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Riana Infotech Data Protection Policy

Introduction

Riana Infotech Limited (“Riana” “we” or “us” or “our”) respects the privacy of our users (“user” or “you” or “client organization”). This Data Protection Policy explains how we collect, use, disclose, and safeguard your information when you use our provisioned software solution, surveillance platform and/or visit our websites, including any other media form, media channel, mobile website, or mobile applications and SMS gateway related or connected thereto (collectively, the “software application” and the “Site”).

This policy statement applies to all our provisioned solutions, please read it carefully. If any portion of it is not clear, you may contact us on dataprotection@riana.co for any clarifications or queries. or rather if you do not agree with the terms of this privacy policy, please do not access the service(s).

We are committed to protecting your personal data and ensuring that your privacy is protected. This Data Privacy Policy explains the types of personal data we collect, how we use and protect that data, and your legal rights regarding your personal data. In addition, all of our employees, contractors, or consultants, independent or otherwise, will be required to act consistently with this Data Protection Policy.

Riana Responsibilities

Riana has a mandate to ensure that any personal data that we process is guided by various principles. We shall ensure that all data is:

Processed in accordance with the rights of the data subject

Processed lawfully, fairly and in a transparent

Collected for explicit, specified, and legitimate purposes and not further processed in a manner incompatible with those purposes.

Adequate, relevant, limited to what is necessary in relation to the purposes for which it is

Accurate and, where necessary, kept up to date, with every reasonable step being taken to ensure that any inaccurate personal data is erased or rectified.

Not transferred outside Kenya unless there is proof of adequate data protection safeguards or consent from the data subject.

Data Processing

Personal data is information that identifies you as an individual, such as your name, email address, phone number, address, PIN, and surveillance records. Riana shall only process personal data when the data subject consents to processing for one or more specified purposes, or where such processing is necessary for any of the below to occur:

The performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject before entering into a contract.

For compliance with any legal obligation(s) to which Riana is subject, including those imposed by applicable Regulatory bodies / Government entities;

In order to protect the vital interests of the data subject or another natural person;

For the performance of a task carried out in the public interest or in the exercise of official authority vested in Riana.

The performance of any task carried out by a public

For the exercise, by any person in the public interest, of any other functions of a public

For the legitimate interests pursued by Riana or by a third party to whom the data is disclosed, except if the processing is unwarranted in any particular case having regard to the harm and prejudice to the rights and freedoms or legitimate interests of the data

For the purpose of historical, statistical, journalistic, literature and art or scientific

The processing relates to personal data which is manifestly made public by the data

Where processing is necessary for: The establishment, exercise, or defense of a legal

The purpose of carrying out the obligations and exercising specific rights of Riana or of the data subject.

Protecting the vital interests of the Data Subject or another person where the Data Subject is physically or legally incapable of giving consent.

Data Collection

We may collect personal data from you when you visit our Site, when you register on the Site, or when you use our services.

We will only collect and process your personal data in accordance with the Kenya Data Protection Act, 2019. We will collect your personal data only for specific, explicit, and legitimate purposes and will not process your personal data in any way that is incompatible with these purposes.

Riana has several categories of data subjects whose data will be processed and controlled, due to regulatory, operational and / or other needs.

Employees

These are individuals directly or indirectly employed by Riana. Riana may control and process data related to employees to allow for identification, validation as well as processing of regulatory information such as remittances on taxes and other key data required by the Government of Kenya. Such data may also be shared with authorised third parties where necessary for fulfilment of a contractual obligation with the respective Data Subject or based on consent.

The data processed may also include sensitive personal / health data for e.g. biometric access control, and where applicable, for the provision of medical insurance / healthcare to the Employees. Whenever this is the case, consent of the Data Subject will always be sought along with an explanation as to the use to which the said data will be put, save for emergencies or life-threatening instances in which consent is not obtainable.

Clients

This category includes all identifiable clients who procure services and/or products from Riana and/or other third-party partners with whom Riana collaborates with to provide services and products. Riana may share personal data with authorised third-parties in furtherance of their obligations to the Client, e.g. for sought-after/required services/products to be rendered to or provided to the Client.

Riana may control and process personal data related to our customers and/or clients in furtherance of a contractual obligation, due to legal obligations and/or due to other operational processes.

Riana partners

These are all Riana partners who have a business relationship, collaborative initiative, and existing connection either directly and or indirectly that would necessitate the processing and control of personal data. Such processing and control might be due to regulatory compliance, internal processes and or other assessed need, and accordingly, may be shared with authorised third parties.

Riana Data Subjects

Riana is committed to the promotion and enforcement of the rights of Data Subjects. These include, but are not limited to, the right:

To be informed of the use to which their personal data is to be put;

To access their personal data in the custody of data controller or data processor;

To object to the processing of all or part of their personal data;

To correction of false or misleading data; and

To deletion of false or misleading data about

Data Use

We use your personal data to provide our services to you and/or the client organization. Your contact details may be used to communicate with you as part of the service delivery including but not limited to managing the collection and storage of End User data. We may use personal data to improve our services.

We may also use your personal data to send you promotional materials, newsletters, and other communications that we believe may be of interest to you.

You, however, have the right to opt out of these communications at any time.

Data Storage and Transfer

Digital records:

Riana is committed to the secure storage and preservation of all the personal identifiable information captured in its information systems.

We may acquire storage hosting services thereby transfer your personal data to third parties facility, including those located in other jurisdictions, only if appropriate safeguards are in place to protect the data, such as the use of standard contractual clauses, binding corporate rules, or compliance with other lawful mechanisms.

Storage of all Riana-controlled personal data shall be under Riana owned infrastructure and / or infrastructure under contractual Riana ownership.

Physical records:

All physical records containing personal identifiable information shall be kept under lock and key and shall be under the sole control of the People and Culture Executive.