Privacy Policy

SunCulture is committed to complying with all applicable laws and best corporate governance practices, wherever we operate. It is a core aspect of our mission to act with integrity in all of our operations.

SunCulture Limited Privacy Policy

1. Introduction

SunCulture Kenya Limited and its relevant affiliates (collectively referred to as “SunCulture”, “we”, “us” or “our”) are committed to protecting the privacy and personal data of individuals with whom we interact. This Privacy Notice explains how we collect, receive, use, store, disclose, transfer and otherwise process personal data in the course of our business operations. It applies to customers, prospective customers, employees, job applicants, suppliers, business partners, contractors, website visitors and other individuals whose personal data we process. We process personal data in accordance with all applicable data protection and privacy laws and regulations in the jurisdictions in which we operate, as amended or enacted from time to time.

2. General

For the purposes of applicable data protection laws, the relevant SunCulture entity may act as a data controller, determining the purposes and means of processing personal data, or as a data processor, processing personal data on behalf of another organisation.

The relevant SunCulture entity responsible for processing your personal data will depend on your relationship with us and the services or activities involved.

Contact details:
SunCulture Kenya Limited
19 Kanjata Road, Muthangari Drive
P.O. Box 25723-00603, Nairobi, Kenya
Email: legal@sunculture.com or report a complaint through our website by filling in the Grievances Entry form

3. Personal Data We Collect

Depending on your relationship with SunCulture and how you interact with us, we may collect and process the following categories of personal data/information:

  1. Identification and Contact Information: Names, identification details, date of birth, contact details and addresses.
  2. Customer and Transaction Information: Account details, purchases, orders, service requests, warranties, contracts, payment and repayment records, and customer communications.
  3. Financial and Credit Information: Financial transactions, credit assessments and credit reference information, where applicable and legally permitted.
  4. Employment and Recruitment Information: CVs, qualifications, employment history, references, payroll and other employment-related records.
  5. Supplier and Business Partner Information: Professional and business contact details, credentials, contracts and payment information.
  6. Technical and Digital Information: IP addresses, device identifiers, browser data, website usage and system logs.
  7. Product and Location Information: Equipment identifiers, product registration, usage, operational and diagnostic data, and location information where applicable.
  8. Communications and Images: Emails, call records, support correspondence, survey responses, photographs, CCTV footage and audio recordings, where applicable.
  9. Sensitive personal data: Where necessary and legally permitted, we may process sensitive personal data, such as health information, biometric information or other legally protected categories of data. Such information will be subject to the additional safeguards and legal requirements applicable to its processing.

4. How We Collect Personal Data

We may collect personal data:

  1. Directly from you through forms, applications, contracts, surveys, interviews, telephone calls, emails, websites or other communication channels.
  2. Through our employees, authorised agents, sales representatives, dealers, distributors and service providers.
  3. From business partners, financial institutions, credit reference bureaus, referees and other third parties where legally permitted.
  4. Automatically through our websites, digital platforms, connected products and information technology systems.
  5. From publicly available sources or government authorities where necessary and lawful.
  6. During recruitment, employment, procurement, contract management, customer support and other business activities.
  7. Through third parties; where we obtain personal data from third parties, we ensure that all necessary consents.
    have been obtained and that the collection and processing of such data comply with applicable data protection laws.

5. Purposes for Collecting Personal Data

SunCulture may process personal data for the following purposes:

  1. Products and Services: To process orders, deliver and install products, provide warranties, customer support and maintain equipment.
  2. Contracts and Commercial Relationships: To manage agreements, suppliers, contractors, business partners, payments and contractual obligations.
  3. Financing and Credit Administration: To assess credit eligibility, manage repayments, monitor accounts and fulfil applicable reporting obligations.
  4. Recruitment and Human Resources: To manage recruitment, employment, payroll, benefits and related legal obligations.
  5. Communications and Marketing: To respond to enquiries, provide service updates, conduct surveys and send marketing communications where lawfully permitted. You may opt out of direct marketing at any time.
  6. Business Operations and Improvement: To conduct audits, reporting, analytics, research, risk management and improve our products, services and digital platforms.
  7. Security and Legal Compliance: To protect our people, property and systems, prevent fraud, comply with legal and regulatory obligations, and establish, exercise or defend legal claims.

6. Disclosure of Personal Data

SunCulture may disclose your personal data, where necessary and lawful, to:

  1. Our employees, authorised representatives, subsidiaries and affiliates who require the information for legitimate business purposes.
  2. Service providers, suppliers, contractors and business partners supporting our operations and delivery of products and services.
  3. Financial institutions, payment service providers and credit reference bureaus, where applicable.
  4. Professional advisers, auditors and insurers.
  5. Regulators, government authorities, law enforcement agencies and courts where required or permitted by law.
  6. Parties involved in actual or proposed business transactions, including mergers, acquisitions or asset sales.

Additionally, SunCulture may disclose your personal data to third parties where necessary and lawful:

  1. To comply with applicable laws, regulations, court orders or lawful requests from competent authorities.
  2. In connection with actual or prospective legal proceedings.
  3. To establish, exercise or defend our legal rights, prevent fraud or manage credit risk.
  4. In connection with an actual or proposed merger, acquisition, restructuring or sale of our business or assets, subject to appropriate safeguards.
  5. Where disclosure is otherwise permitted or required by applicable law.

