Bold Insight Tech Solutions Limited Data Privacy Statement

• 1.0 Introduction 

• 1.1 Bold Insight Tech Solutions Limited  (“BITs”) operates in a highly data-oriented environment which requires the processing and use of personal data in order to fulfil its core mandate of processing bids on behalf of our clients.  BITs is committed to high standards of privacy and security of your personal data as required under the Data Protection Act, 2019 and the regulations thereto. 

• 1.2 This Privacy Statement explains the personal data we collect, how we process it and for what purpose. It also describes how BITs handles your data when you use any of our products and the controls BITs has established to safeguard your data.   The Privacy Statement applies to our visitors who either physically visit our premises or our portal, users of any of Our Products and services, suppliers, agents, customers and all our stakeholders. 

• 2.0 Definition of terms 

Under this Privacy Statement:

• 2.1 “BITs,” “We,” “Our,” “Ours,” and “Us,” means Bold Insight Tech Solutions Limited and includes its successors in title and assigns, its affiliates and/or its subsidiaries as may from time to time be specified by BITs to you.
• 2.2 “Our Products” includes but is not limited to SRM eProcurement, TenderAlert, DiversityLink, www.srmhub.com  
• 2.3 “Processing” collectively means handling, collecting, using, altering, merging, linking, organizing, disseminating, storing, protecting, retrieving, disclosing, erasing, archiving, destroying, or disposing of your personal data.

• 3.0 Collection of Information 

• 3.1 The information we collect about you will be for specified and legitimate purposes and will not be further processed in a manner incompatible with those purposes
• 3.2 The information we collect about you and your business includes but is not limited to: your identity including your name, age of business, physical address, phone number, email address, PIN, Registration and various documents to support this information.
• 3.3 We collect your personal information with your knowledge and consent when you do any of the following (please note that this list is not exhaustive): 

• 3.3.1 Register/subscribe for Our Products or services, including but not limited to SRM eProcurement, TenderAlert, DiversityLink, www.srmhub.com  

• 3.3.2 Subscribe to BITs services, Short Message Service (SMS), email or social media platforms;
• 3.3.3 Respond to or participate in a survey, marketing promotion, prize competition or special offer;
• 3.3.4 Visit, access or use BITs or third-party websites;
• 3.3.5 Contact BITs with a query or complaint;
• 3.3.6 Interact with us as a supplier, buyer, SRM staff as prescribed in this Privacy Statement;
• 3.3.7 Visit any of our premises or when you request us to reserve parking for you, we collect and retain your personal data (name, telephone number, national identification number and vehicle registration details) 
• 3.3.8 Call data records including the phone numbers that you use to call or send messages to us;
• 3.3.9 Billing details when you make payment for any of Our Products or Services;
• 3.3.10 Register for or attend any events organized by BITs or its affiliates;
• 3.3.11 Closed Circuit Television (CCTV) surveillance recordings. CCTV Devices are installed at strategic locations within BITs’s premises to provide a safe and secure environment.

• 3.4 By choosing to interact with us in any way specified under clause 3.3 above, you will be doing so with full knowledge and consent that we will collect and process your personal data. By consenting, you allow Us to collect, process, store, disclose and transfer your data as provided for under the Data Protection Act and the regulations thereto. 

• 4.0 Use of information 

We may use your data for the following purposes: 

• 4.1 Processing products and services that you have subscribed to or bought from us or from third parties through our SRM portal; 
• 4.2 Responding to any of your queries, concerns or complaints regarding any of Our Products or services; 
• 4.3 Generally keeping you informed about any of our new or existing products and services. 
• 4.4 Complying with any legal and regulatory requirements e.g Know Your Customer (KYC) documents for suppliers, contractors and service providers; 
• 4.5 For research, survey and other business purposes;
• 4.6 Providing aggregated data (where data is gathered and expressed in a summary form without indicating any information that may identify you as an individual) to third parties for research and scientific purposes;
• 4.7 Administering any of our online platforms/websites.
• 4.8 Notifying you of any changes to our terms and conditions or this privacy statement, or changes (permanent or temporary) to any of Our Products or services. Such messages will not include any promotional content. 

• 5.0 Retention of Data 

We will only retain your personal data only as long as may be reasonably necessary to satisfy the purpose for which it is collected and for purposes of satisfying any legal and regulatory requirements.

The data may also be retained for historical, statistical, journalistic literature or research purposes. 

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means like anonymization or Pseudonymisation. At the end of the retention period and so that the data is held indefinitely by BITs, we may anonymize or Pseudonymize your data so that it can no longer be associated with you.

