09/10/24

REVIEWED EcocanApp PRIVACY POLICY

This Privacy Policy details in general terms how we collect, store, and use your personal information.

 ECOCAN, represented by ECOCAN Finland OY, and ECOCAN Recycling Company Limited, with respective registered addresses of Korkeavuorenkatu 7c 49 00140 Helsinki, Finland, and, Hanover Building, 5686-00100 Nairobi, Kenya, and their worldwide subsidiaries, associates and/or affiliates, collectively “ECOCAN, collects, stores, and uses your personal information as a data controller, in connection with the use of the ECOCAN services (the “Services”), ECOCAN websites (the “Sites” or each “Site” including https://ecocan.africa/ ), ECOCAN Mobile application (the “EcocanApp”), and participation in our various reward programs (each a “Program”, including Recycling discounts and Loyalty benefits), accessible via the Services, the Site or via any related mobile or computer-based applications (“Apps” including EcocanApp) and other related services (collectively, “Services“) according to this privacy policy (“Privacy Policy”). The Privacy Policy should be read together with, and is subject to, the ECOCAN Terms of Use.

For questions and information about Privacy Policy, please contact us via email at email address: info@ecocanarica.com .

All Services are governed by this Privacy Policy and by using or accessing the Services you give consent to the processing, use and disclosure of your data. Please do not install or use the Services if you do not agree to this Privacy Policy. 

ECOCAN reserves the right to modify this Privacy Policy. Your continued use of Services will signify your acceptance of the changes to this Privacy Policy. The Privacy Policy as amended from time to time is available in the Site (under “Privacy Policy”) and via the EcocanApp.

What information does ECOCAN Collect?

A. Information You Provide Voluntarily

In order for you to get access and participate in any ECOCAN Service(s), you first must create an ECOCAN profile and agree to the Terms of use of the services. As a User, you may provide us with the following types of information, all of which will be subject to this Privacy Policy

• Personally identifiable information (" PII "), such as your name, phone number, or email address, which we require to enrol you as a User and communicate with you.
• Information about you (which may include your age and gender), which we may request to help provide legal, safe and more personalized experience.
• ECOCAN ID and Online Profile Information. If you choose to create an online profile on our Site or associated Sites, or customise your ECOCAN ID, which is optional, you will have the option to upload certain personal information about yourself that you wish to share (such as food and drinks preferences, pictures, identification number, hobbies and interests, text descriptions, friends, and other profile information similar to other social networking communities). You can update your online profile by logging in to your ECOCAN profile, go to My information, and edit.

B. Information Provided About You From Other Sources

Your participation in some of ECOCAN Service(s) may lead to us to receive certain additional information about you through third parties. This information may originate from:

• Reward programmes, Recycling benefits programmes and Customer loyalty programs offered by ECOCAN, participating Retailers, Grocers and Agents where you buy and/or recycle containers, or participating producers of eligible products.
• Social media and social networking sites such as those offered by Meta or X that you have opted to link to your ECOCAN profile.
• Third party account providers which may include M-PESA, T-Kash, Airtel Money, or PayPal to which you transfer ECOCAN credits and payments to or from, in the course of using the Services.

C. Browsing, Scanning and navigation Information:

When you use the Services and/or Site, we track information to assist us to administer the Services, our other products, and analysing usage. This information includes:

• Your Internet Protocol (IP) address
• The state, country or region from which you access the Services
• Date and time
• The kind of browser or computer you use
• Name of your Internet service provider
• Web pages from which you link to our Services or go to from our Services
• The web pages within our Site you view when visiting our Services
• Geolocation if you access our Services via a mobile device, and use map function for navigation. You will have the option to turn off geolocation on your mobile device, but certain features in our mobile apps may not then work properly for you. As part of our browsing, scanning and tracking processes described above, we use third-party technology, which include Google Analytics and AWS (US) ECOCAN does not knowingly provide Google or AWS with any PII as part of using Google Analytics or AWS. Further information about the Google Analytics privacy principles can be found at http://www.google.com/intl/en/analytics/learn/privacy.html . And AWS privacy Notice https://aws.amazon.com/privacy/ 

D. Cookies

We use cookies to personalize or enhance your user experience and to facilitate the tracking of session and cross session activities. A cookie is a small text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. For example, if you personalize a web page, or navigate within a site, a cookie helps the site to recall your specific information on subsequent visits. Hence, this simplifies the process of delivering relevant content and eases site navigation by providing and saving your preferences and login information as well as providing personalized functionality.

The type of information that may be stored in a cookie includes non-PII about you. Some examples may include a randomly assigned user or session identification number, the country where you are located, and your first name to welcome you back to the site. We reserve the right to share aggregated site statistics with third parties, but will not allow other companies to place cookies on our Site unless there is a temporary, overriding customer value (such as merging into our Site another site that relies on third-party cookies).

