Introduction

This website is maintained by eKitabu, LLC.

The security of that data is very important to us. In this document, we will explain how we collect, use and protect your personal data.

We will also explain what rights you have with regard to your personal data and how you can exercise those rights.

Personal data

Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:

“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

How we use your information

This privacy policy tells you how eKitabu, LLC will collect and use your personal data to manage your use of our websites (listed in Section 3, below) software applications, ebooks, online learning, and in-person and virtual events.

Why does eKitabu need to collect and store personal data?

In order for us to provide you with the information on our websites, deliver ebooks you purchase or read for free, engage in online learning, and participate in our events we need to collect personal data to keep our websites and underlying infrastructure secure, to meet our contractual obligations with third parties, to process payments, and for tax and audit purposes. In any event, we are committed to ensuring that the information we collect, and use is appropriate for this purpose, and does not constitute an invasion of your privacy.

For marketing purposes, eKitabu will request your consent before contacting you.

Will eKitabu share my personal data with anyone else?

We may pass your personal data on to third-party service providers contracted to eKitabu, LLC in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to process information for eKitabu and fulfill the service they provide to eKitabu on your behalf. When they no longer need your data to fulfill this service, they will dispose of the details in line with eKitabu’s procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.

How will eKitabu use the personal data it collects about me?

eKitabu will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavor to keep your information accurate and up to date, and not keep it for longer than is necessary. eKitabu is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

Who we are

eKitabu, LLC maintains this website. This means that eKitabu, LLC determines what data is collected, how this data is going to be used, and how this data is protected.

Our registered office address is:

eKitabu, LLC

Rainbow Tower, 5th floor,

Nairobi Kenya

If you have questions about how we process personal data or would like to exercise your data subject rights, please email us at privacy@ekitabu.com or by phone at +254 708 727 037.

Websites within scope

The following websites are within the scope of this privacy policy:

www.ekitabu.com
www.languagebeforeliteracy.org
www.digitalliteracytrust.org

Collection of personal data

We collect personal data from you for one or more of the following purposes:

• To provide you with information that you have requested or that we think may be relevant to a subject in which you have demonstrated an interest.
• To initiate and complete commercial transactions with you, or the entity that you represent, for the purchase of products and/or services.
• To ensure the security and safe operation of our websites and underlying infrastructure.
• To manage any communication between you and us.

The table in section 5 below provides more detail about the data that we collect for each of these purposes, the lawful basis for doing so, and the period for which we will retain each type of data.

Technical information

In addition, to ensure that each visitor to any of our websites can use and navigate the site effectively, we collect the following:

• Technical information, including the IP (Internet Protocol) address used to connect your device to the Internet.
• Your login information, browser type, and version, language preference, time zone setting
• Operating system and platform.
• Information about your visit, including the URL (Uniform Resource Locators) clickstream to, through, and from our site.

Our cookies policy, which can be viewed from the home page of each of our websites, describes in detail how we use cookies.

In section 8 below, we identify your rights in respect of the personal data that we collect and describe how you can exercise those rights.

The basis for the processing of personal data

The table below describes the various forms of personal data we collect and the lawful basis for processing this data. Our business architecture, accounting and systems infrastructure, and compliance organization means that all personal data is processed on common platforms. We have processes in place to make sure that only those people in our organization who need to access your data can do so. A number of data elements are collected for multiple purposes, as the table below shows. Some data may be shared with third parties; where this happens, is also identified below.

When we process on the lawful basis of legitimate interest, we apply the following test to determine whether it is appropriate:

The purpose test – is there a legitimate interest behind the processing?

Necessity test – is the processing necessary for that purpose?

Balancing test – is the legitimate interest overridden, or not, by the individual’s interests, rights, or freedoms?

eKitabu, LLC in the United States Limited Liability Company with offices in the US, Kenya, and Rwanda.

• Our websites are hosted in the EU, Africa, and the US.
• We use a wide range of CSPs (Cloud service providers) as part of our processing environment. Unless we specifically state otherwise, we are, in respect of all these CSPs, the data controller.
• Our payment processors and banking arrangements are based in Kenya, Rwanda, and the United State.
• We operate a data retention policy in respect of all data, whether paper-based or digital

Security measures

We have what we believe are appropriate security controls in place to protect personal data. Risk assessment, including assessing risks to the rights and freedoms of data subjects. We do not, however, have any control over what happens between your device and the boundary of our information infrastructure. You should be aware of the many information security risks that exist and take appropriate steps to safeguard your own information. We accept no liability in respect of breaches that occur beyond our sphere of control.

Your rights as a data subject

As a data subject whose personal information we hold, you have certain rights. If you wish to exercise any of these rights, please email privacy@ekitabu.com or use the information supplied in the Contact us section below. To process your request, we will ask you to provide two valid forms of identification for verification purposes. Your rights are as follows:

The right to be informed
As data controllers, we are obliged to provide clear and transparent information about our data processing activities. This is provided by this privacy policy and any related communications we may send you.

The right of access
You may request a copy of the personal data we hold about you free of charge. Once we have verified your identity and, if relevant, the authority of any third-party requestor, we will provide access to the personal data we hold about you as well as the following information:

• • The purposes of the processing
  • The categories of personal data concerned
  • The recipients to whom the personal data has been disclosed
  • The retention period or envisioned retention period for that personal data
  • When personal data has been collected from a third party, the source of the personal data

If there are exceptional circumstances that mean we can refuse to provide the information, we will explain them. If requests are frivolous or vexatious, we reserve the right to refuse them. If answering requests is likely to require additional time or occasions unreasonable expense (which you may have to meet), we will inform you.

The right to rectification
When you believe we hold inaccurate or incomplete personal information about you, you may exercise your right to correct or complete this data. This may be used with the right to restrict processing to make sure that incorrect/incomplete information is not processed until it is corrected.

The right to erasure (the ‘right to be forgotten)
Where no overriding legal basis or legitimate reason continues to exist for processing personal data, you may request that we delete the personal data. This includes personal data that may have been unlawfully processed. We will take all reasonable steps to ensure erasure.

The right to restrict processing
You may ask us to stop processing your personal data. We will still hold the data but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies you may exercise the right to restrict processing:

• • The accuracy of personal data is contested.
  • Processing personal data is unlawful.
  • We no longer need personal data for processing but personal data is required for part of a legal process.
  • The right to object has been exercised and processing is restricted pending a decision on the status of the processing.

The right to data portability
You may request your set of personal data be transferred to another controller or processor, provided in a commonly used and machine-readable format. This right is only available if the original processing was on the basis of consent, the processing is by automated means, and if the processing is based on the fulfillment of a contractual obligation.

The right to object
You have the right to object to our processing of your data where

• • Processing is based on legitimate interest;
  • Processing is for the purpose of direct marketing;
  • Processing is for the purposes of scientific or historic research; or
  • Processing involves automated decision-making and profiling.

Contact us

Any comments, questions, or suggestions about this privacy policy or our handling of your personal data should be emailed to privacy@ekitabu.com

Alternatively, you can contact us using the following postal address or telephone numbers:

Rainbow Tower, 5th floor,

Nairobi, Kenya

Phone: +254 708 727 037

Complaints

Should you wish to discuss a complaint, please feel free to contact us using the details provided above. All complaints will be treated in a confidential manner.