• 6.0 Disclosure of Information 

• 6.1 Any disclosure of your personal data shall be in accordance with applicable laws and regulations. BITs shall assess and review each application for disclosure and sharing of data and may decline to grant such data to the requesting party. 
• 6.2 We may however disclose your personal data to: 

• 6.2.1 law-enforcement agencies and other regulatory authorities to the extent that such demand is compliant with applicable laws. 
• 6.2.2 Other buyers who are may be interested in purchasing goods or services from you.
• 6.2.3 Professional service providers including lawyers, bankers, auditors and insurers
• 6.2.4 Survey agencies that conduct surveys on behalf of BITs; 
• 6.2.5 Any other person that BITs may deem legitimately necessary to share the data with. 

• 6.3 Direct Marketing

• 6.3.1 You may be required to opt in or give any other form of explicit consent before receiving marketing messages from us.
• 6.3.2 You can ask us to stop sending you marketing messages at any time by writing to us at admin@srmhub.com or by following the opt out links on any marketing message sent to you or by contacting us at any time through the provided contacts.
• 6.3.3 Where you opt out of receiving these marketing messages, this will not apply to personal data already provided to us as a result of a product or service already taken up

• 7.0 The Use of Cookies and web beacons 

• 7.1 We may store some information using cookies or web beacons on your computer or any other device you use when you visit our websites. This enables us to recognize you during subsequent visits and to maintain your preferences and individual interests based on your activity. The type of data gathered is the Internet Protocol (IP) address of your computer, the date and time of your visit, which pages you browsed, the device used, files viewed and whether the pages have been delivered successfully.
• 7.2 You may be prompted before accepting any cookies, or to prevent your browser from accepting any cookies at all. If you reject the cookies, you can still use our website but your ability to use some features or areas of our website may be limited and certain features of the website may not be accessible.

• 8.0 Social media features and widgets: 

Our website includes social media features, such as the Facebook, Twitter and LinkedIn button and widgets, such as the Share This button or interactive mini–programs that run on our website. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy policy of the company providing them.

• 9.0 Use of Hyperlinks 

• 9.1 Our websites may provide hyperlinks to web content that is part of our website or third party external websites. 
• 9.2 BITs does not endorse or guarantee any products and services by providing hyperlinks to an external website and will not be in any way responsible for the content of any externally linked website. 
• 9.3 By clicking on a hyperlink, you will leave BITs’s website and accordingly, you will be subject to the terms of the other website that you choose to visit. We therefore recommend that you to read the privacy statement of every website you visit.

• 10.0 Safeguarding and protection of your personal data 

• 10.1 BITs has put in place technical and operational measures to ensure integrity and confidentiality of your data through information classification, access control, data encryption, physical and environmental security and monitoring and compliance with provisions of the Data Protection Act, 2019 and the regulations thereto.

• 11.0 Transfer of your data outside Kenya

We may need to transfer your personal data outside of the Republic of Kenya. Where we send your data outside Kenya, we will ensure that your data is properly protected in accordance with the applicable data protection laws of that country.

• 12.0 Your Rights 

Your rights as a data subject include: 

• 12.1 Right to be informed that we are collecting personal data about you and the use to which your personal data is to be put; 
• 12.2 Right to access personal data that is in our custody; 
• 12.3 Right to request that we correct your personal data where it is inaccurate or incomplete; 
• 12.4 Right to request that we erase your personal data noting that we may continue to retain your information if obligated by the law or entitled to do so; 
• 12.5 Right to object and withdraw your consent to processing of your personal data. We may continue to process if we have a legitimate or legal reason to do so; 
• 12.6 Right to request transfer of your personal data in a structured, machine readable and commonly used format and to request that we transfer the personal information provided by you to another Data Controller.

If you wish to exercise any of the rights set out above, please contact us at admin@srmhub.com

• 13.0 How to Contact Us 

If you would like to contact us regarding this Privacy Statement, you can email us on admin@srmhub.com

As a Data Controller and Processor, below are our contact details 

Bold Insight Tech Solutions Limited

iHiT Innovation Centre

Dennis Pritt Road

P.O Box 36662 -00200

Nairobi 

Tel: +254 733312000

www.srmhub.com

• 14.0 Amendments to this Statement 

BITs reserves the right to amend or modify this statement at any time. If BITs amends this statement, you can access the most current version of the Privacy Statement by accessing our website on www.srmhub.com

Email: admin@srmhub.com