Privacy Policy

Queer African Network
Privacy Policy

1.0. WHO ARE WE?
Queer African Network’s website and App (“Site/App”) is operated by Queer African Network (“QAN”, “we”, “us” and/or “our”). Our Services constitute a technology platform that enables users to express their dual African and LGBTQIA+ identity status in a safe space. In this space, you can build a network/community of friends, romantic relationships, find mentors, discover grant and scholarship opportunities as well as share and promote your own artistic expression.

You can contact us as indicated under the “Contact” section in the main navigations.

The privacy policy (“Privacy Policy”) applies to personal data that we collect from you as a user of the Site/App (“you” or “your” being interpreted accordingly). It provides information on what personal data we collect, why we collect it, how it is used and the lawful basis on which your personal data is processed. Additionally, this policy highlights what your rights are under the applicable data protection and privacy laws, including The Data Protection Act (Act No. 24 of 2019) of Kenya. ‘Personal data’ as used in this Privacy Policy and as per Section 2 of The Data Protection Act (Act No. 24 of 2019) means any information relating to an identified or identifiable natural person. By using our Site/App, or submitting your personal data you are taken to accept the terms of this Privacy Policy, so please read it carefully.

We collect the following personal data about you:
● Registrations: The personal details you provide when creating an Account, such as your email address, name, phone number, year of birth, payment and billing details or other information we require for the purpose of recording and processing you. For further details please also refer to the section below headed “Payment Information”.
● Customer Transaction: The personal details you provide when you are registering or purchasing a ticket for an event (such as Book Club meetings). These transactions include your full name, address, email address, phone number, gender, approximate age, industry, career level, and other information that you elect to provide to support your application such as your full name, email address, and billing and payment information. For further details please also refer to the section below headed “Payment Information”.
● Other Information: Personal details you choose to give when corresponding with us by phone, email, or our social media platform(s), participating in user surveys, or otherwise visiting and interacting with our Site/App.

● Log Data: When you visit our Site/App, our servers record information (“log data”), including information that your browser automatically sends whenever you visit our Site/App. This log data includes your Internet Protocol (“IP) address (from which we understand the country you are connecting from at the time you visit the Site/App), browser type and settings, the date and time of your request.
● Our Site/App uses cookies (small text files placed on your device) and similar technologies to distinguish you from other users. This is to provide you with a good user experience when you browse our Site/App and allows us to improve its features.

We use your personal data in the following ways:
● To acknowledge and confirm your newly created account.
● To contact you in connection with user surveys and use any information you choose to submit in response, provided that you gave us your consent to be contacted in this way at the time you provided us with the personal data.
● From time to time, we may organize contests and other promotions. If you share information with us directly or through one of our third-party service provides, we may use the email address you provided in order to notify you of the results.
● QAN, and our affiliated businesses, may provide you, or permit selected third-party service provides to provide you with information about goods and services, events and other promotions we feel may interest you as a user. We (or such third-party providers) will contact you by email only with your consent, which was given at the time you provided us with the personal data.
● We may use your personal data for other purposes which you have consented to at the time of providing your data.
● As necessary for certain legitimate business interests, meaning the interests of QAN or affiliates businesses, in conducting and managing QAN. When we process your personal data for our legitimate interests, we make sure to consider and balance any potential impact on you, and your rights under the data protection laws. These legitimate business interests include
o Where we are asked to deal with any inquiries or complaints you make.
o To protect the vital interests of you or another person.
o To administer our Site/App, to better understand how customers interact with our websites/app and ensure that our Site/App is presented in the most effective manner for you and for your computer/device.
o To conduct analytics to inform our marketing strategy and enable us to enhance and personalize the experience we offer to our users.
o If you ask us to delete your data or to be removed from our marketing lists and we are required to fulfil your request, to keep basic data to identify you and prevent further unwanted processing.
o To share personal data among our affiliated businesses for administrative purposes, for providing user services, and in relation to our sales and marketing activities.
o We may anonymise, aggregate and de-identify the data that we collect and use such anonymised, aggregated and de-identified data for our own internal business partners, including sharing it with our current and prospective users, business partners, our affiliated businesses, agents and other third parties for commercial statistical and market research purposes, for example to allow those parties to analyse patterns among groups of people, and conducting research on demographics, interests and behaviour.
o For internal business/technical operations, include troubleshooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to keep our Site/App, network and information systems secure.
o To comply with legal obligations.
o To respond to requests from competent authorities.
o To enforce our Terms of Use.
o To protect our operations or those of any of our affiliated businesses.
o To protect your rights, safety or property, and/or that of our affiliated businesses, you or others.
o To enforce or defend legal rights, or prevent damage.

We share your personal data with third parties in the following situations:
● Service Providers: QAN, like many businesses, sometimes hires selected third parties who act on our behalf to support our operations, such as
o Card processing or payment services (see the section below headed “payment Information”)
o Credit reference agencies to protect against possible fraud
o IT supplies and contractors (e.g. data hosting providers or delivery partners) as necessary to provide IT support and enable us to provide users services and other goods/services available on this Site/App or to members
o Web analytics provides
o Providers of digital advertising services and
o Provides of, markets and sales software solutions.
Pursuant to our instructions, these parties may access, process or store your personal data in the course of performing their duties to us and solely in order to perform the services we have hired them to provide.
● QAN’s affiliated businesses: In order to provide the services you request from us, our affiliated businesses may access and process the information which we collect from you for the purposes described above, including to offer products and services to you. Our affiliates businesses will only use your data for the purposes for which we originally collected it.
● Business Transfers: if we sell our business or our company assets are acquired by a third party, personal data held by us about our users may be one of the transferred assets.
● Administrative and Legal Reasons: if we need to disclose your personal data
o To comply with a legal obligation and/or judicial or regulatory proceedings, a court order or other legal process
o To enforce our Terms of Use or other applicable contract terms that you are subject to or
o To protect us, or our users against loss or damage.
This may include (without limit) exchanging information with the police, courts or law enforcement organisations.

