Hotsoko Privacy Policy

INTRODUCTION

This privacy policy ("Policy") describes how the personally identifiable information ("Personal Information") you may provide on HOTSOKO, and its website and mobile applications (herein referred to as the, "Platform") is collected, protected and used. It also describes the choices available to you regarding our use of your Personal Information and how you can access and update this information. This Policy is a legally binding agreement between you ("User", "you" or "your") and HOTSOKO Ltd (herein referred as "we", "us" or"our"). By accessing and using the platform, you acknowledge that you have read, understood, and agree to be bound by the terms of this Agreement. This Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.

Collection of Information

When you open the platform (website and mobile applications), our servers automatically record information that your browser or device sends. This data may include information such as your device's IP address and location, browser and device name and version, operating system type and version, language preferences, the webpage you were visiting before you came to the Platform, pages of the Platform that you visit, the time spent on those pages, information you search for on the Platform, access times and dates, and other statistics. Information collected automatically is used only to identify potential cases of abuse and establish statistical information regarding the usage and traffic of the Platform. This statistical information is not otherwise aggregated in such a way that would identify any particular user of the platform.

Personal information

You can access and use the platform without telling us who you are or revealing any information by which someone could identify you as a specific, identifiable individual. If, however, you wish to use some of the features on the Platform, you may be asked to provide certain Personal Information (for example, your name and e-mail address). We receive and store any information you knowingly provide to us when you create an account, make a purchase, or fill any online forms on the platform. When required, this information may include the following:

• Personal details such as name, country of residence, etc.
• Contact information such as email address, address, etc.
• Geolocation data such as latitude and longitude.
• Certain features on the mobile device such as contacts, calendar, gallery, etc.
• Any other materials you willingly submit to us such as articles, images, feedback, etc.

Some of the information we collect is directly from you via the Platform. However, we may also collect Personal Information about you from other sources such as public databases, social media platforms, third-party data providers, and our joint marketing partners. Personal Information we collect from other sources may include demographic information, such as age and gender, device information, such as IP addresses, location, such as city and state, and online behavioral data, such as information about your use of social media websites, page view information and search results and links. You can choose not to provide us with your Personal Information, but then you may not be able to take advantage of some of the features on the Services.

Use and processing of collected information

In order to make the platform available to you, or to meet a legal obligation, we need to collect and use certain Personal Information. If you do not provide the information that we request, we may not be able to provide you with the requested products or services. Any of the information we collect from you may be used for the following purposes:

• Improve products and services offerings
• Improve user experience on the platform
• Protect from abuse and malicious users
• Respond to legal requests and prevent harm
• Run and operate the platform
• Post customer testimonials
• Deliver targeted advertising
• Administer prize draws and competitions
• Create and manage user accounts
• Fulfill and manage orders
• Deliver products or services
• Enforce terms and conditions and policies
• Send administrative information
• Send marketing and promotional communications
• Respond to inquiries and offer support
• Request user feedback

Processing your Personal Information depends on how you interact with the Platform, where you are located in the world and if one of the following applies:

1. You have given your consent for one or more specific purposes; this, however, does not apply, whenever the processing of Personal Information is subject to European data protection law.
2. Provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
3. Processing is necessary for compliance with a legal obligation to which you are subject.
4. Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us.
5. Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.

Note that under some legislations we may be allowed to process information until you object to such processing (by opting out), without having to rely on consent or any other of the following legal bases below. In any case, we will be happy to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Billing and payments

We use third party payment processors to assist us in processing your payment information securely. Such third party processors' use of your Personal Information is governed by their respective privacy policies which may or may not contain privacy protections as protective as this Policy. We suggest that you review their respective privacy policies.

