Introduction

Destreza is strongly committed to protecting your personal information. This Privacy Policy describes how Destreza handles personal information collected through the sites on www.destrezalimited.com that link to this Privacy Policy (collectively, “the Websites”).

By using the Websites and providing personal information to us, you acknowledge you have read this Privacy Policy, and, to the extent your consent is necessary and valid under applicable law, you consent to the collection, use and disclosure of such personal information by the Destreza network and any third party recipients in accordance with this Privacy Policy.

As used in this Privacy Policy and the Websites, Destreza, us, and we refer to the Destreza network and/or one or more of its Member Firms or Associates that may process your personal information. In this Privacy Policy, your information is sometimes called “personal data” or “personal information”. We also sometimes collectively refer to handling, collecting, protecting or storing your personal information as “processing” such personal information.

Third party links

The Websites may link to third-party sites not controlled by Destreza and which do not operate under Destreza’s privacy practices. When you link to third-party sites, Destreza’s privacy practices no longer apply. We encourage you to review each third-party site’s privacy policy before disclosing any personally identifiable information.

Collection of personal information

When you use our Websites, we may collect information about you and your use of the relevant site, including through cookies and analytics tools.  We may collect personally identifiable information about you, such as your name, job title, company name, address, email address, and telephone number, either directly from you or by combining information we collect via the Websites with personal information we collect and maintain through other means (such as client relationship management systems or identification and access management systems, including IP addresses) or as we may receive from social media or other third-party sites.

Below are some examples of how you may provide personal information to Destreza:

  • searching and browsing for content;
  • subscribing to or ordering newsletters and/or publications;
  • registering for premium online services;
  • participating in “join our mailing list” initiatives;
  • participating in bulletin boards, discussion or message forums;
  • entering Quick Surveys, Quizzes or Benchmarking Surveys;
  • registering for events and conferences;
  • submitting resumes or work history information;
  • contacting us for further information;
  • visiting our Websites while logged into a Social Media platform; and/or
  • providing us with business cards or other contact information.

We do not intend to collect sensitive information through the Websites unless we are legally required to do so. Examples of sensitive information include race or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; physical or mental health; genetic data; biometric data; sexual life or sexual orientation; and criminal records. We ask that you do not provide sensitive information of this nature when using the Websites.  If you choose to provide sensitive information to us for any reason, the act of doing so constitutes your explicit consent, where such consent is necessary and valid under your local law, for us to collect and use that information in the ways described in this Privacy Policy or as described at the point where you choose to disclose this information.

We also do not actively seek demographic information from visitors to the Websites. However, you may choose to provide such information (including for example when becoming a Registered User, visiting our site from a social media site, submitting a resume, or responding to an online job application). If you choose to provide demographic information to us, the act of doing so constitutes your explicit consent, where such consent is necessary and valid applicable law, for us to collect and use that information in the ways described in this Privacy Policy or as described at the point where you choose to disclose this information.

It is our policy to collect only minimum information required to complete your request. If the Websites seek non-mandatory personal information about you, you will be notified of this at the point of collection. If you believe a Website has collected excessive information about you, please contact us to raise any concerns.

Some pages on the Websites may permit you to send emails to us. Messages sent via the Websites will contain your screen name and email address, as well as any additional information you may wish to include in the message.

Registered Users

  1. If you choose to become a Registered User, as part of the registration process you will be asked to provide us with personal information through a registration form. Information we collect may include your name, email address, password, organization, and job title. Some of the information is required and, if you do not provide it, you will not be able to register and receive the benefits of being a Registered User (for example, obtaining access to premium content). We have marked with a * those registration fields seeking information that you must provide in order to become a Registered User.
  1. For as long as you are a Registered User, you are responsible for providing us with accurate information about you and for keeping that information up to date. You may update your information by editing your user profile in your Account.
  1. Once you are a Registered User, we may combine the information you give us as part of the registration process with information we collect and/or have previously collected through your use of the Websites (such as articles you read, comments you make). As a Registered User, all of the data you provide as part of registration may be tied back to the information we collect or have previously collected about you through your use of the Websites.
  1. We may also match the information you provide us with third-party data to supplement your user profile. For example, if a third party has additional information related to your email address (such as a social media profile URL or a photo), we may match your email address and activity on the Websites (including activity information collected prior to your becoming a Registered User) against that data and then use the third-party data for additional marketing activities.

