Privacy Policy

1- INTRODUCTION

1.1 - Important Information and Who We Are

Welcome to Senses Hub’s Privacy and Data Protection Policy (“Privacy Policy”)

At Senses Hub (“we”, “us”, or “our”) we are committed to researching and developing products for people with disabilities. We proudly support over 30 Assistive Technology products in the East African market, have launched six groundbreaking innovations, and collaborate with over ten international organizations to advance research and product development.

We also offer a premier venue for hosting events, providing an executive space designed to accommodate a variety of gatherings. In addition, we offer a dynamic coworking hub, where professionals can work in a collaborative and inspiring environment.

This Privacy Policy explains how we collect, process, and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.

The individuals from which we gather and use data can include:

• Clients Booking Space

• Newsletter Subscribers

• Online Shoppers

• Website Visitors who fill in the contact form.

And any other people the organization has a relationship with or may need to contact.

This Privacy Policy applies to all our employees and staff members, and we process all Personal Data at any time.

2 - LEGAL BASIS FOR DATA COLLECTION

2.1 - Types of data / Privacy policy scope

“Personal Data” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store, and transfer different kinds of Personal Data about you which we have grouped below.  Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:

• Booking Data: When you book an event or coworking space through our website, we collect your name, email address, and phone number.

• Newsletter Subscription Data: When you subscribe to our newsletter, we collect your email address to send you updates and information.

• Purchase Data: When you purchase items from our online shop, we collect your name, email address, payment details, and shipping address to process and deliver your order.

• Contact Data: This is data relating to Phone numbers, Email addresses, and Message.

We also collect, use, and share Aggregated Data such as how many users rely on which assistive technologies. 

Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used under this Privacy Policy.

We may also aggregate data to enable research or analysis so that we can better understand and serve you and others. For example, we may conduct research on your demographics and usage. Although this aggregated data may be based in part on Personal Data, it does not identify you personally. We may share this type of anonymous data with others, including service providers, our affiliates, agents, and current and prospective business partners.

For our business, we also collect what is known under the GDPR as special categories of Personal Data. We collect the following types of special Personal Data:

• Health Data: Information about health, including any medical condition, health and sickness records

To collect this special kind of data we need enhanced legal justifications beyond the ordinary legal justifications under the GDPR. We explain which justifications we rely on in paragraph 2.2 below.

2.2 – The Legal Basis for Collecting That Data

Several justifiable reasons under the GDPR allow the collection and processing of Personal Data. The main avenues we rely on are:

“Consent”: Certain situations allow us to collect your Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt-in’ to a service.

“Contractual Obligations”: We may require certain information from you to fulfill our contractual obligations and provide you with the promised service.

“Legal Compliance”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.

“Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests - this covers aspects that can be reasonably expected as part of running our business, and that will not have a material impact on your rights, freedom, or interests. Examples could be your address, so that we know where to deliver something to, or your name so that we have a record of who to contact moving forward.

For the special categories of data that we collect, the enhanced legal justification we rely on is:

(a)   The data subject has given explicit consent to the processing of such Personal Data for one or more specified purposes (“Explicit Consent”).

3 – HOW WE USE YOUR PERSONAL DATA

3.1- Clients Booking Space:

• Booking Management: We use your name, email address, and phone number to confirm and manage your bookings for events or coworking spaces. This includes sending you booking confirmations, reminders, and any necessary follow-up communications.

3.2- Newsletter Subscribers:

• Communication: We use your email address to send you newsletters, updates, and promotional materials about Senses Hub’s services, products, events, and other relevant information. You can unsubscribe at any time.

3.3- Online Shoppers:

• Order Processing: We use your name, email address, payment details, and shipping address to process and deliver your orders from our online shop. This includes sending you order confirmations and handling any customer service inquiries related to your purchase.

3.4 - Website Visitors Who Fill in the Contact Info Form:

• Customer Support and Communication: We use the information provided in the contact form (e.g., name, email address, phone number) to respond to your inquiries, provide customer support, and address any questions or concerns you may have.

