Table of Contents
- 1 General Information
- 2 Information Privacy
- 3 What is this Privacy Notice for?
- 4 The Personal data that we collect
- 5 What purpose do we use your Personal data?
- 6 Who do we share your Personal data with?
- 7 How long do we keep your Personal data for?
- 8 Security and retention of your Personal data
- 9 Privacy of children
- 10 Your rights
- 11 Social media
- 11.1 Facebook
- 12 Changes to our Privacy Notice
- 13 Contact & Communication
1 General Information
This notice/policy is specific to Surgipharm Limited, Kenya.
The following information describes what happens with Personal data provided to Surgipharm, either while visiting our website, or during the course of normal business operations. Personal information is data which could be used to identify you as a person.
The Data Protection Act, 2019 can be accessed at
2 Information Privacy
If you use this website, various Personal data may be collected. Information transmission via the internet (e.g. email communication) can be subject to security vulnerabilities, and it is not possible to completely protect the information against access by third parties. Nonetheless, Surgipharm adheres to recognised information security practices in order to secure this information.
3 What is this Privacy Notice for?
The Data Protection Act, 2019 (the “Act”) came into force on 25th November 2019 and is now the primary statute on data protection in Kenya. It gives effect to Article 31 c) and d) of the Constitution of Kenya, 2010 (right to privacy).
The objectives of the Act include, inter alia
- to protect the privacy of individuals
- to regulate the processing of Personal data
- to establish the legal and institutional mechanism to protect Personal data
- to provide data subjects with rights and remedies to protect their Personal data from processing that is not in Accordance with the Act.
The regulation applies to all storage and processing of Personal data
The Regulations also seek to enhance the competitiveness of Kenyan companies in international trade through the safeguards that are in line with global best practices.
Surgipharm (“we“) values your Personal data
4 The Personal data that we collect
Personal data means any information that can be used to identify directly or indirectly a specific individual.
We collect Personal data that you give to us, for example, where you create an account with us, request for further information about our service, fill a form, apply for a job through our website or you subscribe to newsletters on our website
5 Use of your Personal data
We may process your Personal data to communicate with you (including sending marketing or promotional materials to you),provide you with further information about our services and how we can serve you better, respond to your requests, process your application for employment with Surgipharm or to fulfill our contractual obligations with you. We may also process your Personal data to comply with provisions of applicable laws.
We also process your Personal data when we have a legal obligation (e.g., tax or social security obligations) to perform such processing. For example, a court order or a subpoena may require us to process Personal data for a particular purpose, or we may be compelled to process Personal data to report suspicious transactions under the local anti-money laundering rules.
6 With whom do we share your Personal data ?
We respect your privacy and we limit disclosure of your Personal data
Legal disclosure. We may transfer and disclose your Personal data to third-parties:
- To comply with a legal obligation;
- When we believe in good faith that an applicable law requires it;
- At the request of governmental authorities conducting an investigation;
- To detect and protect against fraud, or any technical or security vulnerabilities; or
- To respond to an emergency.
7 How long do we keep your Personal data for?
We will keep your Personal data for as long as we need it for processing purposes.
We will actively review the Personal data we hold and delete it securely, or in some cases anonymise it, when there is no longer a legal, business or consumer need for it to be retained.
8 Security and retention of your Personal data
Your Personal data is kept private and we make every effort to keep your Personal data secure, including restricting access to your Personal data with us on a need to know basis. We require our staff and any third parties who carry out any work on our behalf to comply with appropriate security standards to protect your Personal data.
We take appropriate measures to ensure that your Personal data is only processed for the minimum period necessary, in line with the purposes set out in this Notice or as required by applicable laws, until a time it is no longer required or has no use.
Our measures include implementing appropriate access controls, investing in the latest Information Security Capabilities to protect the IT environments we leverage, and ensuring we encrypt, pseudonymise and anonymise Personal data wherever possible. Once your Personal data is no longer required, we destroy it in a safe and secure manner.
9 Privacy of children
At Surgipharm, we do not knowingly collect any Personal data from children as our platforms are not directed towards children. If you are a minor, please do not submit any Personal data through our Website or Service. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through our Website without their permission.
10 Your rights
Surgipharm collects Personal data only for the purposes identified in this Policy and such information cannot be reused for another purpose that is incompatible with the original purpose.
You can exercise the following rights with respect to your Personal data with Surgipharm:
- Be informed of the use of your Personal data ;
- Request for and access your Personal data collected and stored by Surgipharm;
- Withdraw consent at any time. For example, you can withdraw your consent to receipt of our marketing or promotional materials or unsubscribe to our newsletters;
- Object to automated decision making;
- Request rectification and modification of Personal data kept by Surgipharm to:
- erase your Personal data;
- restrict our use of your Personal data;
- object to our use of all/part of your Personal data;
- withdraw any consents you have provided for our use of your Personal data;
- receive your Personal data in a usable electronic format and transmit it to a third party (right to data portability); and
- lodge a complaint with your local data protection authority
- Be informed of and entitled to provide consent prior to the processing of Personal data for purposes other than that for which the Personal data were collected; and
- Request for information regarding any specific processing of your Personal data .
If you would like to discuss or exercise such rights, please contact us at the details below.
If you are concerned that any of the information we hold about you is incorrect, or out of date, please write to the address below to report your concerns and we will take appropriate steps to amend our records.
11 Social media
11.1 Google Analytics
This website uses Google Analytics offered by Google Inc. (1600 Amphitheatre Parkway Mountain View, CA 94043, USA) to analyse user behaviour on our website.
Google Analytics uses “Cookies“ – small text files, which are saved on your computer. The information collected by the cookies is generally transmitted and saved to a Google server in the USA.
This website uses the anonymize Ip function. The users IP address is shortened, ensuring that the visitor is not personally identifiable. Within the framework of the agreement on information processing which the website provider has made with Google Inc., Google creates analyses of the users website activity and behaviour with the collected information, and provides Surgipharm with services connected to internet usage.
If you do not want to have the cookie saved on your device, you can disable it in the preferences of your browser. However, we cannot ensure that you can access all functions without any limitations if your browser does not accept cookies.
Furthermore, you can use a browser plugin to prevent Google Inc. from obtaining and using the information which is collected by the cookie (including your IP address). The following link directs you to the plugin: https://tools.google.com/dlpage/gaoptout?hl=en
You can find further information on information usage by Google Inc. here: https://support.google.com/analytics/answer/6004245
12 Changes to our Privacy Notice
This privacy notice was last updated in August 2021. We reserve the right to update and amend this privacy notice at any time to reflect the way we use your Personal data or changes in legal requirements. In the event of such changes, we will publish the amended data protection notice on our website. All amended information is effective from the date it is posted on our website.
13 Contact & Communication
If you would like further information on this Notice, or to contact our Data Protection Officer, you may contact us :
Nivina Towers, 71 Westlands Road,
P.O.Box 46043-00100, Nairobi,
Mob: 0722204707, 0734224228
We will endeavour to respond to your concerns as soon as possible.