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. If you reject cookies by changing your browser settings, then be aware that this may affect the functionality of our Site.

E. Recycling and Purchase Patterns

In order to participate in any of our various recycling and/or loyalty Programs, ECOCAN may record beverage container recycling habits, redemption habits, purchasing habits and other information about you associated with our Programs. For example, we may record the frequency with which you recycle and the weight or volume of the materials you recycle through our Programs as well as the particular containers that your recycle. And the purchases made via our Services

F. When you provide personal information, the information may be sent to servers located in the EU.

Why Does ECOCAN Collect Information About You and How Do We Use It?

ECOCAN uses the information described above to provide you with a superior and personalised User experience, to administer our business and our offerings, and to administer rewards, recycling and loyalty  Programs. For example, we collect various types of information that allow us to:

• Reward Users in our Programs for certain activities including recycling and purchases.
• Provide a more personalized experience by using any images and screen names that you may provide or select to identify you, both to yourself and to other participants, which may include us publicly displaying on our Site your photo and user name in connection with your profile and activities in our Programs.
• Verify your identity.
• Promote partners and vendors who support our various Programs.
• Conduct research and perform analysis
• Administer sweepstakes, contests, promotions, or surveys.
• Communicate with you about special offers, events, new products or services, or surveys.
• Provide you with information about products and services from us and others, and also to enable trusted marketing partners to communicate with you about their products/services.
• Serve advertisements to you which are tailored to your interests based on information we receive about you as set forth above, including tracking your activities while you use our Services.

With Whom Does ECOCAN Share Your Information and Why?

A. With your Consent: We may share or disclose your PII with third parties with your express consent. Should an event arise which we deem appropriate to obtain your express consent, we will contact you directly using the contact information we have on file for you. It is therefore important that you maintain all your information with us current and accurate.

B. Service Providers: ECOCAN, like many businesses, sometimes hires other companies to perform certain business-related functions (e.g. further development of our services, mailing campaigns to customers, maintaining databases, processing payments, and processing purchases). When we employ the services of another company to perform a function of this nature, we will provide them with the information they need to perform their specific function(s) and require them to use it only for the limited purpose of providing the services contracted by ECOCAN. In other circumstances, we may use the services of a third party, where both we and the third-party receive your information and the third party also acquires the right to use the information you submit in accordance with its own privacy policy.

C. Participating Retailers and Producers: If you elect to participate in a Program offering integration into a participating retailers, grocer or producers loyalty program, information about you and your recycling activities may be shared with the retailer/grocer/producer.

D. Business Transfers: In the event we sell or transfer our business or assets, including as part of any bankruptcy, our databases may be transferred to the new owner/successor.

E. Legal Compliance: We may disclose your PII if we are required to comply with a law, regulation or legal request such as a subpoena from a court; to protect the safety of any of our Services users, any person or the general public; to address fraud, security or technical issues; or to protect ECOCAN’s rights or property.

F. Trusted Marketing Partners: From time to time, we may share information about you with trusted third parties for them to market to you goods or services we think may be of interest to you.

G. ECOCAN Rewards (Loyalty and Recycling) Programs: A key component of our Rewards Programs is the ability for you to earn and redeem credits and rewards, which are then redeemable for various Rewards offered Reward Partners, or for cash. These Reward Partners are linked to our Rewards Programs both outside and through our Services and integrated into User Accounts to allow for maximum User ease in both earning and transferring credits, and redeeming Rewards. This integration includes ECOCAN making available certain aggregated User information which is anonymous as to any specific User. In addition, when you claim a Reward from a third-party Reward Partner, you will also be giving information to that Reward Partner which will be subject to that Reward Partner’s privacy policy as well as this privacy policy. The ECOCAN Rewards Program will commence and apply in the absolute discretion of ECOCAN. As at the date of commencement of this Privacy Policy, the ECOCAN Rewards Program has not commenced. ECOCAN makes no representation that the ECOCAN Rewards Program will commence, or will commence in the manner proposed in the Terms of Service.

H. Non-Personal Aggregate Data: We may provide aggregated anonymous information concerning usage of our Services to third parties for any purpose not prohibited by law.

What Information Is Collected Through Integration With Social Media/Third Party Services?

A. The Services may make access to social media sites available to you. You are not required to provide any personal information when using these areas, but if you do then (i) such information will become publicly available, (ii) you may receive unsolicited messages from other parties with access to the same social media platforms, and (iii) when you post a comment to some social media sites, your username and possibly your current location may be made publicly available. By accessing social media sites via our Services, you acknowledge that your username and location information may be disclosed, and that the information you post then becomes subject to the usage terms and privacy policy of the applicable social media site(s); be sure to check those terms and policies.

B. We may also offer you the ability to sign in to our Services through one or more social networking services. If you do so, any information you supply (or have supplied) to us becomes subject to the privacy policy of that social network/service. We do not control, and are not responsible for, the privacy practices of such networks or services. You should consult the privacy policy of such networks/services.

