Welcome to Mwalimu National!
1. About Us
1.2 If you have any questions about your personal information, please click on “support” and select “contact support”.
2. Use of the Website
3. Collection of Information
3.1 When you access the Website via any means, register or post comments, make inquiries, respond to or participate in any survey or questionnaire sent to you by us, provide comments via the support button, or make any application through the Website, we may collect, store and use certain of your personal information in line with this policy. We may also ask you for information when you report a problem with the Website or any of our products/services.
3.2 To register or make an application on the Website, we ask for your name, email address, details of your next of kin/beneficiaries/nominees, guarantors and financial details. If you contact us, we may also keep a record of that correspondence.
3.3 We may also collect data relating to your visits to the Website that cannot identify you but records your use of our Website including, for example, details of how long you have used the Website for.
3.4 We may also collect your computer’s IP address in order to help us tailor the service to your location, or collect the data marketing research.
3.5 If you elect to verify your identity through our Website, our identity verification partner will receive directly from you, process and store your personal information and identity documentation for this purpose. Our identity verification partner may store your information for a maximum of 5 days for the sole purpose of resolving user support issues. Upon successful verification of your identity, we will store only the name given on your identification documentation.
3.6 Finally, we may receive information about you from third parties (such as credit reference bureaus) who are legally entitled to disclose that information.
4. Use of Your Information
4.1 By accessing the Website via any means, register or post comments, make inquiries, respond to or participate in any survey or questionnaire sent to you by us, provide comments via the support button, or make any application through the Website, you agree that your personal information may be collected, stored, used and shared by us and our subsidiaries and partners or third parties we work with, for any of the following purposes:
(a) to provide, maintain, protect and improve the quality of the Website and our products and service; including by conducting anonymised market research, and to protect us and our users;
(b) to provide you with a personalised browsing experience when using the Website;
(c) to fulfil any contractual agreements between you and us;
(d) if you have applied and or are utilizing any of our products, to send you details of our other products and services which we think may interest you, unless you opt out as described at clause 9 below. You can control your email preferences on the settings page;
(e) to tailor our advertising on social media to your use of the Website;
(f) to manage your membership account that you hold with us;
(g) to allow you to use the full range of features on or via our Website;
(h) to send you product/service-specific email notifications and updates the product/service you are enrolled on;
(i) to comply with legal and regulatory requirements;
(j) to contact you occasionally in order to invite you to share your opinions and experiences of Mwalimu National;
(m) to collect, moderate and present reviews and ratings of our products/services to be published on our Website; and
(n) in order to provide Mwalimu or subsidiary products or services available through our Website.
4.2 We may use your email address to send you course notices and updates about our products/services. You can control your email preferences on the settings page.
4.3 With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or telephone with information, news, and offers on the relevant product/services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Act No. 24 of 2019, and you will always have the opportunity to opt-out.
5. Storage of Information
5.1 All information is stored on our secure servers. When you register, we will ask you to choose a password which enables you to access the member portal, where applicable. You are responsible for keeping this password confidential. We ask you not to share this password with anyone.
5.2 In addition, we (or third parties acting on our behalf) may also store or process information that we collect about you in countries outside Kenya, which may have lower standards of data protection. Specifically, servers used by our Website are located in Kenya. We have put in place technical and organisational security measures to prevent the loss or unauthorised access of your personal information. However, whilst we have used our best efforts to ensure the security of your data, please be aware that we cannot guarantee the security of information transmitted over the Internet.
6. Legal Basis for Processing Your Information
6.1 Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
6.2 However, we will normally collect personal information from you only (i) where we have your consent to do so, (ii) where we need the personal information to perform a contract with you (provide you with a product/service you have applied for), or (iii) where the processing is in our legitimate interests and not overridden by your rights. In some cases, we may also have a legal obligation to collect personal information from you.
6.3 If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as the possible consequences if you do not provide your information).
6.4 Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
7. Disclosure of Your Information
We may disclose your personal information to third parties when permitted by law including:
(a) with your consent;
(b) to our suppliers in order for them to help us provide our product/services to you, this includes:
i. loyalty program providers;
ii. our provider of customer relationship management services (which allows us, for example, to send personalised email communications to you);
iii. our provider of file storage and management services if you email us directly;
iv. our payment services provider when you make a payment for a service on the website to enable us process your payment;
v. our identity verification partner (as discussed at clause 3.5 above) to verify your identity where you choose to select this option;
vi. where you have agreed, to our refer-a-member program provider, solely to enable your participation in the program;
vii. suppliers of channel and integrated services we require in order to provide you with our products and services;
viii. our customer service software if you contact our support team; and
ix. our third party review and ratings partner, who assists us with collecting and moderating your review and rating of our product/services;
These suppliers’ use of your personal data may be subject to their own privacy policies, which are available on their websites, and which we suggest you familiarise yourself within the relevant circumstances set out above.
(e) if we are under a duty to disclose or share your information in order to comply with any legal obligation, or in order to enforce or apply our Terms and other agreements; or to protect our rights, property, or safety, our users, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
8. Data Retention
8.1 We retain personal information we collect from you where we have an ongoing legitimate business need to do so and in line with relevant laws and our Records Policy (for example, to provide you with a product service you have requested, you continue to be a member of Mwalimu National or to comply with applicable legal, tax or accounting requirements).
8.2 When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
9. Your Rights
9.1 You have the following data protection rights:
(a) You can edit your personal details via your member portal whenever you wish. We maintain a procedure in order to help you confirm that your personal information remains correct and up-to-date or choose whether or not you wish to receive material from us or some of our partners.
(b) In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “Contacting Mwalimu National” heading below.
(d) Similarly, if we have collected and process your personal information on the basis of your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
(e) If you have any privacy-related questions or unresolved problems, you may contact us using the information provided at clause 13 below.
(f) You have the right to complain to the Data Commissioner about our collection and use of your personal information.
(g) The Website may, from time to time, contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies. Please check these policies before you submit any personal information to these websites.
We strongly believe in protecting the privacy of children. In line with this belief, we do not knowingly collect or maintain personal information from persons under 18 years of age, and no part of the Website is directed to persons under 18 years of age. If you are under 18 years of age, then please do not use or access the Website at any time or in any manner. We will take appropriate steps to delete any personal information of persons less than 18 years of age.
• 11.2 For more information about cookies, including further details as to what they are and how to refuse them, please see our Cookies Policy.
12. Links to Third Party Websites
12.1 When clicking on a link within the website, you will be taken to a third party website, the use of which has been arranged by and is the responsibility of the third party.
14. Contacting Mwalimu National
The Chief Executive Officer: Mwalimu National Sacco,
Upper Hill, Hill Lane,
P.O. Box 62641, City Square,
TEL: (020) 2956000/0709898000
Approved vide minute MIN/BOD/44/2021 on 31 day of March 2021