We may also use your information for the following purposes:

  • to tailor the content within our Websites and across Destreza digital properties, including content shown to you, to your preferences and interests;
  • to manage our relationship with you or the organization for which you work (for example, by including personal data we collect about you from your use of the Websites in our customer relationship management systems);
  • to provide you with information about us and our services including via personalized marketing messages and/or communications unique to your organization about our products and services;
  • to invite you to attend events, participate in forums, etc.;
  • to conduct quality and risk management reviews;

any other purposes for which you provided the information to Destreza.

Use of personal information

When you provide personal information to us, we may use it for any of the purposes described in this Privacy Policy or as stated at the point of collection (or as obvious from the context of collection), including:

  • to administer and manage the Websites, including to confirm and authenticate your identity and prevent unauthorized access to restricted areas of the site, premium content, or other services limited to Registered Users;
  • to personalize and enrich your browsing experience by displaying content that is more likely to be relevant and of interest to you;
  • to sort and analyze user data (such as determining how many users from the same organization have subscribed to or are using the Websites);
  • to determine the company, organization, institution, or agency that you work for or with which you are otherwise associated;
  • to develop our businesses and services;
  • to conduct benchmarking and data analysis including, for example, regarding usage of the Websites and demographics analyses of their users;
  • to conduct quality and risk management reviews;
  • to understand how users interact with the features and functions of our Websites in order to improve the user experience;
  • to monitor and enforce compliance with our Terms, including acceptable use policies; and/or
  • any other purposes for which you provided the information to Destreza, including any of the purposes given in the ‘Collection of personal information’ section above.

Our Websites do not collect or compile personally identifying information for sale to non-Destreza parties for consumer marketing purposes.

If you would like to find out more about the different categories of information we collect on the Websites, please review the ‘Collection of personal information’ section.

Legal grounds for processing personal information

Your local law may require us to set out in this Privacy Policy the legal grounds on which we rely in order to process your personal information.  In such cases, we rely on one or more of the following processing conditions:

  1. our legitimate interests in the effective delivery of information and services to you and in the effective and lawful operation of our businesses (provided these do not interfere with your rights);
  2. to satisfy any legal and regulatory obligations to which we are subject;
  3. to perform our obligations under the Terms; or
  4. where no other condition for processing is available if you have agreed to us processing your personal information for the relevant purpose.

Security of personal information

We have implemented generally accepted standards of technology and operational security in order to protect personally identifiable information from loss, misuse, alteration or destruction. Only authorized persons are provided access to personally identifiable information collected via the Websites; such individuals have agreed to maintain the confidentiality of this information.

Although we use appropriate security measures once we have received your personal data, the transmission of data over the internet (including by e-mail) is never completely secure. We endeavor to protect personal data, but we cannot guarantee the security of data transmitted to or by us.

Cookie Policy

We utilize online identification technologies — such as cookies, web beacons, or pixels — on the Websites. “Cookies” are small text files placed on your hard drive that assist us in providing a more customized website experience. For example, a cookie can be used to store registration information in an individual site or area of a site so that you do not need to re-enter it on subsequent visits to that site or area. We use these technologies to make navigation of the Websites easier for you and to better deliver tailored content to you.  If you choose to become a Registered User (see below), we will use cookies to facilitate your registration and remember your preferences. It is not possible to be a Registered User unless you accept the cookies used as part of registration.