Disclosure of information

Depending on the requested Services or as necessary to complete any transaction or provide any service you have requested, we may contract with other companies and share your information with your consent with our trusted third parties that work with us, any other affiliates and subsidiaries we rely upon to assist in the operation of the Services available to you. We do not share Personal Information with unaffiliated third parties. These service providers are not authorized to use or disclose your information except as necessary to perform services on our behalf or comply with legal requirements. We may share your Personal Information for these purposes only with third parties whose privacy policies are consistent with ours or who agree to abide by our policies with respect to Personal Information. These third parties are given Personal Information they need only in order to perform their designated functions, and we do not authorize them to use or disclose Personal Information for their own marketing or other purposes. In the event, we go through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of its assets, your user account, and Personal Information will likely be among the assets transferred.

Retention of information

We will retain and use your Personal Information for the period necessary to comply with our legal obligations, resolve disputes, and enforce our agreements unless a longer retention period is required or permitted by law. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after the expiration of the retention period.

The rights of users

You may exercise certain rights regarding your information processed by us. In particular, you have the right to do the following:

1. You have the right to withdraw consent where you have previously given your consent to the processing of your information.
2. You have the right to object to the processing of your information if the processing is carried out on a legal basis other than consent.
3. You have the right to learn if information is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the information undergoing processing.
4. You have the right to verify the accuracy of your information and ask for it to be updated or corrected.
5. You have the right, under certain circumstances, to restrict the processing of your information, in which case, we will not process your information for any purpose other than storing it.
6. You have the right, under certain circumstances, to obtain the erasure of your Personal Information from us.
7. You have the right to receive your information in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that your information is processed by automated means and that the processing is based on your consent, on a contract which you are part of or on pre-contractual obligations thereof.

Privacy of children

We do not knowingly collect any Personal Information from children under the age of 13. If you are under the age of 13, please do not submit any Personal Information through the Services. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through the Services without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Information to us through the platform, please contact us. You must also be old enough to consent to the processing of your Personal Information in Kenya.

Do Not Track signals

Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a website. For these purposes, tracking refers to collecting personally identifiable information from consumers who use or visit a website or online service as they move across different websites over time. The Services do not track its visitors over time and across third-party websites. However, some third-party sites may keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you.

Advertisements

We may permit certain third party companies to help us tailor advertising that we think may be of interest to users and to collect and use other data about user activities on the Services. These companies may deliver ads that might place cookies and otherwise track user behavior.

Email marketing

We offer electronic newsletters to which you may voluntarily subscribe at any time. We are committed to keeping your e-mail address confidential and will not disclose your email address to any third parties except as allowed in the information use and processing section or for the purposes of utilizing a third party provider to send such emails. We will maintain the information sent via e-mail in accordance with applicable laws and regulations.

In compliance with the CAN-SPAM Act, all e-mails sent from us will clearly state who the e-mail is from and provide clear information on how to contact the sender. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us. However, you will continue to receive essential transactional emails.

Links to other resources

The Services contain links to other resources that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other resources or third parties. We encourage you to be aware when you leave the Services and to read the privacy statements of each and every resource that may collect Personal Information.

Information security

We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in its control and custody. However, no data transmission over the Internet or wireless network can be guaranteed. Therefore, while we strive to protect your Personal Information, you acknowledge that:-

1. There are security and privacy limitations of the Internet which are beyond our control.
2. The security, integrity, and privacy of any and all information and data exchanged between you and the Services cannot be guaranteed; and
3. Any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.

Data breach

In the event we become aware that the security of the Services has been compromised or users Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the user as a result of the breach or if notice is otherwise required by law. When we do, we will send you an email.

Changes and amendments

We reserve the right to modify this Policy or its terms relating to the Services from time to time at our discretion and will notify you of any material changes to the way in which we treat Personal Information. When we do, we will revise the updated date at the bottom of this page. We may also provide notice to you in other ways in our discretion, such as through the contact information you have provided. Any updated version of this Policy will be effective immediately upon the posting of the revised policy unless otherwise specified. Your continued use of the Services after the effective date of the revised Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Information in a manner materially different than what was stated at the time your Personal Information was collected.

ACKNOWLEDGMENT OF ACCEPTANCE

You acknowledge that you have read this policy and agree to all its terms and conditions. By accessing and using the platform and its services, you agree to be bound by these terms and conditions. If you do not agree to abide by the terms, you are NOT authorized to access or use the HOTSOKO platform.