We do not disclose Personal Data indiscriminately. We apply pseudonymisation and other data minimisation measures to reduce the identification of individuals where personal identifiers are not necessary for the intended purpose. Where third parties process Personal Data on our behalf, we take appropriate steps to ensure that suitable contractual, confidentiality and data protection safeguards are in place.

7. International Transfers of Personal Data

  1. SunCulture may transfer or permit access to Personal Data across borders, including between its affiliated companies and to service providers, technology platforms or business partners located outside the country in which the Personal Data was collected.
  2. All international transfers of Personal Data will be conducted in accordance with applicable data protection laws, with appropriate safeguards in place. These may include contractual protections, assessments of the receiving jurisdiction and other measures required by law.
  3. Where consent or another specific legal condition is required for an international transfer, SunCulture will ensure that the applicable requirements are met before making the transfer.

8. Data Retention

  1. SunCulture retains personal data only for as long as necessary to fulfil the purposes for which it was collected, comply with legal and regulatory obligations, manage contractual relationships, resolve disputes, or establish, exercise or defend legal claims.
  2. We may retain personal data for longer where required by law or where it is reasonably necessary for ongoing or anticipated legal proceedings, fraud prevention or the protection of our legal rights.
  3. Retention periods vary depending on the nature of the data, the purpose of processing and applicable legal requirements. Once personal data is no longer required, we will securely delete, destroy or anonymise it, subject to applicable legal retention obligations.

9. Data Security

  1. SunCulture implements appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, loss, misuse or destruction. These measures may include access controls, authentication procedures, encryption where appropriate, secure storage, confidentiality obligations, staff training, vendor due diligence and incident response procedures.
  2. While we take reasonable steps to safeguard personal data, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.
  3. You are responsible for maintaining the confidentiality of your account credentials and passwords. SunCulture will not request your password except where necessary for authentication during login.
  4. In the event of a personal data breach, SunCulture will assess and respond to the incident in accordance with applicable data protection laws, including any applicable notification obligations.

10. Your Data Protection Rights

Subject to applicable law, you have the right to:

  1. Be informed about how your personal data is collected and used.
  2. Access your personal data held by SunCulture.
  3. Request correction or deletion of inaccurate, incomplete or unlawfully processed personal data, where applicable.
  4. Object to or restrict processing of your personal data, where permitted by law.
  5. Withdraw consent where processing is based on consent.
  6. Request data portability, where applicable.
  7. Object to direct marketing and related processing.
  8. Challenge certain automated decisions, where applicable.
  9. Lodge a complaint with the relevant data protection regulator.

These rights are subject to applicable legal conditions and exceptions. SunCulture may retain personal data where required by law or necessary to establish, exercise or defend legal claims. To exercise your rights, contact us using the details in Section 2. We may request information to verify your identity before processing your request.

11. Cookies and Similar Technologies

  1. SunCulture may use cookies and similar technologies, such as pixels and tags, to ensure website functionality and security, remember preferences, analyse website performance and measure marketing effectiveness.
  2. Depending on the technologies deployed, we may use:
    a) Strictly Necessary Cookies: Enable essential website functions and security.
    b) Functional Cookies: Remember user preferences.
    c) Analytics Cookies: Help us understand website usage and improve performance.
    d) Marketing Cookies: Measure advertising effectiveness and support relevant promotional content, where applicable.
  3. We will obtain consent for non-essential cookies where required by applicable law. You may manage your preferences through our website’s cookie settings, where available, or through your browser settings. Disabling certain cookies may affect website functionality.
  4. Our website may also use third-party cookies. These providers may process information in accordance with their own privacy notices and applicable law. Where SunCulture permits third-party cookies, we will take appropriate steps to ensure that their use complies with applicable data protection requirements.

12. Third-Party Websites and Services

  1. Our website, digital platforms and communications may contain links to third-party websites or services. (“Third party sites”)
  2. SunCulture is not responsible for the privacy practices, policies or content of such third parties. We encourage you to review their privacy notices before providing your Personal Information directly to them.

13. Amendments

  1. SunCulture may update this Privacy Notice from time to time to reflect changes in its business operations, products, services, technology or applicable legal requirements. The revised Notice will be published on our website or communicated through other appropriate channels and will take effect on the date of publication or as otherwise stated in the Notice.
  2. Where required by law, SunCulture will notify affected individuals or obtain the necessary consent before implementing material changes to its personal data processing activities. We encourage you to review this Notice periodically to stay informed of any updates.

14. Grievances

If you have questions, concerns or requests relating to this Privacy Notice or the processing of your personal data, please contact:

SunCulture Kenya Limited
19 Kanjata Road, Muthangari Drive
P.O. Box 25723-00603, Nairobi, Kenya
Email: legal@sunculture.com or report a complaint through our website by filling in the Grievances Entry form.

You may also lodge a complaint with the relevant data protection authority if you believe that your personal data has been processed in violation of applicable law.