C. We cannot ensure the security of any information you choose to make public on social media sites. Also, we cannot ensure that parties who have access to such publicly available information will respect your privacy. Please exercise caution when deciding to disclose personal information in these areas.

The Use Of Third-Party Ad Serving Technologies

Our Services may use third party ad serving technology that use certain methods to collect information as a result of ad serving through Services. Information collected will as a main rule not be personal identifiable.

ECOCN reserves the right to use and disclose the collected data for purposes of advertising through the Services or ECOCAN partners and contractors.

Services or third parties operating the ad serving technology may use demographic and geo-location information, as well as information logged from your hardware or device to ensure that relevant advertising is presented within the Service. ECOCAN or third parties may collect and use data, for such purposes, including but not limited to, data such as IP address, email address, Device ID, MAC address, installed software, application usage data, hardware type, Operating System information, browser information, unique identifiers in browser cookies, Flash cookies, and HTML5 local storage, Internet and on-line usage information and in-game information. Please note that you may adjust the settings in your device to accept or not accept cookies. Rejection of cookies may affect functionality in the Services. The foregoing data may be used and disclosed in accordance with this Privacy Policy and the privacy policy of the company providing the ad serving technology.

Data Processors

ECOCAN may use Data Processors which processes PII and other relevant information on ECOCAN’s behalf for the purposes of providing the Services and in accordance with a written data processing agreement.

Third Party Links and Websites

This Privacy Policy applies only to the ECOCAN Services and the Site. Use of ECOCAN Services, the site, and emails received from ECOCAN may contain advertisements for and links to other websites not operated or controlled by ECOCAN. The policies and procedures we describe here do not apply to those third-party sites. The links to third party websites available on ECOCAN Services and the Site or in any emails sent to you by ECOCAN do not imply that ECOCAN endorses or has reviewed those third-party sites. We suggest contacting those sites directly for information on their privacy policies

Information Security

ECOCAN processes personal data in accordance with the GDPR Privacy Principles, and follows generally accepted industry standards to maintain appropriate technical and organizational security measures.

We use reasonable safeguards to help prevent loss, misuse and unauthorized access, disclosure or modification of PII provided to us or collected through our services and the Site. However, because no method of transmitting or storing electronic data on the internet is ever completely secure, we cannot guarantee that such information will never be accessed, used, or released in a manner that is inconsistent with this Privacy Policy.

Data Retention

ECOCAN retains the collected data for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. Thereafter ECOCAN deletes all aforementioned data in its possession within a reasonable timeframe.

Please note that some data may be further retained if necessary to resolve disputes, enforce Terms of Service and comply with technical and legal requirements and constraints related to the security, integrity and operation of Services.

Special Note About Children’s Privacy

Our content is neither directed toward minors nor children who are under the age of 14 years. We do not knowingly collect personal information from children under the age of 14. If ECOCAN learns that we have inadvertently gathered personal data from children under 14 years of age, ECOCAN will take reasonable measures to promptly delete such personal data from ECOCAN records.

Parents/guardians who have questions about personal information that they suspect may have been submitted by a child under the age of 14 should email us at info@ecocanafrica.com 

ECOCAN requires that companies comply with ECOCAN’s  Privacy Policy before ECOCAN allows those companies to access our sites and Services. However, please note that ECOCAN’s partners may have their own policies related to tracking technologies for analytics and ad-serving purposes.

Updates to the Privacy Policy

The Services, Site and our Programs may change from time to time. As a result, it may be necessary for ECOCAN to make changes to this Privacy Policy. We reserve the right to update this Privacy Policy at any time, with or without advance notice. In the event there are significant changes in the manner in which we maintain and treat PII or the terms of this Privacy Policy, we will display a notice on our Site and Services. We also may send Users’ emails to inform them of these changes, though we not obligated to do so. If you object to this Privacy Policy or to any future update of this policy or no longer wish to participate in any ECOCAN Reward Programs, you may close your User Account by contacting us. We encourage you to periodically review this Privacy Policy to stay informed about how we are helping to protect the PII we receive from you. Your continued use of the Services, Site or participation in any of the Programs ECOCAN offers after the posting of any change shall constitute your agreement to this Privacy Policy and any of its updates.

Idea Submissions

All unsolicited information (other than your PII and personal information) that you provide to ECOCAN through our Services, Site or through other means (such as by posting to any public areas of the Services, Site or sending us ideas for new services or modifications to our services) is deemed non-confidential and we are free to reproduce, use, disclose, and distribute any of this unsolicited information to others without limitation or attribution.

Governing Law

This Privacy Policy is governed by the Laws of The Republic of Kenya.

Contact Us and Complaints

Should you have any questions or comments or complaint about our Privacy Policy, or regarding how your personal information is collected, stored or used, please contact us at email: info@ecocanafrica.com