Privacy Policy – Sri Murugan Koil , Nairobi

Privacy Statement – Sri Murugan Koil Nairobi Society

1.0 Introduction

Privacy of Personal information of the devotees is taken seriously by the Society.. This document lists the types and methods by which the devotees’ personal data is collected by Sri Murugan Koil Nairobi Society (“SMKN”) and how it is processed with a clear communication on the reasons for use..This statement should be read together with the Terms & Conditions of Use for other SMKN services. In any portion where there arises a difference in interpretation, this statement will prevail.

2.0 Why do we need this document ?

This statement outlines the effort taken by the Temple Society to comply completely with the existing Data Protection Regulations of Government of Kenya and other laws applicable in Republic of Kenya. Any interpretation to the contrary will be superseded by the spirit and principles laid out in the Data Protection Regulations.

3.0 To whom does this statement apply ?

1. All Online visitors to our website.

2. Physical visitors who come to the Temple premises

4.0 Definitions

References to

4.1 “You” means:

i)Visitor – the person who views & transacts with our Website or App for any of our services or accesses our websites, Social Media pages & includes any person who accesses any of the services you have subscribed to.

ii) Any visitor that is a person (including contractors/subcontractors or any third parties) who visits the Temple.

4.2 “SMKN”, “we” or “us”, “our” and “ours” means Sri Murugan Koil Nairobi Society

5.1 Your personal information is collected by us with your consent and knowledge when you do any of the following (please note that this list is not exhaustive):

a) register for Murugan Adiyargal Punyam Scheme (MAPS)

b) Choose to dedicate a service or donation, including but not limited to the temple Website, App, SMKN premises, Social Media pages – using the Cloud, Mobile or other Device, physical visit to the Temple

c) ask the Society for more information about a service or contact SMKN with a query or complaint;

d) respond to or participate in a survey, marketing promotion, or special offer;

e) We may collect your information when you interact with us as a supplier, devotee, visitor as prescribed in this statement;

5.2 We do not specifically collect information from minors (any person under 18 years of age) except where they additionally donate / participate on behalf of their parent and/ or legal guardian. If a devotee allows a child to use our services, the personal information of the minors could be collected as described in this statement.

6.0 What Information is collected?

The information we collect and store about you includes but is not limited to the following:

6.1 Your identity, including your name, photograph, address, location, phone number, email address, identity document type and number, date of birth, email address, age, gender.

6.2 Your credit or debit-card information, information about your bank account numbers and SWIFT codes or other banking information.

6.3 Your transaction information when you use Payment Gateway services.

6.4 Your preferences for services, based on information provided by you or from your use of SMKN’s (or third party) services.

6.5 Name, family details, age, profiling information such as level of education, bank account status, income brackets, etc. collected as part of surveys conducted by SMKN or their agents.

6.6 Your contact with us, such as when you: call us or interact with us through social media, ‘post mail’, email, visit SMKN temple premises.

6.7 We maintain a register of visitors in which we collect and keep your personal data such as names, company/institution details, telephone number, vehicle registration details and National ID
number.

7.0 Use of Information

Your information may be analysed for the following purposes:

7.1 Processing donations and services that you have transacted with SMKN on our App, Website, Social Media platforms and physical visits;

7.2 Verifying identity information through publicly available and/or restricted government databases in order to comply with applicable regulatory requirements;

7.7 to comply with any legal, governmental or regulatory requirement or for use by our lawyers in connection with any legal proceedings;

7.10 To understand how you use our services for purposes of developing or improving them;

7.11 Preventing and detecting fraud or other crimes;

7.13 Provide aggregated data (which do not contain any information which may identify you as an individual) to third parties for research;

7.14 Administer any of our online platforms/websites.

8. Categories of Data

Categories of Personal Data as defined in the Data Protection Act of Kenya may be processed depending on the types of products and services you have subscribed to.We will process your personal information based on any of the lawful basis provided for under the Data Protection Law:

8.2 SMKN’s legitimate society interests;

8.3 Compliance with a mandatory legal obligation;

8.4 Consent you provide;

8.5 Public interest;

8.6 Your vital interest.

9. Retention of Information

Your personal data will be retained for as long as reasonably necessary to fulfil the purposes it was collected for, including for the purposes of satisfying any legal, tax, accounting or reporting requirements. Your personal data may be retained for a longer period in case of a complaint or if there are reasons to 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 unauthorized 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, the need to comply with our internal policy and the applicable legal, regulatory, tax, accounting or other requirements.

Anonymized information that can no longer be associated with you may be held indefinitely.

