PRIVACY POLICY

Last updated October 16, 2023

This privacy notice for Eldoret Water and Sanitation Company (‘we’, ‘us’, or ‘our’), describes how and why we might collect, store, use, and/or share (‘process’) your information when you use our services (‘Services’), such as when you:

i. Visit our website at https://eldowas.or.ke/, or any website of ours.

ii. Fill any of our online forms

iii. Engage with us in other related ways, including any events

Questions or concerns?

Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not hesitate to contact us with complaints or suggestions. If you still have any questions or concerns, please contact us at communications@eldowas.or.ke.

What personal information do we process?

When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make and the products and features you use.

Do we process any sensitive personal information?

We do not process sensitive personal information.

Do we receive any information from third parties?

We do not receive any information from third parties.

How do we process your information?

We process your information to provide, improve and administer our Services, communicate with you, for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

In what situations and with which parties do we share personal information?

The information we collect shall not be shared with any third party. But if, part of our process to serve you calls for the need, then we shall communicate to you

How do we keep your information safe?

We have organisational and technical processes; and procedures in place to protect your personal information. Your data will be safe as it will not be shared with a third party.

How do you exercise your rights?

The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable local data protection laws.

1. WHAT INFORMATION DO WE COLLECT?

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You.

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

i. Names

ii. Phone Numbers

iii. Email Addresses

iv. Contact Preferences

v. Location

We do not process sensitive information such as date of birth or National Identity numbers

All personal information that you provide to us should be true, complete and accurate; and you must notify us of any changes to such personal information.

2. HOW DO WE PROCESS YOUR INFORMATION?

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

i. To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.

ii. To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

iii. To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.

iv. To fulfil and manage your requests. We may process your information to fulfil and manage your water accounts, payments, and refunds made through the Services.

v. To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.

vi. To send you notices and publications. We may process the personal information you send to us for our publication’s purposes, if this is in accordance with your

preferences. You can opt out of our emails at any

time by contacting us via E-mail communications@eldowas.or.ke

vii. To deliver targeted notices to you. We may process your information to develop and display personalised content tailored to your interests, location, and more.

viii. To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.

ix. To evaluate and improve our Services, products, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our notices and to evaluate and improve our Services, products and your experience.

x. To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests and exercise, establish or defend our legal rights.

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We may need to share your personal information in the following situations:

i. Complaint resolution. We may share or transfer your information in connection with, or during resolution of your Complaints. This will be done internally within departments during the normal flow and as per our standard operating procedures.

ii. Your information entrusted to us is not intended to be shared to any third party of external entity. But if, part of our process to serve you calls for the need, then we shall communicate to you

4. HOW LONG DO WE KEEP YOUR INFORMATION?

We will only keep your personal information for as long as it is necessary for the purposes set out in services you requested, unless a longer retention period is required or permitted by law.

When we have no need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

5. HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process.

However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet is 100% secure. As we do our best to protect your personal

information in our custody, you should only access the Services within a secure environment.

6. DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly process data from or send notices to children under 18 years of age. By using our Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services.

If we learn that personal information from users less than 18 years of age has been collected, we will take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under the age of 18, please contact us.

7. WHAT ARE YOUR PRIVACY RIGHTS?

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be expressed and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us via E-mail.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of notices and publications: You can unsubscribe from our notices and publication communications at any time by clicking on the unsubscribe link in the emails that we send. You will then be removed from the notices lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your water account, to respond to service requests, or for the purpose of complaint resolution.

If you have questions or comments about your privacy rights, you may email us at communications@eldowas.or.ke

8. UPDATES TO THIS NOTICE

We may update this privacy notice from time to time. The updated version will be indicated by an updated ‘Revised’ date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

9. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please fill out and submit a data subject access request. This can be done by sending an E-mail to communications@eldowas.or.ke

10. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions, suggestions or comments about this notice, you may contact us by email at communications@eldowas.or.ke or contact us by post:

Eldoret Water and Sanitation Company,

Kambi Somali Rd, Off Oloo Street,

PO BOX 8418-30100,

Eldoret, KENYA