3.5 - Change of purpose:

We will only use your Personal Data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4 – YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US

4.1 – Your legal rights

Under certain circumstances, you have the following rights under data protection laws about your data:

• Right to be informed. You have a right to be informed about our purposes for processing your data, how long we store it, and who it will be shared with. We have provided this information to you in this policy.

• Right of access. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it (also known as a "data subject access request"). See section 4.4 below for more details on how you can make a data subject access request.

• Right to rectification. You have a right to 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.

• Right to erasure. You have the right to ask us to delete or remove personal data where there is no good reason for us to continue to process it, where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Right to object. You can object to the processing of personal data we hold about you. This effectively allows you to stop or prevent us from processing your data. Note that this is not an absolute right and it only applies in certain circumstances, for example:

1.  Where we are processing your data for direct marketing purposes.

2.   Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms.

3. In some cases, we may continue processing your data if we can demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Right to restrict processing. You have the right to request the restriction or suppression of your data. Note that this is not an absolute right and it only applies in certain circumstances:

1.  If you want us to establish the data's accuracy.

2. Where our use of the data is unlawful but you do not want us to erase it.

3. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims.

4. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Right to data portability. You have the right to request the transfer of your data to you or a third party. If you make such a request, we will provide to you, or a third party you have chosen, your data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.

If you wish to request any of these rights, please contact us at info@senseshub.vision

4.2 – How Senses Hub protects customers' Personal Data

We are concerned with keeping your data secure and protecting it from inappropriate disclosure. Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession. However, unfortunately, no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of Senses Hub to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.

4.3 – Opting out of Newsletter Subscriptions

You can ask us to stop sending you newsletters and promotional emails at any time by writing to  info@senseshub.vision

Even if you opt out of receiving these newsletters, we will continue to retain other personal data you have provided to us through interactions that are not related to your newsletter subscription preferences.

4.4 – How to request your data and the process for obtaining it

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is unfounded, we could refuse to comply with your request.

We may need to request specific information from you to help us confirm your identity and ensure you have the 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 about your request to speed up our response.

5 – YOUR DATA AND THIRD PARTIES

5.1 – Sharing your data with third parties

We may share non-personal Data with third parties. We may share your Personal Data with subcontractors or affiliates, subject to confidentiality obligations to use it only for the purposes for which we disclose it to them and under our instructions.

We may also share Personal Data with interested parties if Senses Hub anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology.

If Senses Hub is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell, or assign your Data to a third party as part of or in connection with that transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the further use of your Personal Data. In all other situations, your data will remain protected per this Privacy Policy (as amended from time to time).

We may share your Personal Data at any time if required for legal reasons or to enforce our terms or this Privacy Policy.

 6 – HOW LONG WE RETAIN YOUR DATA

We will only retain your Data for as long as reasonably necessary to fulfill the purposes we collected it for. We may retain your Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation concerning our relationship with you.

7 – INTERNATIONAL TRANSFER OF DATA

Your information may be stored and processed in Kenya or other countries or jurisdictions outside the country where Senses Hub has facilities. By using Senses Hub, you are permitting and consenting to the transfer of information, including Personal Data, outside of the country. 

8 – NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY

We keep our Privacy Policy under review and will place any updates here. This version is dated 12 August 2024.

By using Senses Hub, you consent to the collection and use of data by us as set out in this Privacy Policy. Continued access or use of Senses Hub will constitute your express acceptance of any modifications to this Privacy Policy.

9 – INTERPRETATION

All uses of the word "including" mean "including but not limited to" and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to a legitimate subject matter for which we have provided an email address. You are more likely to get a reply if your request or question is polite and reasonable and there is no relatively obvious other way to deal with or answer your concern or question (e.g. FAQs, other areas of our website, etc.).

Our staff is not authorized to contract on behalf of Senses Hub, waive rights, or make representations (whether contractual or otherwise). If anything contained in an email from Senses Hub’s email address contradicts anything in this policy, our terms, or any official public announcement on our website, or is inconsistent with or amounts to a waiver of any Senses Hub’s rights, the email content will be read down to grant precedence to the latter.

The only exception to this is genuine correspondence expressed to be from the Senses Hub’s legal department.