At Apostolos Sacco, accessible from www.apostolossacco.com, one of our main priorities is the data protection, maintenance of data privacy and confidentiality of   users to our website (“site”). This Privacy Policy applies to personal information collected that is collected by Apostolos Sacco on its site and how we use the information, with whom it is shared with; and the choices available to users of our site.

This Privacy Policy applies solely to our site and is applicable to the users of our site.. This policy is not applicable to any information collected offline or via channels other than the site. All information collected through the site shall be processed by adhering to the principles of data protection provided in Section 25 of the Data Protection Act, 2019 (“DPA”)

You MUST read our disclaimer policy statement and terms and Conditions Statement for use of this site.

Consent

By using our website, you hereby consent to our Privacy Policy and agree to its terms. If you consent to us processing your personal information, you may withdraw this consent at any time. If you have consented to receiving marketing emails, including newsletters, you may withdraw your consent as explained below on the aspect of cookie notices. In all other cases or if you have problems withdrawing your consent on the site, you can contact us as indicated in the “How to Contact Us” section provided on the site. Please note that your consent can only be withdrawn with future effect and such a withdrawal does not have any influence on the legality of past processing. In certain instances, we may be entitled in spite of withdrawal to continue processing your personal information on a distinct basis e.g. to perform a contract. Provisions of the DPA and the attendant regulations will be complied with in this regard.

Information we collect

The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information. If you contact us directly, we may receive additional information about you such as your name, email address, phone number, and the contents of the message and/or attachments you may send us, and any other information you may choose to provide. When you register for an Account ( if there is any service that needs such feature ), we may ask for your contact information, including items such as name, company name, address, email address, and telephone number.

How we use your information

We use the information we collect in various ways, including to:

• Provide, operate, and maintain our website
• Improve, personalize, and expand our website
• Understand and analyze how you use our website
• Develop new products, services, features, and functionality
• Serve our clientele
• Communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the website, and for marketing and promotional purposes
• Send you emails
• Detect and prevent fraud

Log Files

Apostolos Sacco follows a standard procedure of using log files. These files log visitors when they visit websites. All hosting companies do this and a part of hosting services’ analytics. The information collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of the information is for analyzing trends, administering the site, tracking users’ movement on the website, and gathering demographic information. Use of Sacco Branch, Sacco Agency or Sacco ATM locator works by using your GPS that is detected through your browser by reading your IP Address. Using this features you agree to share your location with our website.

Cookies and Web Beacons

Like any other website, Apostolos Sacco uses ‘cookies’. These cookies are used to store information including visitors’ preferences, and the pages on the website that the visitor accessed or visited. The information is used to optimize the users’ experience by customizing our web page content based on visitors’ browser type and/or other information. The data and information collected through cookies is anonymized in line with the provisions of the DPA and used solely for the purpose of improving functionality, performance and effectiveness of services provided by the bank.

Google DoubleClick DART Cookie

Google is one of a third-party vendor on our site. It also uses cookies, known as DART cookies, to serve ads to our site visitors based upon their visit to www.website.com and other sites on the internet. However, visitors may choose to decline the use of DART cookies by visiting the Google ad and content network Privacy Policy at the following URL – https://policies.google.com/technologies/ads

Data Transfers

We may transfer the personal information we collect about you to recipients in other countries, apart from Kenya. In such circumstances of transfer the provisions of the DPA on “transfer of personal data outside Kenya”, specifically Sections 48, 49 and 50 of the Act will be complied with. We will comply with applicable safeguards and legal requirements of Kenya and the jurisdiction of transfer.

Information We Share

We do not sell personal information we collect. We may disclose information about you (i) if we are required to do so by law , (ii) to law enforcement authorities or regulatory authorities; and (iii) when we believe disclosure is appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual fraudulent or illegal activity. We also reserve the right to transfer personal information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a corporate restructure, dissolution or insolvency).

