GALACHA COMPANY LIMITED Privacy Policy
1 INTRODUCTION
GALACHA Company Limited (“GALACHA”], “Us”, “We”, “Our”) registered in United Republic of Tanzania under company number 113207 Our TIN registration number is 136-449-125 .
We respect your privacy and we are committed to protecting your personal Information. We comply with the principles of the Act (The Electronic and Postal Communication Act (CAP.306) and The Electronic and Postal Communications (Online Content) Regulations, 2018) and aim to maintain consistently high levels of best practice in our processing of your Information.
This Privacy Policy (“Policy”) is intended to inform you how we collect, use and disclose your personal data. This Policy is intended to assist you in making informed decisions about your Information when using our websites, Apps, Products or the services provided by us. Please take a few moments to read and understand the Policy.
By using our websites, apps or services you consent to our collection and use of your Information as described in this Policy. If we change our Policy and/or procedures, we will update this Policy to keep you aware of what Information we collect, how we use it and under what circumstances we may disclose it. Your continued use of the website or services after this Policy has been amended shall be deemed to be your continued acceptance of the terms and conditions of this Policy, as amended. We encourage you to bookmark this Web page and review this Policy regularly.
In addition to this Policy, each service offered by us or our group companies may have additional privacy provisions that are specific to the particular service. These supplemental disclosures are made adjacent to the particular service at the time your Information is collected. A list of our group companies can be seen at the end of this document.
2 WHAT INFORMATION DO WE COLLECT?
All your Information will be held and used in accordance with the Act where applicable. If you want to know what Information we collect and hold about you, please email us at: info@galacha.com, or write to us at the address given at the end of this Policy. When you visit and use our websites, products or request our services you may provide us with or we may collect your Information such as your postal address, email address and other personal information. You may provide or we may collect this Information in a number of ways:
2.1 Information you voluntarily provide to us
We collect and maintain Information that you voluntarily submit to us during your use of our website, applications or services. For example:
• When you register on our website or for a product or service, you may provide us with certain Information including your name, email address, user name, password and demographic Information
• If you sign up to our service via a social network we may use the profile Information you enable us to access regarding your interests.
• If you sign up to receive a newsletter, a magazine, enter a competition or participate in social networking activities, you may provide us with contact Information (e.g., email, telephone and/or or physical address)
• You may provide us with Information in the course of email, customer support interactions and surveys.
Different websites and Apps operated by us may ask for different pieces of Information. You can choose not to provide us with certain Information, but this may stop you from gaining access to a service or limit the features that you can use on our websites. For more Information, please see the “How We Use Your Information” section of the Policy below.
2.2 Information we collect through your use of our Websites and Apps
As you use our website or Apps, Information may also be passively collected by us through our use of cookies, flash cookies, web beacons, pixels, log files, and other technologies. This Information allows us to deliver more helpful Information, services, tools and advertisements.
2.3 Information we receive from third parties
We may also combine online and/or offline Information received from third parties (including other members of our group of companies – see point 15) with your Information. The third party Information is used for a variety of purposes including to verify other Information about you (e.g., verify your mailing address to send you requested products or services) and to enhance the content and relevance of the advertising we provide to you.
3 PROTECTION OF CHILDREN’S PERSONAL INFORMATION
3.1 Most of our sites/Apps are not designed for children, but one or two may receive visits by children and young people under the age of 16 and we encourage them to speak to their parents before submitting any personal Information on any of our sites.
3.2 We recommend that parents or guardians supervise young people while they are online.
3.3 We are dedicated to the protection of children’s and young people’s personal Information and we do not knowingly market to children.
3.4 If you are under 16 years of age you should always ask your parent or guardian before:
• Responding to anything on any of our sites
• Asking us to send anything to you or another young person
• Enter a competition or a game online – you must generally be over 16 years of age to enter, but please do check the specific Terms & Conditions for each instance.
• Post anything on a bulletin board or any chat room
• Offer to agree to buy anything online
3.5 A parent or guardian may submit a request to info@galacha.com to stop any further use of a child or young person’s personal Information or to request that we suppress any Information as far as we are able. Before disclosing Information about a child, we may request that the parent or guardian provide reasonable Information for identification purposes.
4 HOW WE USE YOUR INFORMATION
We will use your Information in the ways described below and as described at the time that the Information is collected.
4.1 To Provide the Services
In general, we use your Information as necessary or appropriate for our business purposes including to:
• Administer your account where you have opened an account with us
• Register you and provide you access to the website or services requested by you
• Respond to inquiries or requests that you direct to us
• Fulfil your requests for products or services
• Send communications and administrative emails about the website or our services
• Personalise and better tailor the features, performance and support of the website and our services for your use; analyse, benchmark and conduct research on user data and user interactions with the website and our services
• Run competitions
• Deliver customer services
• Other purposes related to any of the above
4.2 Marketing
Where you have provided us with the appropriate consents, or where the Act entitles us to do so, we may send you marketing materials about other products or services offered by GALACHA through its Product Mix.
