuracy of your personal data; 
2. To provide events, membership programs & services that you have requested or registered for or
3. To train our robo-advisors or online bots to make them more responsive

To respond and deal with inquiries, complaints, and other customer-care matters or otherwise communicate with you; 

1. To monitor customer-facing interactions for quality assurance, employee training, and performance evaluation; 
2. To manage payment, billing, account, credit checks, and debt-recovery matters; 
3. To send you information, promotions, updates, marketing, and advertising materials in relation to our courses and programs and that of our subsidiaries. 

To manage, develop and improve our business and operations to serve you better; 

To personalize your experience at our customer touchpoints; 

1. To carry out market research and customer surveys; 
2. To conduct investigations or audits or carry out crime and fraud prevention and risk management activities; 
3. To comply with legal and regulatory requirements; 

To enforce our legal rights and obligations; 

For other purposes for which we have obtained your consent 

Your Personal Data may be disclosed for the purposes indicated above to our officers and employees, third parties, affiliates, service providers, and advisors which include without limitation, the following persons or entities: 

1. Banks, credit card companies, and payment vendors; 
2. Debt collection agencies; 

Credit information companies; 

1. Logistics and courier services companies; 
2. Call center service providers; 
3. Our business partners and authorized program partners 

Relevant government regulators or authorities or law enforcement agencies, e.g. Kenya Revenue Authority, Etc., 

Our insurers and advisors, including consultants, trainers, assessors, auditors, and lawyers; 

1. Data intermediaries; and 
2. Any other party to whom you authorize us to disclose your Personal Data. 

Except for relevant government regulators and authorities or law enforcement agencies, we will ensure that the parties listed above receiving your personal data are 

1. Under the duty of confidentiality to us with respect to the use, holding, processing, retention, and/or transfer of your Personal Data; and 
2. Have the need to know or handle such personal data 

Security of Personal Data 

We have put in place appropriate physical & IT security measures which continually strive to meet industry standards to protect our possession & control of all personal data against unauthorized access, collection, use, disclosure, copying & disposal. 

However, even though we endeavor to ensure our internal systems are secured, we would like to remind you that all communications sent via Internet (E.g. Email & Website) cannot be guaranteed to be completely secure and thus you are providing your personal data via the Internet at your own risk. ARMA will not hold any responsibility or liability for the confidentiality and security of any information you send via the Internet. 

Withdrawal of Consent 

You have the right at any time to indicate your choice to us to withdraw your consent for the continued use & disclosure of your personal data (to a reasonable extent and as permitted by PDPA) via one or more of the following means:- 

1. By writing to our System Administrator (who is the designated Data Protection Officer). 
2. Unsubscribe options as stated in our email or other services. 

In withdrawing your consent, you acknowledge that, depending on the purpose(s) that you have indicated your withdrawal of consent for, we may not be able to provide or continue providing certain programs, courses & services to you. We may also have to cease such provisions accordingly without any liability to ARMA. 

Please note that it may take up to 30 working days for any request for withdrawal of consent to be processed and updated in our systems. 

Compliance with Data Protection Laws:

Our privacy policy is compliant with relevant data protection laws, such as the Kenya Data Protection Act, GDPR for the EU, or any other local data protection laws applicable to our users.

Use of Cookies and Tracking Technologies

Types of Cookies Used

Our website (including some services e.g. Robo Advisors – utilize cookies and similar tracking technologies to enhance user experience, collect usage data, and improve our service. These technologies may include, but are not limited to, cookies, pixels, beacons, and scripts.

• Session Cookies: These are temporary cookies that remain in the cookie file of your browser until you leave the site. They enable certain functionalities and are essential for the working of the service.
• Persistent Cookies: These remain on your device for a pre-defined period of time or until manually deleted. They are used to collect identifying information about the user, such as web surfing behavior or preferences for a specific site.
• Analytical/Performance Cookies: These cookies collect information about how you use our service, including which pages you visit most often and whether you receive error messages. The data gathered is used for statistical analysis to improve the functionality and user experience of our site.

Purpose of Cookies

The cookies and tracking technologies are used for various purposes:

• To personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested.
• To improve our website in order to better serve you.
• To allow us to better service you in responding to your customer service requests.
• To administer a contest, promotion, survey or other site feature.
• To quickly process your transactions.
• To ask for ratings and reviews of services or products

Control and Consent

Upon your first visit to our site, you will be prompted to accept or decline the use of cookies. You have the ability to accept all cookies, to be notified when a cookie is set, or to reject all cookies. Please note that if you choose to reject cookies, certain parts of our site may not work as intended or may not work at all.

Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.

Third-Party Cookies

Our service may include third-party cookies, which are used to provide additional services and features to our users and to help us analyze site usage more accurately. These cookies are subject to the respective privacy policies of the external service providers.

Data Protection Officer 

We have appointed a Data Protection Officer to oversee the protection & security management of all personal data. Should you have any query, request or feedback relating to your Personal Data, please contact us at the following: 

Data Protection Officer 

​ Africa Risk Management Advisors Limited

Peponi Road, Westlands 

P.O. Box 254727993327-00800 

Nairobi, Kenya 

Email: dpo@africarisk.net  

 

For more information about the Kenya Personal Data Protection Act, please visit http://kenyalaw.org/kl/fileadmin/pdfdownloads/Acts/2019/TheDataProtectionAct__No24of2019.pdf