How We Protect Personal Information

We maintain administrative and technical safeguards created to protect the personal information you provide on the site against unlawful, unauthorized or accidental access, disclosure, use, loss, destruction or alteration. Your information is erased as soon as it is no longer needed for the stated purposes. However, we must at times continue to store your personal information until the retention periods, requirements and deadlines set by applicable legislation including the DPA; or regulatory bodies including the Central Bank of Kenya expire or are waived. We may also retain your personal information for purposes of the establishment, exercise or defense of legal claims. Upon completion of these processes or requirements, the relevant personal information is routinely erased. You also have the right to lodge a complaint with Registrar of Society or the Office of the Data Protection Commissioner

Our Advertising Partners

Some of the advertisers on our site may use cookies and web beacons. Please familiarize yourself with the privacy policies of any listed advertising partners on our website Our current advertising partners are listed below(the list being subject to regular updates). Third-party ad servers or ad networks uses technologies like cookies, JavaScript, or Web Beacons that are used in their respective advertisements and links that appear on Apostolos Sacco, which are sent directly to users’ browser. They automatically receive your IP address when this occurs. These technologies are used to measure the effectiveness of their advertising campaigns and/or to personalize the advertising content that you see on websites that you visit. Note that Apostolos Sacco has no access to or control over these cookies that are used by third-party advertisers.

Third Party Privacy Policies and Links to other Sites

Our site may provide links to other sites or applications for information and convenience purposes. These sites may operate independently of us. Apostolos Sacco’s Privacy Policy does not apply to other advertisers or websites. Linked sites may have their own privacy notices or policies, which we strongly advise you review. Thus, we are advising you to consult the respective Privacy Policies of these third-party ad servers for more detailed information. It may include their practices and instructions about how to opt-out. To the extent any linked sites are not owned or controlled by us, we are not responsible for the site’s content, any use of the site or the privacy practices of the third party sites. You can choose to disable cookies through your individual browser options. To have more information about cookie management with specific web browsers, it can be found at the browsers’ respective websites.

Data Protection Act, 2019 (“DPA”) Data Protection Rights

Under the DPA, among other rights, data subjects have the right to:

• Request that a business that collects a consumer’s personal data disclose the categories and specific pieces of personal data that a business has collected about consumers.
• Request that a business delete any personal data about the consumer that a business has collected.
• Request that a business that sells a consumer’s personal data, not sell the consumer’s personal data.
• If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.

Your Rights and Choices

We offer you certain choices in connection with the personal information we collect from you. To update your preferences, ask us to remove your information from our mailing lists or submit a request, please contact us as indicated in the “How to Contact Us” section of this Policy. To the extent provided by the law, you may request access to the personal information we maintain about you or request that we correct, amend, delete, block or move the information by contacting us as indicated below. Where provided by law, you may withdraw any consent previously granted to us or object on legitimate grounds to the processing of your personal information. These updated preferences will then be implemented going forward. To the extent the provisions of the DPA, which came into force on 25th November 2019, apply to the processing of your personal information you have the rights discussed in the below section.

Your Data Protection Rights under the DPA

We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

• The right to access – You have the right to request copies of your personal data. We may charge you a small fee for this service.
• The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.
• The right to erasure – You have the right to request that we erase your personal data, under certain conditions.
• The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.
• The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.
• The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us. To exercise your right, please contact us as indicated in the “How to Contact Us” section provided on the site. You also have the right to lodge a complaint with the applicable regulatory authority, specifically the Office of the Data Protection Commissioner.

Minor’s Information

Another part of our priority is safeguarding minors using the site. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity. Apostolos Sacco does not knowingly collect any Personal Identifiable Information from children under the age of 18. Any information regarding a child must be given by parent or the guardian and guided by Section 27 of the DPA. If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.

Updates to Our Website Privacy Policy

This Policy may be updated in accordance with the regulated services of the bank and in accordance with the provisions of the DPA. It may be updated periodically and without prior notice to you to reflect changes in our personal information practices and statutory; and regulatory requirements. A clear notice shall be posted to our site to notify you of any significant changes to the policy.

Contacting us

If you have any queries. Questions or comments related to this policy our your preferences on the information shared and/or collected on the site,you may contact us on -:

Apostolos Sacco Headquarters / Head Office is located at The Apostolic House – Kenya Cinema Plaza, Moi Avenue, Nairobi Kenya.