Privacy Policy - TREM Africa

Last updated: August 27, 2021

Introduction
Who we are
The data we collect about you
How is your personal data collected?
How do we use your personal data?
Sharing your data
For how long do we retain your personal data?
How do we keep your data secure?
Your legal rights
Your right to opt out of direct marketing

Introduction

This Privacy Policy explains how we collect and use personal data about you when you interact with our website, subscribe to our content and use our services and inform you about your privacy rights and how the law protects you.

It is important that you read this privacy policy together with any other privacy information we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

Who we are

TREM Africa Ltd, registered in Kenya with Reg. no. PVT-LRUA3ZR (hereinafter referred to as “we”, “us” or “our”).

When you interact with our website, subscribe to our content and use our services we are the “data controller”. This means that we are responsible for deciding how we hold and use personal data about you and are required to notify you of the information contained in this privacy policy.

Changes to this Privacy Policy and your duty to inform us of changes

We reserve the right to update this Privacy Policy at any time. We may also notify you in other ways from time to time about the processing of your personal data.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

If you have any questions about this Privacy Policy, please contact us via email info@tremafrica.com.

Third-Party Links

Our website may include links to third-party websites (such as our advertisers), plug-ins (such as Facebook, Twitter, LinkedIn, YouTube and Instagram to allow you to post links and other content from our website) and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the Privacy Policy of every website you visit.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, store and use the following categories of personal data about you:

Identity Data includes first name, last name and title.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information gathered by the use of cookies in your web browser including information about how you use our website and our services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Demographics Data includes information provided by you about your industry, business and interests.
Your communications with us: Enquiries through our Contact Us page, our email exchanges with you or records of telephone calls.
Communications in response to adverts: Enquiries to adverts posted by third parties on our website.
Social media: Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.

We do not collect any Sensitive Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We do not collect any information about criminal convictions and offences.

How is your personal data collected?

We use different methods to collect personal data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

visit our website;
create an account on our website to access our content;
subscribe to our services or publications;
use your account to purchase subscriptions or services;
create and post an advert on our website;
request our products or services (e.g. a digital or print magazine);
send an enquiry using our website in response to an advert posted on our website;
engage with us on our social media pages;
request marketing to be sent to you;
send us an email or contact us through our Contact Us page;
choose to complete a survey we send you or complete a survey on our website;

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

How do we use your personal data?

We aim to provide you with dependable data, analysis and information on the African railway industry, keeping you up-to-date with the latest data, news, events and trends in the rail sector. To do this we will sometimes need to use your personal data in a number of ways depending on your interactions with us and any services you have requested. We will only use your personal data when the law allows us to. We have set out below, in a table format, a description of what we do with your personal data, why we do it, and the legal basis which we rely on. We have also identified our legitimate interests where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us for more details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	(a) Identity (b) Contact	Provide you with our content or services
To process and deliver your purchase including: (a) Manage payments, fees and charges, (b) Collect and recover money owed to us.	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Provide you with our content or services (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or Privacy Policy (b) Asking you to leave a review or take a survey (c) Introducing you to featured content providers and advertisers where you make enquiries	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Provide you with our content or services (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) (d) Consent
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	(a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy). (b) Consent
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)

Trusted third parties

We sometimes share your personal data with trusted third parties such as third-party service providers. We require all third parties to respect the security of your personal data and to treat it in accordance with the law on data protection. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We may also share your personal data with third parties where required by law or where we have another legitimate interest in doing so.

Our industry partners

On some occasions, we may provide your contact details to other companies in our industry for their own purposes, e.g., so they may contact you about services and events you may be interested in. However, we will only do so where we have your informed consent.

Subject to appropriate controls or anonymisation, we may also provide limited data to our advertisers to provide them with insight of our clients.

For how long do we retain your personal data?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of providing you with our content, subscriptions and other products and services.

In some circumstances, we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you. For example, we may collect demographic information from our clients, anonymise it and provide it to our advertisers.

How do we keep your data secure?

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Your legal rights

Your rights in connection with your personal data

Under certain circumstances, you legally have the right to:

Request access to your personal data (commonly known as a “Data Subject Access Request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

If you want us to establish the data’s accuracy.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Your right to opt out of direct marketing

There are several ways you can stop direct marketing communications from us:

opt out of receiving promotional emails and marketing when you create your account or subscribe to any of our content.
if you have an account, log in and change your preferences.
click the ‘unsubscribe’ link in any email communication we send you. We will then stop sending you any further emails from that particular publication or newsletter.

Please note that you may continue to receive communications for a short period after changing your preferences while we update our systems.