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Privacy Policy

Muthaiga Country Club (“the Club” “us” or “we”) operates www.mcc.co.ke (the Site). This Privacy Policy (the 'Privacy Policy’) applies to the collection, use and disclosure of personal information we receive from the users of the Site, a membership applicant, Club suppliers, visitors, and Club members ('you' or 'your' being interpreted accordingly).
 
In addition to this external privacy policy, processing of personal data for an already existing /onboarded Club member, is available in the Members Central Portal.
 
By providing your personal information to this Site or submitting your personal data, you are taken to accept the terms of this Privacy Policy.


Scope of Application

The Privacy Policy provides information on what personal data we collect, why we collect the personal data, how it is used and the lawful basis on which your personal data is processed, and what your rights are under the Kenya Data Protection Act, 2019 (the DPA).

As used in this Policy, ‘Personal Data’ includes information that can be used to identify an individual.

Personal Data we Collect:

We collect the following personal data about you:

Membership Application: The personal details you provide to a Club Member for your nomination as a Club Member through a membership application form. This includes your name, address, country; e-mail address; business address and phone number; gender and date of birth; information about your work and other information that you elect to provide to support your application. We also collect information about your children and spouse, that we require for the purpose of processing your membership application (and administering your membership if admitted as a Club member).

Reservation Information: Guest information, such as your first and last name, email address, billing, and payment information (for further details please also refer to the section below headed "Payment Information"). Personal data collected in relation to reservations will be processed in accordance with a Privacy Policy provided at the time of requesting a reservation so please ensure that you read our privacy notice on the reservation website that we may provide to you when we collect or process your personal data.

Log data: We also process personal data such as internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this Site. Our Site uses cookies (small text files placed on your device) and similar technologies to distinguish you from other users. This is to provide you with a good user experience when you browse our Site and allows us to improve its features. Users have the ability to accept or modifying settings in their browsers to accept or refuse cookies. However, you may not be able to use the interactive features of our site if cookies are disabled. 

Other Information: Personal details you choose to give when corresponding with us by phone or e-mail, participating in our procurement process or otherwise visiting and interacting with this Site, and personal data that you provide to us when you visit our Club.

How we use your personal data
The Club processes your personal data for the following purposes:

  1. To acknowledge, confirm, and process a nomination membership application form, including placing you on our waiting list if necessary. This use of your data is essential for fulfilling your interest in becoming a member.

  2. If you are a member, we use your data to deliver membership services, manage your membership account, and communicate with you regarding your utilization of the services. This processing is necessary to address and fulfill your requests, as well as to perform the contractual obligations between you and us.

  3. To contact you in connection with your enquiries or any complaints you make, and to utilize any information you choose to submit in response. This interaction aims to enhance our services and is contingent upon your request.

  4. To notify you about changes to our service, provide you with user support and enforce our terms, conditions, and policies.

  5. In order to comply with our legal obligations, we use your data to help us detect abuse, fraud, and illegal activity on the Site.

  6. To administer our Site, to better understand how visitors interact with our websites and ensure that our Site is presented in the most effective manner for you and for your computer/device.

  7. We may anonymize, aggregate and de-identify the data that we collect and use such anonymized, aggregated and de-identified data for our own internal business purposes, including sharing it with our current Club members, business partners,  and other third parties for commercial, statistical and market research purposes, for example to allow those parties to analyze patterns among groups of people, and conducting research on demographics, interests and behavior.

  8. For internal business/technical operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to keep our Site, network, and information systems secure.

  9. To comply with legal obligations and enforcing or defending legal rights.

  10. We may use your personal data for other purposes, which you consented to at the time of providing your data including but not limited to provide you with location-based services (where those services are available in your jurisdiction, and you choose to share your precise location with us). 

Sharing, Transfers and Disclosing Your Personal Data

We may share and disclose your personal data with third parties in the following situations:

  1. Administrative and legal reasons: if we need to disclose your personal data : (i) to comply with a legal obligation and/or judicial or regulatory proceedings, a court order or other legal process requirements from public health organization and state authorities;  (ii) to enforce other applicable contract terms that you are subject to ; or (iii) to protect us, our members, membership applicants, or contractors against loss or damage. This may include (without limit) exchanging information with law enforcement officers. 

  2. Service Providers: The Club may hire vetted third parties to support its operations such as: (i) IT suppliers and contractors (e.g., data hosting providers or delivery partners) as necessary to provide IT support and enable us to provide membership services and other goods/services available on this Site or to members; and (ii) web analytics providers.

In some cases, we may transfer your personal data to a country outside of Kenya. If personal data is transferred to any such country, we will ensure that your personal data is protected and that the transfer is carried out in accordance with the DPA.

Your Rights as a Data Subject

Subject to certain limitations under the applicable data protection law, you have the right to: -

  1. be informed of how the Club uses your Personal Data;

  2. access your Personal Data held by the Club;

  3. object or withdraw your consent to processing of part of or all your Personal Data. The Club may however continue to process your Personal Data if we have a legitimate reason to do so. The legitimate reason will be communicated to you upon request; And your withdrawal of your consent may lead to the Club being unable to continue offering services or maintaining your membership.

  4. request for correction of your Personal Data by the Club where it is incorrect or incomplete;

  5. obtain and reuse their personal data for their own purposes across different services.

  6. request for deletion of your Personal Data if it is false or misleading.

If you may wish to exercise any of the rights set out above, please contact the Information Communications Technology (ICT) Department on [email protected]
To realize the above request, we may need to request specific information from you to help us confirm your identity as a security measure to ensure that your personal data is not disclosed to any person who has no right to receive it.

Retention of Personal Data

The Club will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

The Club may retain your Personal Data for a longer period if:-

  1. required or authorized by law;

  2. it is reasonably necessary for a lawful purpose including instances where you have lodged a complaint or if the Club reasonably believes that there is a prospect of litigation in respect to our relationship with you; and

  3. authorized or consented by you.

Security

We have implemented robust security measures to safeguard your personal data, preventing inadvertent loss, unauthorized access, alteration, or disclosure. Access to your personal data is restricted to individuals such as employees, agents, contractors, and relevant third parties with a legitimate business need. These authorized personnel will process your personal data solely based on our instructions and are bound by a duty of confidentiality.

The Club has established procedures to address any suspected breaches of personal data. In the event of such a breach, where legal obligations exist, we will promptly notify you and the relevant regulatory authorities.

Changes to this Privacy Policy

We reserve the right to update or change this Privacy Policy at any time and you should check this periodically. Any changes made to this policy will be placed on our website.

Contact us:
                   ICT Office
                   Email: [email protected]
                   Telephone number: 254 (0)207229215/0111190215
 
Please contact us in case of any questions regarding this Privacy Policy.