This Privacy Policy explains how we use the personal information that ClintelRad and Clintec Technologies through the platform ClintelRad collects or generates both in relation to our website www.clintelrad.com and our products and services.

1. OVERVIEW

1.1 Clintec Technologies having its registered office at Afya Centre, Tom Mboya St, Nairobi, Kenya, collects and uses certain Personal Data (as defined below). Clintec Technologies is responsible for ensuring that it uses that Personal Data in compliance with data protection laws. For the purposes of data protection laws, ClintelRad acts as a “data controller” with respect to certain Personal Data and may receive such information about you.

1.2 At ClintelRad, we respect the privacy of our clients and we are committed to keeping all your Personal Data secure. This Privacy Policy governs the handling of Personal Data by ClintelRad in the course of carrying on commercial activities.

1.3 We use the following definitions in this Privacy Policy:

“we”, “our” or “us” means Clintec Technologies.

“Personal Data” means any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, ClintelRad (or its representatives or service providers). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of ClintelRad or any other person in respect of an individual.

2. OUR PRODUCTS AND SERVICES

2.1 This Privacy Policy concerns the following categories of information that we collect about you when providing the following products and services:

(A) Information we receive through our websites (“ClintelRad Website”);
(B) Information we receive through our products (“ClintelRad Products”); and
(C) Information we receive through our support, cloud-based, system integration and services (“ClintelRad Services”).

3. KIND OF PERSONAL DATA WE COLLECT

3.1 Many of the services offered by ClintelRad require us to obtain Personal Data about you in order to perform the ClintelRad Services we have been engaged to provide. In relation to each of the services described at paragraph 2.1 above, we will collect and process the following Personal Data about you:

• Information that you provide to ClintelRad. This includes information about you that you provide to us (whether by filling in forms on the ClintelRad Website (including our “Contact Us” form), during telephone calls with us, or otherwise). The nature of the services you are requesting (in the case of customers) will determine the kind of Personal Data we might ask for, though such information may include (by way of a non-exhaustive list):

– basic Personal Data (such as first name; family name; position in the company; company name; company email address; business phone number; business address; city; postcode; country).

• Information that we collect or generate about you. This includes (by way of non-exhaustive list):

For customers and suppliers:
• Information collected during the course of maintaining security of our sites (including CCTV images).

For customers only:
• A file with your contact history to be used for enquiry purposes so that we may ensure that you are satisfied with the services which we have provided to you;
– through our cloud security services, traffic and security reports that include information on the internet usage of the organisation’s computer users (e.g. what websites were visited by each user, any documents downloaded, security incidents, prevention measures taken by the gateway, etc.).

• Information we obtain from other sources.

• Cookies
– When you visit the ClintelRad Website, cookies are used to collect technical information about the services that you use, and how you use them.
– For more information on the cookies used by ClintelRad please see our Cookie Policy which is available on the ClintelRad Website www.teleradtech.com

• Non-Personal data
– In addition to the categories of Personal Data described above, ClintelRad will also use other information and data that is not personal data. Such other information and data is not used by reference to a specific individual.

• List brokers
– We receive personal data from list brokers from time to time in order to build our contact data base.

• Industry Events
– When we sponsor industry events such as trade shows, delegates are issued with badges with a barcode which we can scan to collect their contact details when they visit the ClintelRad stand at the event. The event organisers collect the data from our scanners and provide it to us in the form of an Excel document. This data is then uploaded to our marketing automation system.

4. HOW WE USE YOUR INFORMATION

4.1 Your Personal Data may be stored and processed by us in the following ways and for the following purposes:

• To communicate with you in order to provide you with services or information about ClintelRad and ClintelRad Products (including to notify you about changes and upgrades to existing ClintelRad Products and Services that you purchase from us);
• To set up customers to use ClintelRad Products;
• For the management and administration of our business;
• For ongoing review and improvement of the information provided on the ClintelRad Website to ensure they are user friendly and to prevent any potential disruptions or cyber attacks;
• To allow you to use and access the functionality provided by the ClintelRad Products for the purposes of assessing whether ClintelRad Products are suitable for your purposes;
• To assess your application for ClintelRad Products, where applicable;
• To conduct analysis required to detect malicious data and understand how this may affect your IT system;
• For statistical monitoring and analysis of current attacks on devices and systems and for the on-going adaptation of the solutions provided to secure devices and systems against current attacks;
• To understand feedback on ClintelRad Products and to help provide more information on the use of those products and services quickly and easily;
• To understand your needs and interests;
• In order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures; or
• For the administration and maintenance of databases storing Personal Data.