In addition, where you have provided us with the appropriate consents, we may also pass your Information for marketing purposes or host messages on behalf of one or more of our group companies (see point 15) or other selected third parties in the following sectors where the Information they provide will be relevant to you: Professional Associations, Automotive, Charity, Education and Training, Recruitment, Business and Leisure Travel, Events, Conferences and Exhibitions, Financial Services, Surveys and Research, Media, Broadcast and Marketing, Publishing and Subscriptions, Business and Information Services, Electronics, computers, Software and AV, Sports and Sportswear, Gaming, Betting, Telecoms and Retail and Partners and Sponsors of Promotions, Events and Competitions.
However, be assured that we understand the irritations of unsolicited communications and we are fully committed to ensuring the rights and obligations set out in THE ELECTRONIC AND POSTAL COMMUNICATIONS ACT and THE ELECTRONIC AND POSTAL COMMUNICATIONS (ONLINE CONTENT) REGULATIONS, 2018 are respected.
4.3 Behavioural Advertising – customer-relevant advertising
We believe that advertising is more interesting to you when it is relevant. Accordingly, we may customise the advertisements that you see based upon:
• The Information you voluntarily provide to us
• Geographic location Information, which we may determine through your IP address, from your mobile device, or other ways
• Data we receive from third parties
• Your visits to our website or your use of our services (commonly referred to as “Behavioural Advertising”).
• Advertisers or other third parties using our website may also engage in Behavioural Advertising and use cookies and other technologies s in the manner in our Cookie Policy. We do not control these advertisers or other parties’ use of cookies or other technologies or what they do with the Information they collect.
You can limit the way that we tailor advertising based on your Information by objecting to the cookies that we or third parties wish to place on your browser or deleting the cookies that we or third parties have placed on your browser.
After you have exercised your right to object or reject the use of cookies, you may still see advertisements, but the advertising may not be as relevant to your interests. If you change your computer, change your browser or delete certain cookies, you will need to renew your preferences.
5 HOW WE DISCLOSE YOUR INFORMATION TO THIRD PARTIES
We may share your Information with third parties as specifically approved by you or under the circumstances described below and in this Policy.
5.1 Disclosure for legal reasons
We may disclose your Information if we are under a duty to disclose or share your Information to comply with any legal obligation or in order to enforce or apply or fulfil our terms and conditions and other agreements or protect the rights, property, or safety of our customers, our group companies or others. This includes exchanging Information with other companies and organisations for fraud protection and credit risk reduction.
We use a number of third party organisations to help provide a professional service to our customers (i.e. fulfilment bureaus, call centres, and website designers). These organisations act as data processors and are strictly contractually controlled in how they may/may not use your Information and we remain responsible for the protection of your Information.
5.2 Promotions and Sponsors
Some or all of the Information collected during a promotion, contest or poll (“Promotions”) may be disclosed publicly. It may also be shared with other third parties as disclosed and consented to by you at the time of collection or in the Promotion rules. These third parties may include providers of prizes in order to update you of your status of your prize or other fulfilment needs or a co-sponsor who may use your Information to administer the Promotion or for their marketing purposes, but only in conformance with your consent, or with the terms published at the time your personal data is collected. We are not responsible for the privacy policy or practices of third parties.
When you participate in a Promotion, you are subject to any official rules for that Promotion, which may contain additional Information about the specific privacy practices associated with the Promotion.
5.3 Changes to our Company
In the event we go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Information may be among the assets transferred. You acknowledge that such transfers may occur and are permitted by this Policy.
5.4 Message Boards and Chats
We may make message boards, chat rooms, and other interactive forums available as part of our services. You should be aware that any Information which you post to these interactive forums or otherwise choose to make publicly available, may be disclosed and available to all users who have access to that portion of our website or services. By using these interactive forums, you agree that we are not responsible for any Information that you disclose or communicate in such forums, and any disclosures you make are at your own risk.
6 UPDATING AND CONTROL OF YOUR INFORMATION
There are a number of ways in which you can control the collection, use, and sharing of your Information and update your Information and preferences.
6.1 Opting-Out on Receipt of Marketing Communications
When you receive electronic marketing communications from us you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in e-mails covering any marketing communication from us.
6.2 Contacting Us
If your Information has changed or if you no longer wish to receive marketing communications from us then you can amend your Information or update your preferences.
