Privacy Policy

1. Who We Are

This website is operated by ARES CP SOLUTIONS LTD, a company established and operates in Kenya. This Privacy Policy is primarily based on the Kenya Data Protection Act, 2019 and applicable Kenyan data protection regulations.

Our website and courses may be accessed by individuals in other jurisdictions. Where the laws of another jurisdiction apply to our processing of your personal data, we will comply with the requirements applicable to us in that jurisdiction.

2. Who This Policy Applies To

This Privacy Policy applies to individuals who:

• visit our website;
• submit an enquiry;
• subscribe to our newsletters or communications;
• express an interest in one of our courses;
• register for or participate in our courses or related services; or
• otherwise provide personal data to us in connection with our business.

3. Personal Data We Collect

The personal data we collect depends on how you interact with us.

3.1 Website Enquiries

If you submit an enquiry, we may collect:

• your name;
• email address;
• telephone number; and
• the contents of your enquiry and any other information you choose to provide.

3.2 Newsletter and Course-Interest Sign-ups

If you subscribe to our communications or express an interest in a course, we may collect:

• your name;
• email address; and
• the course or courses in which you have expressed an interest.

Where required by applicable law, we will obtain your consent before sending marketing communications.

4. Information Collected Automatically

We do not currently use Google Analytics or similar analytics services, advertising pixels, behavioural tracking tools or other technologies for advertising or behavioural tracking.

Our website hosting and technical service providers may nevertheless automatically process limited technical information necessary to operate, maintain and secure the website. This may include information such as:

• IP address;
• browser type;
• device information;
• operating system; and
• basic server logs.

This information may be used for security, troubleshooting, website administration and other legitimate operational purposes.

5. Cookies and Tracking

We do not currently use cookies for analytics, advertising or behavioural tracking.

If we introduce non-essential cookies or similar technologies in the future, we will update this Privacy Policy and, where required by applicable law, provide an appropriate consent mechanism before such technologies are used.

6. How We Use Personal Data

We may use personal data for the following purposes:

• responding to enquiries;
• providing information about our courses and services;
• communicating with you about our courses and services;
• sending newsletters or course-related communications where you have chosen to receive them;
• administering and improving our website and services;
• maintaining business and customer records;
• maintaining the security of our website and services;
• preventing or detecting fraud, misuse or unlawful activity;
• establishing, exercising or defending legal claims; and
• complying with applicable legal and regulatory obligations.

We will not use your personal data for purposes incompatible with the purposes for which it was collected unless permitted or required by applicable law.

7. Consent and Other Grounds for Processing

Where we rely on your consent to process personal data, we will obtain that consent in an appropriate manner.

For example, where you choose to subscribe to newsletters or course-related communications, you may be asked to provide your consent through an opt-in checkbox.

You may withdraw your consent at any time by contacting us at info@aresafrica.com or, where applicable, by using the unsubscribe facility included in our communications.

Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal. It also does not prevent us from continuing to process personal data where another lawful basis or legal obligation permits or requires us to do so.

We may also process personal data where necessary for purposes permitted under applicable law, including where processing is necessary to respond to an enquiry, provide requested services, comply with a legal obligation, protect our legitimate interests or establish, exercise or defend legal claims.

Where another jurisdiction requires us to identify specific lawful bases for processing, we will apply the requirements of that jurisdiction where applicable.

8. Who We Share Personal Data With

We do not sell your personal data.

We may share personal data where reasonably necessary to operate our website, respond to enquiries, provide our services or comply with legal obligations.

This may include sharing information with:

• website and hosting providers;
• form and email delivery providers;
• email and communications service providers;
• administrative and marketing support providers;
• professional advisers;
• regulators, courts or law enforcement authorities where required or permitted by law; and
• other service providers who process personal data on our behalf.

Web3Forms

We use Web3Forms, a third-party form and email delivery service, to receive and forward enquiries and newsletter or course sign-up submissions made through our website.

Web3Forms processes personal data submitted through these forms on our behalf for the purposes of facilitating website communications and related services.

Enquiry and course-related information may be accessed by Nina Sperl Digital Marketing in an administrative or support capacity where necessary to assist Ares Africa with communications and related business activities.

We take reasonable steps to ensure that third-party service providers that process personal data on our behalf handle that information appropriately and in accordance with applicable data protection requirements.

