Introduction & Contents
Afro Exports Ltd respects your privacy and is committed to protecting your personal data. This privacy notice explains how we use and protect the personal data you provide to us. It also explains your privacy rights and protections.
We have tried to keep this privacy notice simple without compromising on the information provided to you. We have therefore broken it down into the following sections:
1. Important information & our details
2. The data we collect about you
3. How your personal data is collected
5. How we use your personal data
6. Disclosure of your personal data
7. International Transfers
8. Data Security
9. Links to other websites
10. Data Retention
11. Your Legal Rights
1.Important information & our details
Purpose of this privacy notice
This privacy notice gives you information about how we collect and process personal data you provide to us, including any data you provide via our website (https://www.afroexports.com) or when you provide us with your contact details through day to day business contact.
Our contact details and role
We are the data controller responsible for your personal data. Our full details are:
Name: Afro Exports Limited
Company registration number: 1679028
Email address: firstname.lastname@example.org
Postal address: 5 Clifton Court, Cornerhall, Hemel Hempstead, Herts HP3 9XY
Telephone number: +44 (0)1442 230006
If you have any questions about this privacy notice, including any requests to exercise your legal rights (see section 11 below), please contact us using the details set out above.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) (www.ico.org.uk), which is the supervisory authority for UK data protection issues. However, we ask that you contact us in the first instance and give us the opportunity to address your concerns before you consider contacting the ICO.
It is important that the personal data we hold about you is accurate and current, so please let us know if your personal data changes at any time.
2.The data we collect about you
We may collect, use, store and transfer the following kinds of personal data about you, which we have summarised into categories:
Identity Data: includes first name, last name.
Contact Data: includes email address and telephone numbers.
The above categories are used as defined terms elsewhere in this privacy notice, in particular section 5.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Our business offering is not intended for children and we do not knowingly collect data relating to children.
3.How your personal data is collected
We use different methods to collect your personal data including through:
Directly from you. You may give us your Identity and Contact Data either face to face, via exchange of business cards or by filling in forms or by corresponding with us by post, phone, email or otherwise.
Third party sources. We may receive Identity and Contact Data from other network organisations.
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website
5.How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform our business contractual obligations to your business.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Legitimate Interest(s) means the interest of conducting and managing our business to enable us to give you good services/products and a good and secure experience. We consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by clicking on the “Unsubscribe” link at the bottom of all our marketing emails or by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and legal bases we rely on in doing so. We have also identified what our legitimate interests are where appropriate.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest||Personal Data Retention|
|To register interest in our products and services||I. Identity||Necessary for our legitimate interests||Prospect Data – 7 years|
|II. Contact||Specific Consent gathered in certain circumstances|
|To register you as a customer||I. Identity||Performance of a contract with you||Live Customer – 10 years|
|II. Contact||Dormant Customer – 6 years|
|To process and deliver goods or services to you, your associates or clients:||I. Identity||Performance of a contract with you, your associates or clients||Live Customer – 10 years|
|II. Contact||Necessary to comply with a legal obligation||Dormant Customer – 6 years|
|Necessary for our legitimate interests|
|To administer and protect our business, our Site and our Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||I. Identity||Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)||Industry or Supplier contacts – 10 years|
|II. Contact||Necessary to comply with a legal obligation|
6.Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in section 5 above.
Internal third parties
AEL Sweden AB – acting as joint controllers or processors and who are based in Sweden and provide coordinated sales implementation and support services.
Afratech Ltd – acting as joint controllers or processors and who are based in Kenya and provide coordinated sales implementation and support services.
Hospitality Systems Consultants Ltd – acting as processors who are based in Kenya and provide coordinated support services.
Gamtech Ltd – acting as processors who are based in The Gambia and provide coordinated support services.
The following external third parties:
Professional advisers including lawyers, accountants and auditors who provide [legal and accounting services].
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Although your personal data is held in UK secure environments, our group employees may view your data over secure internet devices outside the European Economic Area. This classifies as an international data transfer. For example, the companies listed in section 6 above are partner companies that operate jointly to support our customer base.
Whenever we transfer your personal data out of the EEA, we ensure that the data is transmitted using secure protocols and subject to the same security processes as the UK business.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9.Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Personal data retention periods are summarised in the table in section 5.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
11.Your legal rights
You have the right to:
Request access to your personal data (commonly known as a « data subject access request »). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us at email@example.com
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.