4.2 However we use Personal Data, we make sure that the usage complies with law. We use personal data for a variety of reasons. These include:

• We need to do so in order to perform our contractual obligations with our customers and suppliers (as applicable);
• We have obtained your consent;
• We have legal and regulatory obligations that we have to discharge;
• We may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
• The use of your Personal Data as described is necessary for our legitimate business interests, such as:
– allowing us to effectively and efficiently manage and administer the operation of our business;
– maintaining compliance with internal policies and procedures;
– monitoring the use of our copyrighted materials;
– enabling quick and easy access to information on ClintelRad Products;
– offering optimal, up-to-date security solutions for mobile devices and IT systems; and

4.3 We will take steps to ensure that the Personal Data is accessed only by employees of ClintelRad that have a need to do so for the purposes described in this Privacy Policy.

5. DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES

5.1 We may also share your Personal Data outside of the ClintelRad group for the following limited purposes:

• With third party agents and contractors for the purposes of providing services to us (for example, ClintelRad’s accountants, professional advisors, IT and communications providers and debt collectors). These third parties will be subject to appropriate data protection obligations and they will only use your Personal Data as described in this Privacy Policy;
• To the extent required by law, for example if we are under a duty to disclose your Personal Data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend its legal rights;
• If we sell our business or assets, in which case we may need to disclose your Personal Data to the prospective buyer for due diligence purposes; and
• If we are acquired by a third party, in which case the Personal Data held by us about you will be disclosed to the third-party buyer.

6. INTERNATIONAL TRANSFERS OF PERSONAL DATA

6.1 ClintelRad is a global business. Our distributors, suppliers, customers and our operations are spread around the world. As a result, we collect and transfer Personal Data on a global basis. That means (except where the terms of the contract between us expressly prohibit us from doing so), that we may transfer your Personal Data to locations outside of your country.

7. HOW WE PROTECT YOUR INFORMATION

7.1 We have extensive controls in place to maintain the security of our information and information systems. Client files are protected with safeguards according to the sensitivity of the relevant information. Appropriate controls (such as restricted access) are placed on our computer systems. Physical access to areas where Personal Data is gathered, processed or stored is limited to authorised employees.

7.2 As a condition of employment, ClintelRad employees are required to follow all applicable laws and regulations, including in relation to data protection law. Access to sensitive Personal Data is limited to those employees who need to it to perform their roles. Unauthorised use or disclosure of confidential client information by a ClintelRad employee is prohibited and may result in disciplinary measures.

7.3 When you contact a ClintelRad employee about your file, you may be asked for some Personal Data. This type of safeguard is designed to ensure that only you, or someone authorised by you, has access to your file.

8. HOW LONG WE KEEP YOUR PERSONAL DATA

8.1 How long we will hold your Personal Data for will vary and will be determined by the following criteria:

• The purpose for which we are using it – ClintelRad will need to keep the data for as long as is necessary for that purpose; and
• Legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Data.

9. YOUR RIGHTS

9.1 In all the above cases in which we collect, use or store your Personal Data, you may have the following rights, and, in most cases, you can exercise them free of charge. These rights include:

• The right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
• The right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain Personal Data to comply with a legal obligation;
• In some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided directly to ClintelRad;
• The right to request that we rectify your Personal Data if it is inaccurate or incomplete;
• The right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are legally entitled to retain it;
• The right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled to refuse that request; and
• The right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.

9.2 You can exercise your rights by contacting us using the details listed in paragraph 11 below.