10.0 Disclosure of Information

10.1 Any disclosure of your information shall be in accordance with applicable law and regulations shall assess and review each application for information and may decline to grant such information to the requesting party.

10.2 We may disclose your information to:

a) law-enforcement agencies, statutory authorities in response to a demand issued with the appropriate lawful mandate and where the form and scope of the demand is compliant with the law. b) Fraud prevention and Anti money laundering agencies, credit-reference agencies; c) publicly available and/or restricted government databases to verify your identity information in order to comply with regulatory requirements; d) Survey agencies that conduct surveys on behalf of SMKN; e) Any other person that we deem legitimately necessary to share the data with.

10.3 We shall not release any information to any individual or entity that is acting beyond its legal mandate.

10.4 We will get your express consent before we share your personal data with any third party for direct marketing purposes.

11.Direct Marketing

11.1 You may be required to opt in or give any other form of explicit consent before receiving marketing messages from us.

11.2 You can ask us to stop sending you marketing messages at any time by writing to us or logging into our website, www.nairobimurugankoil.org and checking or unchecking relevant boxes to adjust your marketing preferences or by following the optout links on any marketing message sent to you or by attending to us or contacting us at any time through the provided contacts.

11.3 Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product, service already taken up, warranty registration, product or service experience or other transactions.

12.0 The Use of Cookies

12.1 We may store some information (using “cookies”) on your computer when you visit our websites. This enables us to recognize you during subsequent visits. The type of information gathered is non-personal (such as: The Internet Protocol (IP) address of your computer, the date and time of your visit, which pages you browsed and whether the pages have been delivered successfully.

12.2 We may also use this data in aggregate form to develop customized services – tailored to your individual interests and needs. Should you choose to do so, it is possible (depending on the browser you are using), to be prompted before accepting any cookies, or to prevent your browser from accepting any cookies at all. This will however cause certain features of the web site not to be accessible.

13.0 The Use of Hyperlinks

13.1 Our websites may provide hyperlinks to other locations or websites on the Internet. These hyperlinks lead to websites published or operated by third parties who are not affiliated with or in any way related to us and have been included in our website to enhance your user experience and are presented for information purposes only.

13.2 We do not endorse, recommend, approve or guarantee any third- party products and services by providing hyperlinks to an external website or webpage and do not have any co-operation with such third parties unless otherwise disclosed. We are not in any way responsible for the content of any externally linked website or webpage.

13.3 By clicking on a hyperlink, you will leave the SMKN webpage and accordingly you shall be subject to the terms of use, privacy and cookie policies of the other website that you choose to visit.

14.0 Access to and Updating your Information

To update your information, go to www.nairobimurugankoil.org to look at your personal information. You can change how we get in touch with you and your account details whenever you like.

15.0 Safeguarding and Protection of Information

SMKN has put in place technical & operational measures to ensure integrity and confidentiality of your data via controls around: information classification, access control, cryptography, physical and environmental security and monitoring and compliance.

16.0 Your Rights

Subject to legal and contractual exceptions, you have rights under data protection laws in relation to your personal data. These are listed below: –

a) Right to be informed that we are collecting personal data about you;
b) Right to access personal data that we hold about you and request for information about how we process it;
c) Right to request that we correct your personal data where it is inaccurate or incomplete;
d) Right to request that we erase your personal data noting that we may continue to retain your information if obligated by the law or entitled to do so;
e) Right to object and withdraw your consent to processing of your personal data. We may continue to process if we have a legitimate or legal reason to do so;
f) Right to request restricted processing of your personal data noting that we may be entitled or legally obligated to continue processing your data and refuse your request;
g) Right to request transfer of your personal data in [an electronic format].

If you wish to exercise any of the rights set out above, please contact us on tech@nairobimurugankoil.org .

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.

We try to respond to all legitimate requests within reasonable time. Occasionally it could take us longer if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

If you would like to contact us on any topics in this privacy policy, you can email us on tech@nairobimurugankoil.org or submit a request via our digital platforms.

17.0 Right to Lodge Complaint

You have the right to lodge a complaint with the relevant supervisory authority that is tasked with personal data protection within the Republic of Kenya

18.0 Non-Compliance with this Statement

SMKN shall have the right to terminate any agreement with you for failure to comply with the provisions of this statement and reject any application for information contrary to this statement.

19.0 Amendments to this Statement

SMKN reserves the right to amend or modify this statement at any time. If SMKN amends this statement, You can access the most current version ofthe privacy statement by clicking this link SMKN Privacy Statement so that you will always know how your personal information is being used or shared. Any amendment or modification to this statement will take effect from the date of notification on the SMKN website.