Privacy Policy
This notice explains what personal data Monvalen Holdings Limited collects through this website, why we collect it, who else can see it, and what you can do about it. It is written to meet our obligations under the Data Protection Act 2019 of Kenya.
Who we are
Monvalen Holdings Limited is the data controller for personal data collected through this website. We are a company incorporated in Kenya.
For anything in this notice, including a request to exercise your rights, contact info@monvalen.co.ke.
What we collect and why
We only collect personal data that you choose to give us, plus basic analytics about how the site is used. We do not buy data, and we do not build profiles about you from other sources.
Contact form
- What
- Name, email address, phone number (optional), subject, message
- Why
- To respond to your inquiry
- Lawful basis
- Your consent, given when you submit the form
- How long
- Kept while we are in contact with you and for 24 months after our last exchange
IIE and SIE apps (accounts)
- What
- Your name, email address and password (the password is stored in scrambled form by our sign-in provider and is never visible to us), the answers you enter in the tools, and when you last used them
- Why
- To let you sign in, keep your progress on your account across devices, and give our administrators usage statistics
- Lawful basis
- Performance of the service you asked for when you created the account
- How long
- Until you delete your account from the account menu in the app, or ask us to. Administrators see only your email address and how far you have progressed, not your answers
Website analytics
- What
- Pages viewed, approximate location derived from a truncated IP address, device and browser type, referring site
- Why
- To understand which pages are useful and how people find the site
- Lawful basis
- Our legitimate interest in maintaining and improving the site
- How long
- Aggregated and retained by Google Analytics for 14 months
The free first stages of the apps (Gauge in the IIE, Explore in the SIE) need a free account, and what you enter is saved to it, as described above for the apps, so that it carries on if you subscribe.
Who else sees your data
We use a small number of service providers who process data on our behalf. They may only use it to provide their service to us.
Google Firebase (Hosting, Authentication and Cloud Firestore)
- Role
- Website hosting, sign-in for the IIE and SIE apps, and storage of contact-form messages and your saved progress
- Location
- South Africa (Johannesburg) for stored data, and other countries where Google operates for hosting and sign-in
Receives what you submit through the contact form, your name, email address, sign-in details and the work you save in the apps, plus standard server request logs.
Google Analytics
- Role
- Website usage statistics
- Location
- United States and other countries
IP addresses are truncated before storage. No form content is sent to Google.
We do not sell personal data, and we do not share it with advertisers. We may disclose data where the law requires it, or to establish or defend a legal claim.
Fonts on this site are served from our own domain rather than a font network, so loading a page does not tell a third party that you visited.
Where your data goes
Our hosting and analytics providers store data outside Kenya, including in the United States. Where personal data is transferred out of Kenya, we rely on the provider's contractual commitments to protect it to a standard comparable with the Data Protection Act 2019, and we transfer only what the service needs to function.
How long we keep it
Retention periods are listed against each type of data above. In short: we keep inquiry correspondence while a conversation is live and for a period afterwards, app accounts until you delete them, and analytics in aggregate form only.
You can ask us to delete your data earlier than the stated period, and we will do so unless we are required to keep it. If you have an account in the IIE or SIE app, you can delete it yourself from the account menu, which removes your saved work in both apps immediately.
Your rights
Under the Data Protection Act 2019 you have the right:
- To be informed. To know how your personal data is being used, which is what this notice is for.
- To access. To ask for a copy of the personal data we hold about you.
- To correction. To have inaccurate or incomplete data corrected.
- To deletion. To ask us to delete data where we no longer have a reason to keep it.
- To object. To object to processing, including for direct marketing.
- To portability. To receive data you gave us in a structured, commonly used format.
- To withdraw consent. Where we rely on consent, to withdraw it at any time, without affecting processing already carried out.
To exercise any of these, email info@monvalen.co.ke. We will respond as soon as we reasonably can and in any event within the period the Act allows. We may ask you to confirm your identity first, so that we do not disclose your data to someone else.
How we protect your data
This site is served over HTTPS, so what you submit is encrypted in transit. Form submissions and app data are stored in our database behind access-controlled accounts, and access is limited to people who need it.
No system is perfectly secure. If a breach occurs that is likely to result in a real risk to your rights and freedoms, we will notify the Data Commissioner and, where required, you.
Children
This website and the services described on it are aimed at organizations and adults. We do not knowingly collect personal data from children. If you believe a child has given us personal data, contact us and we will delete it.
Changes to this notice
We update this notice when what we do with data changes. The effective date at the top of the page tells you when it last changed. If a change materially affects how we use data you have already given us, we will tell you directly where we can.
Complaints
If you are unhappy with how we have handled your personal data, please tell us first at info@monvalen.co.ke so we can try to put it right.
You also have the right to complain to the Office of the Data Protection Commissioner, the supervisory authority for data protection in Kenya.
Questions about this page can be sent to info@monvalen.co.ke.