In order to manage the Websites properly, we also log information on our operational systems and identify categories of visitors by items such as domains, browser types, and IP addresses.  Statistics are reported in the aggregate to our webmasters. We gather this information so that the Websites present the best web experience for visitors. Anonymous log information is also an effective information resource.

We also use these technologies to gather tracking information and statistics regarding use of the Websites. For example, we collect information about page visits and navigation to determine what articles and topics are of greatest interest and if users are able to find content easily. Likewise, we collect information about which articles and videos are viewed and whether videos are viewed in their entirety to determine what content is of most interest to users. We also use tracking information to generate various reports regarding the use of the Websites. These reports contain aggregated information about users; if you are a Registered User, tracking information may be tied to your Account and your information as an individual Registered User.

We may utilize online identification technologies from marketing partners, third party sites and social media platforms. These technologies help us measure the efficacy of our marketing and awareness campaigns and to understand how visitors navigate to the Websites from a PwC ad. We use these technologies to compile statistics about visitors who interact with the Websites and other PwC online content, to gauge the effectiveness of our ads, and to provide more pertinent information to our visitors.

Many browsers permit individuals who are concerned about cookies to decline them. In most cases, you may refuse or delete one or more cookies and still access the Websites, but the functionality of the sites you want to visit may be impaired.  You may delete site cookies from your system after you finish browsing the Websites if you wish to do so unless you are a Registered User.  As a Registered User, you must accept certain cookies in order for your registration to work; you may delete cookies once you terminate your registration.

If you are a Registered User, the tracking information we collect may be linked to the information we collect about you as part of the registration process, including your name and email address.

We use site analytics providers that may set cookies in your browser.  Site activity information collected by these analytics providers may be combined with personal information we hold about you. Information about the cookies used on our Websites can be found here: Cookie Disclosure.  Individual sites may use additional cookies or third-party analytic tools.  For more information about the cookies and third-party tools used on individual sites, please review the cookie information on the individual sites you visit.

By using our Websites, you consent, where such consent is necessary and valid under applicable law, to our use of the cookies listed in our Cookie Disclosure and the placement of these cookies on your device for the purposes described.

Third-party providers

We may transfer or disclose the personal data we collect to Destreza Member Firms and/or Associates (and their respective subsidiaries and affiliates) and to their third-party contractors, subcontractors, and/or their subsidiaries and affiliates.  When we transfer personal data, we do so for the purposes for which the information has been submitted, for the purposes listed above under Use of Personal Information, for the administration and maintenance of the Websites and associated systems, and/or other internal or administrative purposes. We also may transfer personal data to third party service providers of identity management, website hosting, and management, data analysis, data backup, security and storage services.

The third party providers may use their own third-party subcontractors that have access to personal data (sub-processors).  It is our policy to use only third-party providers that are bound to maintain appropriate levels of security and confidentiality, to process personal information only as instructed by Destreza, and to flow those same obligations down to their sub-processors.

Other disclosures

We may also disclose personal information to third parties under the following circumstances:

  1. when explicitly requested by you;
  2. when required to deliver publications or reference materials as requested by you;
  3. when required to facilitate conferences or events hosted by a third party;
  4. for regulatory compliance purposes; and/or
  5. as otherwise set out in this Privacy Policy.
  6. We may also disclose your personal information to law enforcement, regulatory and other government agencies and to professional bodies and other third parties, as required by and/or in accordance with applicable law or regulation. This includes disclosures outside the country where you are located. Destreza may also review and use your personal information to determine whether disclosure is required or permitted.

Retention of personal information

We will retain your personal information on our systems only for as long as we need it, given the purposes for which it was collected, or as required to do so by law. We keep contact information (such as mailing list information) until a user unsubscribes or requests that we delete that information. If you choose to unsubscribe from a mailing list, we may keep certain limited information about you so that we may honor your request. We dispose of resumes when they are no longer under consideration.

Marketing

Where we are legally required to obtain your explicit consent to provide you with marketing materials, we will only provide you with such marketing materials if you have provided consent for us to do so.

