TransUnion Kenya
Last revised: 22 September 2022
Version 1.0
© 2022 TransUnion LLC
All Rights Reserved
No part of this publication may be reproduced or distributed in any form or by any means, electronic or otherwise, now known or hereafter developed, including, but not limited to, the Internet, without the express written permission of TransUnion. This document is protected by U.S. and International copyright laws. This document and the subject matter contained herein is TransUnion proprietary and confidential information, and may not be shared or used for any purposes other than the purpose for which it was provided by TransUnion, without the express written permission of TransUnion. By using this document, you are agreeing that you will not attempt, directly or indirectly, to reverse engineer, decompile, or disassemble any TransUnion services or service information, any confidential or proprietary criteria developed or used by TransUnion relating to services you receive from TransUnion, or any of the TransUnion confidential and proprietary information contained herein. The entire right, title and interest in and to this document and TransUnion services, and all copyrights, patents, trade secrets, trademarks, trade names, and all other intellectual property rights associated with any and all ideas, concepts, techniques, inventions, processes, or works of authorship including, but not limited to, all materials in written or other tangible form developed or created by TransUnion, shall at all times vest exclusively in TransUnion. You acknowledge that any misuse, misappropriation or threatened misappropriation of TransUnion’s intellectual property rights, or any breach or threatened breach of the foregoing restrictions, may cause immediate and irreparable injury to TransUnion, and in such event, TransUnion shall be entitled to seek injunctive relief. Nothing stated herein will be construed to limit any other remedies available to TransUnion including, but not limited to suspension and/or termination of the services provided to you.
Requests for permission to reproduce or distribute any part of, or all of, this publication should be mailed to:
Law Department
TransUnion
Delta Corner Annex, 2nd Floor, Ring Road,
Westlands, Nairobi.
The “tu” logo, TransUnion, and other trademarks, service marks, and logos (the “Trademarks”) used in this publication are registered or unregistered Trademarks of TransUnion LLC or their respective owners. Trademarks may not be used for any purpose whatsoever without the express written permission of the Trademark owner.
Table of contents
- Who we are and how to contact us
- How we use personal information
- The kinds of personal information we use and where we get it
- How long we keep personal information
- Our legal basis for handling personal information
- Where we store and send personal information
- Your rights concerning personal information
- Where to lodge a complaint
Introduction
This document provides information about how we use and share personal information relating to our business contacts.
In brief
We use personal information to:
- Manage our relationships with our business contacts and keep in touch with them
- Promote our products and services to our customers and potential customers
We use tracking, monitoring and profiling techniques as part of our marketing decisions to help us decide who to contact, about what, and when.
This notice covers the following topics:
- Who we are and how to contact us
- How we use personal information
- The kinds of personal information we use and where we get it
- How long we keep personal information
- Our legal basis for handling personal information
- Where we store and send personal information
- Your rights concerning your personal information
- Where to lodge a complaint
1. Who we are and how to contact us
Information for Good®
We’re in an era of rapid digital transformation where consumers demand more access to seamless, personalised products and services online. But the currency of personal data that fuels this platform economic boom poses threats to individuals and endangers corporate security.
Now more than ever — and likely more so in the future — consumers and corporates need new levels of trust and transparency.
As a global information and insights company, TransUnion seeks to make trust possible in global commerce. We do this by curating a robust and actionable picture of each consumer so they’re reliably represented in the marketplace. This enables businesses and consumers to transact with confidence and achieve great things. We call this Information for Good®.
We’re a company with registered offices at TransUnion, Delta Corner Annex, 2nd Floor, Ring Road, Westlands, Nairobi. Although we’re part of a larger group, this notice covers only the activities of TransUnion companies within the Republic of Kenya.
Contact details
Contact us about personal information issues, including the contents of this notice via:
- Post:O Box 46406-00100, Nairobi
- Telephone: Contact Centre: +254 768262495, +254 768617074, +254 768253748, +254 706565285
2. How we use personal information
Relationship management
We use personal information to maintain and develop our relationships with clients, suppliers and their representatives.
Example: Relationship management
- Informing you about product changes or planned maintenance activity
- Contacting you with billing enquiries
- Inviting you to events and webinars
- Corresponding with you about your enquiries
- Conducting surveys to collect qualitative and quantitative feedback
- Canvassing you about products or product features you want us to develop
Marketing
We use personal information to market our products and services to current and potential clients and their representatives. This includes providing industry insights, commentary and research on data and software, notification of events and webinars, and updates on products and services.
Example: Marketing
- Monitoring your interactions to understand the products and services that interest you so we can tailor our marketing
- Contacting you by email, telephone or post to tell you about products and services we think will interest you
Providing services
Sometimes we use personal information to provide information, services, alerts and other facilities requested. For example, we might use your contact details to grant access to one of our webinars.
