This Privacy Notice for Miss Koch Kenya (doing business as MKK) (“we,” “us,” or “our“) describes how and why we might access, collect, store, use and/or share (“process“) your personal information when you use our services (“Services“), including when you:

• Visit our website at misskoch.org, or any website of ours that links to this Privacy Notice
• Engage with us in other related ways, including any events

Miss Koch Kenya (MKK) is a registered not-for-profit youth empowerment organisation based in Nairobi, Kenya. Founded in Korogocho in 2001 and registered as an NGO in 2010, MKK runs programmes in education and mentorship, talents and entrepreneurship, mental and sexual reproductive health, and leadership and governance. Our website shares information about our work, lets visitors get in touch with us, and allows supporters, partners and donors to engage with and support our programmes.

1. What information do we collect?

Personal information you disclose to us

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our Services, when you participate in activities on the Services, when you make a donation, or otherwise when you contact us.

Personal information provided by you. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the features you use. The personal information we collect may include the following:

• names
• email addresses
• phone numbers

Sensitive information. We do not process sensitive information.

Payment data. We may collect data necessary to process your payment if you choose to make a donation, such as your payment instrument number and the security code associated with your payment instrument. All payment data is handled and stored by Paystack and Safaricom (M-PESA). You may find their privacy notices here: Paystack and Safaricom.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

We automatically collect certain information when you visit, use or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many organisations, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Policy.

The information we collect includes:

• Log and usage data. Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings, and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity and error reports, sometimes called “crash dumps”), and hardware settings.
• Device data. We collect device data such as information about your computer, phone, tablet or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system and system configuration information.
• Security and fraud-prevention data. Information collected to protect our website and donation forms from spam, bots and fraud, such as IP address, browser characteristics and interaction signals processed by our CAPTCHA provider, and records of login attempts.
• Donation transaction data. When you make a donation, we automatically record technical information such as your IP address and the date and time of the transaction, to process payments, prevent fraud and keep accurate records.

2. How do we process your information?

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
• To respond to user inquiries and offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To send administrative information to you. We may process your information to send you details about our programmes and Services, donation receipts, changes to our terms and policies, and other similar information.
• To process and manage your donations. We may process your information to process and manage your donations, payments, receipts and any refunds made through the Services.
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To evaluate and improve our Services and your experience. We may process your information when we believe it is necessary to evaluate and improve our Services and your experience.
• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
• To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish or defend our legal rights.

3. When and with whom do we share your personal information?

Vendors, consultants and other third-party service providers. We may share your data with third-party vendors, service providers, contractors or agents (“third parties“) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

The categories of third parties we may share personal information with are as follows:

Data Analytics Services Payment Processors Website Hosting Service Providers Cloud Computing Services Government Entities AI Platforms

Some of these third parties, such as Google and Paystack, may process your information outside Kenya. Where this happens, we rely on their contractual commitments to protect your information in accordance with applicable data protection laws.

We also may need to share your personal information in the following situations:

• Organisational changes. We may share or transfer your information in connection with, or during negotiations of, any merger, restructuring or transfer of all or part of our programmes or operations to another organisation.
• When we use Google Maps. Our Contact Us page displays an interactive Google Map so you can find and get directions to our offices. When you view or use the map, Google may receive information such as your IP address. We do not obtain or store your location. Your use of the map is subject to the Google Maps/Google Earth Additional Terms of Service and the Google Privacy Policy.

4. Do we use cookies and other tracking technologies?

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services, prevent crashes, fix bugs, save your preferences and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics. We do not use cookies or tracking technologies for advertising, and we do not allow third parties to use them on our Services to serve advertising.

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

Google Analytics

We may share your information with Google Analytics to track and analyse the use of the Services. To opt out of being tracked by Google Analytics across the Services, visit tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.

5. How long do we keep your information?

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than five (5) years after your last donation or interaction with us, unless a longer period is required by law.

When we have no ongoing legitimate need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

6. How do we keep your information safe?

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

7. Do we collect information from children?

Our website is intended for adults, including supporters, partners and donors. We do not knowingly collect personal information online from children under 18 years of age, and we do not knowingly accept donations from them.

Young people under 18 who wish to take part in our programmes engage with us in person through our main office, accompanied by a parent or guardian. Any information we need about a child is collected there, with the consent of the child’s parent or guardian, in accordance with Kenya’s Data Protection Act, 2019.

If we learn that we have collected personal information from a child under 18 through our website without the consent of a parent or guardian, we will take reasonable steps to delete it promptly. If you are a parent or guardian and believe your child has provided us with personal information online, please contact us at info@misskoch.org.

8. What are your privacy rights?

Under Kenya’s Data Protection Act, 2019, and other applicable laws, you may have the right to be informed of how your personal information is used, to access it, to object to its processing, and to have inaccurate or misleading information corrected or deleted. If you believe we have not handled your personal information properly, you may lodge a complaint with the Office of the Data Protection Commissioner. We would, however, appreciate the chance to address your concerns first, so please contact us.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us using the contact details provided in the section “How can you contact us about this notice?” below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Cookies and similar technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. For further information, please see our Cookie Policy.

If you have questions or comments about your privacy rights, you may email us at info@misskoch.org.

9. Controls for Do-Not-Track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

10. Do we make updates to this notice?

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated “Last updated” date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

11. How can you contact us about this notice?

If you have questions or comments about this notice, you may email us or contact us by post:

12. How can you review, update or delete the data we collect from you?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

To request to review, update or delete your personal information, please email us:

Email info@misskoch.org