Third-Party Platforms and Course Delivery

Where our courses are delivered online, we may use third-party platforms such as Zoom, Microsoft Teams, Google Meet or similar services to facilitate teaching, communication and course delivery. These platforms may process personal data such as your name, email address and participation details in accordance with their own privacy policies and terms.

Where required, we will take reasonable steps to ensure that such processing complies with applicable data protection requirements, including requirements relating to international transfers of personal data.

Where online classes are recorded, participants will be informed before recording begins and, where required by applicable law, appropriate consent will be obtained.

Payments

Payments for our courses may be made through third-party payment providers, including payment methods such as Visa, M-Pesa or other payment services made available by us from time to time.

Where you make a payment through a third-party provider, that provider may process your payment and related personal information in accordance with its own terms and privacy policy. Ares Africa may receive information necessary to confirm and administer your payment but does not necessarily collect or store your full payment card details.

Where payment processing involves the transfer or processing of personal data outside Kenya, we will take appropriate measures to comply with applicable data protection requirements.

9. International Data Transfers

Ares Africa is established and operates in Kenya, and personal data may be processed in Kenya.

Because our website and courses may be accessed by individuals in other countries, personal data may also be processed or transferred outside the country from which you access our website.

Where applicable law requires additional safeguards for an international transfer of personal data, Ares Africa will take appropriate steps to comply with those requirements.

The fact that our website is accessible internationally does not, by itself, mean that the data protection laws of every jurisdiction apply to Ares Africa.

Where Ares Africa actively offers its services to individuals in a jurisdiction whose data protection laws apply to that activity, we will assess and comply with the requirements applicable to us.

Where the GDPR applies to Ares Africa’s processing of personal data, Ares Africa will comply with the GDPR requirements applicable to that processing.

Website Hosting

Our website is hosted by third-party service providers. Depending on the location of the relevant servers and service providers, personal data submitted through the website may be stored or processed in Kenya or in other countries. We take reasonable steps to ensure that service providers who process personal data on our behalf maintain appropriate safeguards and process such data in accordance with applicable data protection requirements.

10. Data Security

We take reasonable technical and organisational measures to protect personal data against unauthorised access, loss, misuse, alteration or disclosure. These measures may include appropriate access controls, secure transmission of information, protection of systems and accounts used to process personal data, regular updates and security measures for our website and service providers, and appropriate procedures for responding to suspected or actual data security incidents.

Access to personal data is limited to authorised persons who require the information for legitimate business or service-related purposes. Where we use third-party service providers to process personal data on our behalf, we take reasonable steps to ensure that they maintain appropriate safeguards for the personal data they process.

11. Data Retention

Except as otherwise mentioned in this policy, we keep your personal data only for as long as required by us:

• to provide you with the services you have requested;
• to comply with other law, including for the period demanded by our tax authorities; and
• to support a claim or defence in court.

12. Your Data Protection Rights

Subject to applicable law, you may have rights in relation to your personal data, including the right to:

• request access to personal data we hold about you;
• request correction of inaccurate or incomplete personal data;
• request deletion of personal data where applicable;
• object to or request restriction of certain processing;
• request portability of your personal data where applicable;
• withdraw consent where processing is based on consent; and
• lodge a complaint with the relevant data protection authority.

Additional rights may apply depending on the law applicable to you.

To exercise your rights, please contact us at info@aresafrica.com.

We may need to verify your identity before responding to a request relating to personal data.

13. Children’s Privacy

Our website and courses are not specifically directed at children.

We do not knowingly collect personal data from children in circumstances where such collection is prohibited by applicable law.

14. Third-Party Websites and Services

Our website may contain links to third-party websites or services.

We are not responsible for the privacy practices, security or content of third-party websites or services.

We encourage you to review the privacy policies of any third-party website or service you visit.

15. Complaints

If you have concerns about how we have handled your personal data, please contact us first at info@aresafrica.com.

We will consider and respond to your complaint in accordance with applicable law.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our business, services, website functionality, technology, service providers or applicable legal requirements.

Any changes will be published on this page. Where appropriate, we may also notify you of material changes through the contact details we hold for you.

The “Last updated” date at the beginning of this Privacy Policy indicates when the policy was most recently revised.