As a registered user of one of our products, we may use your personal information within that product — please refer to the privacy notice available within the product or our Business Product & Technical Support Privacy Notice for more details.
Monitoring and improving our websites
We use information, such as how different people navigate our websites, how long they spend on particular pages and what content they download. This helps us improve the user experience by tailoring our website to match individual interests and preferences.
Security and systems administration
We also use this information for security and system administration to generate non-personalised data (such as statistics on the uptake of services and patterns of browsing). In addition, we may share this anonymous data with business contacts, selected third parties, sponsors and advertisers.
Legal and regulatory purposes
We may also need to use your personal information for legal and regulatory purposes.
3. The kinds of personal information we use and where we get it
We obtain and use information from various sources summarised in the following table.
|
Type of information |
Description |
Source |
|
Name and contact details: |
Basic personal information about you and your workplace. |
Usually provided by the individual via telephone, email, our websites or in person at an event. |
|
Organisation-related details: |
Your organisation, department and role. |
|
|
Login credentials: |
Username and password recorded when you sign up to any of our web-based services. |
Provided by the user or AI-generated or by us (if we reset a password). |
|
Contact history: |
Our engagements, such as information exchanged, meetings, events or webinars attended, emails opened, links clicked and contacts within TransUnion. |
We produce these records. |
|
Device information: |
The type of device used to access our websites, its operating system, cookies, browser and IP address. |
We produce this information. |
|
Website usage: |
Use of our websites, such as pages visited and content downloaded. |
We need your personal information to provide our products correctly. You don’t have to provide us with personal information for technical support requests, but this may impede the help we can provide.
4. How long we keep personal information
Simply put, we keep personal information for as long as necessary. More technically, we retain it to fulfil the purpose(s) of its provision, comply with applicable laws, and for as long as your consent to such purpose(s) remains valid after termination of our relationship.
5. Our legal basis for handling personal information
Legitimate interests
The Data Protection Act No. 24 of 2019 allows personal information usage where necessary for legitimate purposes without undue adverse impact. We base most of our processing activities on the legitimate interests listed below.
|
Interest |
Explanation |
|
Strategic customer engagement |
Develop and leverage our understanding of customers and suppliers and how they use our products and services. |
|
Strategically targeted marketing |
Promote new and existing products and services to suitable current and potential clients. |
|
Develop new and improve existing products and services |
Help us remain competitive, differentiated and attractive to clients by providing world-class, future-fit solutions. |
|
Monitor and secure our systems and data |
Fulfil our promise by keeping our systems and data secure. |
Other legal bases
Sometimes we process personal information on the following grounds:
|
Grounds |
Examples |
|
Consent |
We’ll ask if you agree to us using your data in specified ways, such as when you tick a box showing you wish to receive marketing emails or telephone calls from us. |
|
Contractual |
We may need to use your details to perform a contracted product or service. |
|
Legal |
Regulators, government bodies and courts can order us to provide information and we may have to comply. |
Service providers
We might provide information to third parties that help us achieve the purposes described in Section 2. For example:
- Cloud-based services, such as Salesforce, to help host, manage and analyse our databases
- Printing companies to produce and send direct mail or other correspondence
- Market research companies to help us better understand our customers
- Third parties that analyse or enhance the data and return the results to us
These service providers cannot use your information for their purposes or on behalf of other organisations unless you agree otherwise.
Regulators
We may sometimes need to pass personal information to a regulator like the Central Bank of Kenya or the Office of the Data Protection Commissioner.
7. Where we store and send personal information
We access and use your information from our base in Kenya. We will not transfer personal information to a country lacking laws that provide an adequate level of information protection — unless we have an agreement with the recipient requiring measures that offer a similar level of protection as the Data Protection Act No. 24 of 2019 in Kenya.
8. Your rights concerning personal information
Access: You have the right to find out if and what personal information we hold about you. Refer all your Data Access requests to info@transunion.com or DPO_KE@transunion.com.
Correction/Destruction/Deletion: If the information we hold about you is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained lawfully, you have a right to ask us to correct it or delete it.
Objection to processing: You may object (on reasonable grounds) to processing your personal information unless legislation provides for such processing.
Objection to direct marketing: You may object to us using your personal information for direct marketing, and if you do, we will stop.
9. Where to lodge a complaint
We strive to deliver the highest levels of customer service. However, if you’re ever unhappy with us, please contact us so we can investigate.
- Post:O Box 46406- 00100, Nairobi
- Telephone:+254 768262495, +254 768617074, +254 768253748, +254 706565285
You can also contact our Data Protection Officer at DPO_KE@transunion.com
You may complain to the Information Regulator:
- Email: info@odpc.go.ke
- Post: P.O Box 30920-00100, Nairobi