● Any credit/debit card payments and other payments you make through our Site/App will be processed by our third party payment providers and the payment data you submit will be securely stored and encrypted by our payment service providers using up to date industry standards. Please note that we do not ourselves directly process or store the debit/credit card data that you submit, or any other payment data.
● We may arrange that card or payment data you submit in support of a member or customer transaction fee to be stored for the purpose of processing your member or customer transaction fees.
● You may choose to opt out of our third-party payment providers holding your card or payment data although this means that you will need to re-supply us with card/payment details to initiate your membership subscription fee or for the purpose of making any future purchases.

● Your personal data may be transferred to and stored in countries other than the country in which the information was originally collected, including countries and other destinations outside the Republic of Kenya to our service provides and affiliates businesses for the purposes described above.
● Where we transfer your personal data to countries outside of the Republic of Kenya we will take all steps to ensure that your personal data will continue to be protected. We will implement appropriate safeguards for the transfer of personal data to our service provides in accordance with the applicable law.

● Where we have given you (or where you have chosen) a password or log-in which enables you to access certain restricted parts of our Site/App, you are responsible for doing everything you reasonably can to keep these details secret. You must not share your password or long-in details with anyone else.
● Unfortunately, the transmission of information over the internet or public communications network can never be completely secure. However, we will take appropriate technical and organisational security measures to protect the personal data that you submit to us against unauthorised/unlawful access or loss, destruction or damage, although we cannot 100% guarantee the security of personal data that you provide to us online.

● We will keep your personal data only for as long as is reasonably necessary for the purposes outlined in this Privacy Policy, or for the duration required by any legal regulatory, accounting or reporting requirements, whichever is the longer. In particular, we retain membership records for six years after expiration or termination of your membership. We retain information submitted through the Site/App for two years following account closure or contact with you, as applicable. When you consent to receive marketing communications, we will keep your data until you unsubscribe.
● To determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of the personal data, the purposes for which we process your personal data, applicable legal requirements, or operational retention needs, and whether we can achieve those purposes through other means.
● Upon expiry of the applicable retention period we will securely destroy your personal data in accordance with applicable laws and regulations. In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case it is no longer personal data.

Certain applicable data protection laws give you specific rights in relation to your personal data. In particular, you have the following rights in relation to your personal data:
● Right to be informed: You have the right to be informed of the use to which your personal data is to be put.
● Right of access: If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a digital copy of that personal data along with certain other details such as the purposes of the data processing. If you require additional print copies, we may need to charge a reasonable fee.
● Right of rectification: If your personal data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your personal data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data so you can contact them directly.
● Right to erasure: You may ask us to delete or remove your personal data, such as where our legal basis for the processing is your consent and you withdraw consent. If we shared your data with others, we will tell them about the reassure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data so you can contact them directly. We may continue processing personal data where this is necessary for a legitimate interest in doing so, as described in this Privacy Policy.
● Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your personal data in certain circumstances, such as where you contest the accuracy of the personal data or object to us processing it. We will tell you before we lift any restriction on processing. If we share your personal data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data so you can contract them directly.
● Right to data portability: You have the right to obtain your personal data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you. we will provide you with your personal data in a structured, commonly used and machine-readable format. You may reuse it everywhere.
● Right to object: You may ask us at any time to stop processing your personal data, and we will do so:
o If we are relying on a legitimate interest to process your personal data— unless we demonstrate compelling legitimate grounds for the processing or
o If we are processing your personal data for direct marketing.
● Right to withdraw consent: If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing of your data before we received notice that you wished to withdraw your consent.
If you wish to exercise any of these rights, please contract us as described in the “Contact” section below. We may also need to ask you for further information to verify your identity before we can respond to any request.

● If you wish to delete your profile, you can access it through the profile settings and immediately delete your account.
● It should be noted that it may not be technologically possible to remove each record of the information you have provided to us from our servers. The need to back-up our systems to protect information form inadvertent loss means that a copy of your Profile may exist in a non-erasable form that may be difficult or impossible for us to locate.
● In addition, we have the right to delete any account at any time if required to do so by process of law, or if necessary in order to investigate fraud, a violation of our Terms of Use or in connection with any harm being caused to a third party or their rights.

Any changes we may make to our Privacy Policy in the future will be posted on this page. Please check back frequently to see any updates or modifications. If required by the applicable law, we will notify you of any material or substantive changes to this Privacy Policy through an email sent to the account associated with your profile. However, It is the user’s responsibility to periodically check our Privacy Policy to keep oneself updated.

We use cookies to understand how you use our site and to improve your experience, this includes personalising content and advertising. By continuing to use our site, you accept our use of cookies.

Questions, comments or requests regarding this Privacy Policy should be addressed to [email protected].

This Privacy policy will come into effect from 1st January 2022.