What is this?
This policy may change from time to time so please check this page occasionally to ensure that you’re happy with any changes.
We, COSEF, Ltd. (company number 80020002062516), is the owner of the site (www.cosefinvest.com) and the data controller in relation to the processing activities described below. This means that we decide why and how your personal data is processed.
When you use this website, our products or services, the categories of information that we may collect about you are as follows:
Personal data you give to us: this includes information about you that you give to us by entering information via:
and is provided entirely voluntarily. This includes information provided at the time of registering to use our site, subscribing to the services we provide through our site (including newsletters), posting material or requesting further services. We may also ask you for information when you report a problem with our site. If you complete any surveys that we request you complete for research purposes, we will collect information in such circumstances as well.
The information you give us includes your name, address, email address, phone number, enquiry details and may include records of any correspondence and responses to any surveys.
We have a separate privacy notice in respect of job applicants and the personal data collected when individuals apply for job opportunities at COSEF.
Personal data we collect about you: we may automatically collect the following information:
Personal data we may receive from other sources: we may receive certain personal data about you from sources outside of our business which may include our group companies. This may include your name, address, email address, phone number, enquiry details, records of any correspondence and responses to any surveys.
The purposes for which we use your information and the legal basis under data protection laws on which we rely to do this are explained below.
Where there is a LEGITIMATE INTEREST
We may use and process your personal data where it is necessary for us to pursue our legitimate interests as a business, or that of a third party, for the following purposes:
Where you have provided CONSENT
We may use and process your personal data where you have consented for us to do so, including in order to contact you via email with information about our us and our group companies if you sign up to our newsletter emails via our website or other medium where available.
You may withdraw your consent for us to use your information in any of these ways at any time. Please see Withdrawing your consent for further details.
Where there is a LEGAL REQUIREMENT
We will use your personal data to comply with our legal obligations: (i) to assist any public authority or criminal investigation body; (ii) to identify you when you contact us; and/or (iii) to verify the accuracy of data we hold about you.
Companies in our network
We may share your information with other companies within COSEF network. They may use your personal data in the ways set out in How we use your personal data, in connection with business strategy analysis, business management or administration, and to assist in the provision of services to you. They may also process personal data on COSEF’s behalf for the purposes of providing services to us.
Our suppliers and service providers
We may disclose your information to our third party service providers, agents, subcontractors and other organisations for the purposes of providing services to us or directly to you on our behalf. Such third parties may include IT and cloud service providers (such as hosting and email management), technical and professional advisors (including accountants and lawyers), advertising and marketing agencies and administrative services.
When we use third party service providers, we only disclose to them any personal data that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.
Customer satisfaction surveys
As customer satisfaction is important to us, we may ask a third party research company to contact you for the sole purpose of gathering general information and specific information relating to us and our products and services.
Other ways we may share your personal data
We may transfer your personal data to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation. We may also transfer your personal data if we’re under a duty to disclose or share it in order to comply with any legal obligation, to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and customers. We will always take steps with the aim of ensuring that your privacy rights continue to be protected.
COSEF is a regional organisation, currently with entities in Uganda and Kenya, but poised for expansion. As a result, all information you provide to us may be transferred to other third countries, including to countries outside East Africa. These countries may not have equivalent or similar data protection laws to the country in which you are located.
If we transfer your personal data to a ‘third country’ outside of East Africa in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this policy. These steps include imposing contractual obligations on the recipient of your personal data that aim to ensure adequate protection or ensuring that the recipients are subscribed to international frameworks that aim to ensure adequate protection.
Please contact us using the details at the end of this policy for more information about the protections that we put in place and to obtain a copy of the relevant documents.
If we collect your personal data, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws. Subject to other applicable laws (e.g. tax requirements), personal data (in an identifiable format) should not be kept longer than is necessary for the purposes for which it was collected and processed.
COSEF has implemented and maintains a separate Data Retention Policy that sets out the specific retention periods in which different categories of personal data will be retained. If you would like further information in respect of these retention periods, please contact us at the details at the end of this policy.
When it is no longer necessary to retain your personal data, we will delete the personal data that we hold about you from our systems. After that time, we may aggregate the data (from which you cannot be identified) and retain it for analytical purposes.
The only exceptions to this are where:
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted to our website and any transmission is at your own risk. Once we have received your personal data, we put in place reasonable and appropriate controls to ensure that it remains secure against accidental or unlawful destruction, loss, alteration, or unauthorised access.
Where we have given (or where you have chosen) a password which enables you to access an account, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Our website may contain links to other websites run by other organisations. This policy does not apply to those other websites‚ so we encourage you to read their privacy statements. We cannot be responsible for the privacy policies and practices of other websites even if you access them using links that we provide. In addition, if you linked to our website from a third party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website and recommend that you check the policy of that third party website.
We may collect your preferences to receive marketing information directly from us by email if you opt in to receive our newsletter then we receive your name and email address.
We may contact you through targeted advertising delivered online through social media and platforms operated by other companies, unless you object.
The below data subject rights shall only apply to the extent applicable under the data protection laws of the country in which you are located. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal data. Except in rare cases, we will respond to you in accordance with any timescales set by the applicable data protection laws of the country in which you are located, which is usually within one month from either (i) the date that we have confirmed your identity or (ii) where we do not need to do this because we already have this information, from the date we received your request.
We may review this policy from time to time and any changes will be notified to you by posting an updated version on our website and/or by contacting you by email. Any changes will take effect 7 days after the date of our email or the date on which we post the modified terms on our website, whichever is the earlier. We recommend you regularly check for changes and review this policy whenever you visit our website. If you do not agree with any aspect of the updated policy, you must immediately notify us and cease using our services.
Please contact us using the details in section 13 below if you have any concerns or complaints about the way we have collected or processed your personal data. We will investigate your complaint and respond to you in writing within 30 days.
If you have any queries about this policy or about the way we process your personal data please contact us by sending an email to firstname.lastname@example.org