Levanter provides access to services and information online in a manner that respects and protects your privacy. This statement describes our information-collection practices and explains how we use and protect your personal information. 

Levanter and other entities owned or controlled by Levanter want you to be familiar with how we collect, use, and disclose information. This Privacy Policy describes our practices in connection with information that we collect: 

• Through websites operated by us from which you are accessing this Privacy Policy (the “Websites”), 
• Through email messages that we send to you that link to this Privacy Policy 
• Through offline communications activities as detailed in this policy 

Collectively, we refer to the Websites, the Email Messages, and our communications as the “Services.” 

Levanter respects your privacy and is committed to protecting your personal data. We may use your personal information to communicate with you and to keep track of the marketing materials you download. If you do not wish to receive communications from Levanter, please unsubscribe.

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual including, but not limited to: 

• Name 
• Postal address (including billing and shipping addresses) 
• Telephone number 
• Email address 
• Profile picture 

We and our third-party service providers collect Personal Information in a variety of ways, including: 

Through the Services 

• We collect Personal Information through the Services, for example, when you sign up for a newsletter, and register an account to access the Services. 

Offline 

• We collect Personal Information from you offline, e.g., when you attend one of our events, place a request over the phone, or contact Levanter. 

From Other Sources 

• We may receive your Personal Information from other sources, for example: 

• Referrals from our partners and contacts 
• Publicly available databases 

We use Personal Information for legitimate business purposes including: 

• Providing the functionality of the Services and fulfilling your requests. 
• To provide the Services’ functionality to you, such as providing you with related services or communications. If you do not provide the information requested, we may not be able to provide the Services’ functionality. 
• To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments, or complaints, or when you request other information. 
• To complete your transactions and provide you with related services or communications. 
• To send administrative information to you, such as changes to our offerings, terms, conditions, and policies. 

We will engage in these activities to manage our relationship with you and/or to comply with any legal obligation. 

Providing you with our newsletter and/or other promotional materials and facilitating social sharing 

• To send you promotional related emails, with information about our services, offerings, new initiatives, and other news about our organization. 

• To facilitate social sharing functionality that you choose to use. 

We will engage in this activity with your consent or where we have a legitimate interest. 

Analysis of Personal Information for business reporting and providing personalized services. 

• To analyse or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Services. 
• To better understand you, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests. 
• To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you. 

We will provide personalized services either with your consent or because we have a legitimate interest. 

Aggregating and/or anonymizing Personal Information. 

• We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose. 

For our business and operational purposes. 

• For data analysis, for example, to improve the efficiency of our Services; 
• For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements; 
• For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft; 
• For developing new offerings, initiatives and services; 
• For enhancing, improving, or modifying our current offerings, initiatives and services; 
• For identifying usage trends, for example, understanding which parts of our Services are of most interest to users; 
• For determining the effectiveness of our promotional and informational campaigns, so that we can adapt our campaigns to the needs and interests of our users; and 
• For operating and expanding our business activities, offerings, and services, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests; 

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest. 

We may disclose Personal Information: 

• To our affiliates, owned or controlled by RIKA, including but not limited to affiliates in the United States and the United Kingdom, for the purposes described in this Privacy Policy. 
• To our third-party services providers to facilitate services they provide to us. 

• These can include providers of services such as website hosting, data analysis, payment processing, order fulfillment, event registration, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services. 

We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so: 

To comply with applicable law and regulations. 

• This can include laws outside your country of residence. 

To cooperate with public and government authorities. 

• To respond to a request or to provide information that we, in our sole discretion, believe is important or is necessary to protect our interests. These can include authorities outside your country of residence. 

To cooperate with law enforcement. 

• For example, when we respond to law enforcement requests and orders or provide information that we, in our sole discretion, believe is important. 

For other legal reasons. 

• To enforce any terms and conditions; and 
• To protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others. 

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual 

• Browser and device information 
• App usage data 
• Information collected through cookies, pixel tags and other technologies 

• Demographic information and other information provided by you that does not reveal your specific identity 
• Information that has been aggregated in a manner such that it no longer reveals your specific identity 

If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy. 

We and our third-party service providers may collect Other Information in a variety of ways, including: 

Through your browser or device: 

• Certain information is collected by most browsers or automatically through your device. We use this information to ensure that the Services function properly. 

Using technology to track use of services and improve the services 

• Pixel tags. Pixel Tags (also known as web beacons or clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates. 
• Analytics. In some instances, we may use Google Analytics, which uses cookies and similar technologies to collect and analyse information about use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/‌partners/. 

IP Address 

• Your IP address is automatically assigned to your computer by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Services. We may also derive your approximate location from your IP address. 

Physical Location 

• We may collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content. We may also share your device’s physical location, with our promotional partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you do, we and/or our promotional partners may not be able to provide you with the applicable personalized services and content.

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law.

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below.

Your choices regarding our use and disclosure of your Personal Information 

We give you certain choices regarding our use and disclosure of your Personal Information for promotional purposes. You may opt-out from receiving electronic communications from us. If you no longer want to receive promotional-related emails from us on a going-forward basis, you may opt-out according to instructions in such communications. 

We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out. 

Access to, change of or deletion of your Personal Information 

To the extent these rights are provided to you by applicable law, if you would like to request to review, correct, update, suppress, restrict or delete Personal Information that you have previously provided to us, object to the processing of Personal Information or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another entity, please contact us at kmajanga@levanterafrica.com.  We will respond to your request consistent with applicable law. 

Retention Period 

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. 

The criteria used to determine our retention periods include: 

• The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services); 
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or 
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations). 

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates. 

In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages. 

The “Last Updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services. Your use of the Services following these changes means that you accept the revised Privacy Policy.

Levanter Africa Limited and other entities owned or controlled by Levanter Africa Limited is the company responsible for collection, use and disclosure of your Personal Information under this Privacy Policy. 

If you have any questions about this Privacy Policy, please contact us at  

Kmajanga@levanterafrica.com 

P.O BOX 76581 

Nairobi, Kenya. 

Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us. 

In accordance with applicable law, you may lodge a complaint with the relevant privacy or data protection regulatory authority. 

LAST UPDATED: November 13, 2023