Please note that:
• Even if you delete Information, we may retain your Information in conformance with our data retention policy most specifically for legal and tax reasons and to honour your opt-out requests; and
• We do not keep Information longer than we deem necessary.
• We are not responsible for updating or removing your Information contained in the lists or databases of third parties who have previously been provided with Information as permitted by this Policy.
7 THIRD PARTY LINKS AND SERVICES
Please remember that when you use a link to go from our website to another website or you request a service from a third party, our Policy no longer applies. Your browsing and interaction on any other website or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies. We do not monitor, control, or endorse the Information collection or privacy practices of any third parties. We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices. This Policy applies solely to Information collected by us through our website or services and does not apply to these third party websites and third party service providers.
8 SECURITY OF YOUR INFORMATION
We follow appropriate security procedures in the storage and disclosure of your Information so as to prevent unauthorised access by third parties. We also require those parties to whom we transfer personal Information to comply with the same. However, unfortunately, the transmission of Information via the Internet is not completely secure. So, we cannot ensure the security of your Information transmitted by you to us via the internet. Any such transmission is at your own risk and you acknowledge and agree that we shall not be responsible for any unauthorised use, distribution, damage or destruction of your Information, except to the extent we are required to accept such responsibility by the Act. Once we have received your Information we will use security procedures and features to prevent unauthorised access to it.
9 REPORTING OF SECURITY VULNERABILITIES
GALACHA Co. Ltd is committed to the privacy, safety and security of our customers. If you discover potential security vulnerability, we would appreciate it if you could report it just to us in a responsible manner. Please email us at info@galacha.com and we will respond to you as soon as possible. This provides us with an opportunity to work with you and quickly address and resolve any issue. Publicly disclosing a potential vulnerability could put the wider community at risk, and therefore we encourage you to come to us first. We’ll keep you informed as we move forward with our investigations.
10 SOCIAL MEDIA
10.1 GALACHA provides users with the ability to use their social media credentials to sign in to our website(s) or Apps.
When you create your account in our websites or Apps, and authenticate via a third-party service like Twitter or Facebook, you grant permission to the social network to share your user details with us.
Depending on the network this will include
• Basic account Information included in your public profile such as name and email address required to verify and facilitate your sign in
• Other Information that is publically available based upon the privacy settings you have with your social media account.
• Any other details you choose to share according to your specific account settings.
We will be clear when we do request more than just basic account Information from you and request that you should also check what permissions we are asking for before you connect with these apps and services. We want to use this Information to better tailor any content we provide to you.
Social sign-in may be provided by GALACHA Websites/Apps or a third party
10.2 Social networking sites, such as Facebook, Linked-In, among others, work with us as trusted third party partners. We also work with application developers who specialize in social media, so that we can connect with your social networks. We provide access to our Websites for third parties and business partners so that we can generate interest in our products and services among members of your social networks and to allow you to share product and service interests with friends in your network.
10.3 We do not control how your personal Information is collected, stored or used by such third party sites or to whom it is disclosed. You should review the privacy policies and settings on any social networking site that you subscribe to so that you understand the Information they may be sharing. If you do not want your networking sites to share Information about you, you must contact that site and determine whether it gives you the opportunity to opt-out of sharing such Information. GALACHA is not responsible for how these third party sites may use Information collected from or about you.
11 ANTI-SPAM POLICY
GALACHA provides exciting and thought-provoking content in our emails and aims to tailor them to the specific needs & interests of our brand audiences. We hope you enjoy receiving and reading them.
GALACHA has zero tolerance concerning the sending of unsolicited/bulk commercial email – “spam”.
11.1 Automated Spam Filtering: We automatically scan all incoming electronic messages and filter out those that appear to be spam. As no system can be 100% accurate in detecting genuine emails from spam, authentic messages may occasionally be filtered. If you believe this may have happened, please contact the recipient by another means.
11.2 Unwanted messages from GALACHA: Any recipient of email communication from us may request, at any time, to unsubscribe. In the unlikely event you are in receipt of email communication from GALACHA which could be considered as spam, we encourage you to report it to us by forwarding a copy to us at: info@galacha.com
We will fully investigate any reports of abuse.
12 HOW TO CONTACT US
If you have any questions regarding privacy or this Policy, you may contact us as follows:
GALACHA Co.Ltd | P.O.BOX 3969 Kimara, Dar es salaam, Tanzania , Email us: info@galacha.com
13. LIST OF THE GALACHA products
• Kandanda.co.tz website & App
• Spocha app
• GALACHA Wear
Changes to this Policy
We may amend/update this policy by publishing a new version on this website at any time, so we encourage you to check back regularly to make sure that you are still happy with the terms under which we process your personal data.
April 30th, 2018.