If you opt into any subscriptions, you will receive automated emails when content is updated. If you opt into any newsletters, you will receive curated emails known as newsletters.  If you select any preferences such as issues, topics, subjects or industries, you may receive email communications related to those self-selected topics.

If you become a Registered User, we may also contact you with email and marketing communications about subjects that we believe may be of interest to you. We may send emails and marketing communications on our own or in conjunction with another organization with which we have entered into a collaboration arrangement.

Unsubscribe

If you want to unsubscribe from mailing lists or any registrations, you should look for and follow the instructions we have provided within the appropriate area(s) of the Websites or in the relevant communications to you.

If you do not wish to receive emails or marketing communications from us, you can at any time contact us to request that such communications cease. If you wish to unsubscribe or no longer receive only certain communications, please identify such communications in your request.

If you choose to unsubscribe from any or all mailings, we may retain information sufficient to identify you so that we can honor your request.

Account Deactivation

If you are a Registered User, you may deactivate your account at any time via the Registered User section of the Websites. If you deactivate your account on the Websites, you will no longer receive the benefits of being a Registered User. If you choose to deactivate your account, we may retain information sufficient to identify you so that we can honor your request.

If you have other registrations with Destreza or have provided your information to Destreza through other means (such as subscribing to a newsletter), those registrations will be maintained unless you to take specific action to inform us to cease contacting you.

Any user-generated content that you may have created before then will not be anonymized following deactivation, nor will it be immediately removed from our systems or records.

Access to data

We are committed to providing reasonable and practical access that allows visitors to the Websites to identify and correct any inaccuracies in the information we collect about them.

When we keep personally identifiable information about you, we are responsible for keeping an accurate record of the information that you have submitted to us and verified.  We do not assume responsibility for verifying the ongoing accuracy of your personal information.  If you are a Registered User, you may update your personal information; to do so, log in using your account credentials and update your information.

If you have questions about the accuracy of identifying the information you previously submitted to Destreza, or want to have outdated information removed, please contact us. When requested, and provided that it is practical and commercially feasible to comply with the request and there is no legal or regulatory need for us to keep the information, we will delete identifying information from current operational systems.

Rights in relation to your information

You may have certain rights under your local law in relation to the personal information we hold about you. In particular, you may have a right to:

  1. request a copy of personal information we hold about you;
  2. ask that we update the personal information we hold about you, or correct such personal information that you think is incorrect or incomplete;
  3. ask that we delete personal information that we hold about you, or restrict the way in which we use such personal information;
  4. object to our processing of your personal information; and/or
  5. withdraw your consent to our processing of your personal information (to the extent such processing is based on consent and consent is the only permissible basis for processing).

If you would like to exercise these rights or understand if these rights apply to you, please contact us by sending an email or by one of the means set out at the end of this Privacy Policy. We may charge for a request to access your information if permitted by applicable law.

Children

We understand the importance of protecting children’s privacy, especially in an online environment. The Websites covered by this Privacy Policy are not intentionally designed for or directed at children, and the Terms and conditions of use require all users to be above the age of majority in their local country.  We adhere to laws regarding marketing to children. We never knowingly collect or maintain personal information about individuals under the age of 18.

Contact us

If you have any questions or complaints about this Privacy Policy or the way your personal information is processed on the Websites or would like to exercise one of your rights set out above, please contact us by one of the following means:

Form: Contact form

Email: info@destrezalimited.com

Post:      Destreza Limited.

P.O.Box 6842-00100, Nairobi

Phone: +254 743 945 592 | +254 20 811 8143

Modifications

We may update this Privacy Policy at any time by publishing an updated version here. So you know when we make changes to this Privacy Policy, we will update the revision date at the top of this page. The new modified or amended Privacy Policy will apply from that revision date. Therefore, we encourage you to review this Privacy Policy periodically to be informed about how we are protecting your information.