Introduction

Chase Springs Limited (“Chase Springs”, “we”, “us”, or “our”) is committed to protecting the privacy and confidentiality of all personal information entrusted to us.

This privacy policy governs your use of our service, and explains how we collect, process, safeguard and disclose information about you.

We will only process information where you have given us the information directly as a data controller or by our partners where we are processors in accordance with their instructions and in line with our obligations and your rights under the Data Protection Act, 2012 (Act 843) and other Jurisdictional Data Protection laws that are applicable.

The information we collect and when

We only collect personal information that is necessary, relevant, and not excessive for the purpose of our processing. The type of personal information that we may collect and process about you when you interact with us includes the following:

• Contact details (name, email, phone number, address)
• Company and role details (for business inquiries)
• Technical information (IP address, browser type, usage data)
• Communications and inquiries submitted via our website
• Subscription details for newsletters or service updates

You are under no obligation to provide us with your personal information; however, certain basic information may be required for us to be able to provide you with the service or request made by you. Where this is the case, we will advise you at the point of obtaining the information.

How do we obtain your personal data?

We collect personal information directly from you when you complete the Insurance Proposal forms or engage with us through various channels. Where we collect your personal information indirectly from you, we will contact and inform you of where we obtained the information from. The following are the various ways we collect information from you.

• When you submit a contact or service request form
• When you subscribe to newsletters or updates
• When you communicate with us by email, phone, or other channels
• When you use or browse our website (via cookies and analytics)
• When you contact us to make an inquiry or request information through our website
• When you contact us through our communication channels (WhatsApp, email).
• When you apply for a job with us

Purpose of processing

The purposes for which we process your personal data include one or more of the following;

• To provide you with information that you have requested relevant to a service or product in which you have exhibited an interest.
• To fulfill a contract that we have entered into with you or with the entity you represent. In these circumstances, it may be your entity, rather than yourself, that has provided us with your personal data for us to fulfill the contract.
• To ensure the security safeguard of your data and underlying business infrastructure.
• To manage any communication between you and us. 
• To respond to inquiries and manage client relationships
• To send service updates, industry insights, and marketing (with your consent)
• To comply with legal and regulatory requirements

Lawful Basis for Processing

We will only process your personal data for the specific purpose that we state at the point of collection and when the law allows or requires us to do so. Most commonly, we will use your personal data in the following circumstances:

• For the purpose of performing a contract that we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests and if your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or statutory obligation.
• Where you grant us consent.

Below is a description of the ways we may use your personal data, and the legal basis upon which we may do so. We have also identified what our legitimate interests are, where appropriate.

Disclosure of your personal information

We may need to disclose your personal information in order to deliver the IT services and consulting products or services requested by you or your employer, or only when the following circumstances apply;

• Where the law or a statutory duty requires us to do so
• Our internal team members who need the information in the course of their roles to administer a contract or service we are providing to you
• If we need to share personal data to establish, exercise, or defend our legal rights (this includes providing personal data to others to prevent fraud)
• If required to disclose your personal information by law or in response to valid requests by public authorities (law enforcement agencies, fraud and crime prevention and detection agencies and certain regulatory bodies).
• Share with recipients, including employees, only for the purposes of administering services to you or responding to your request. This will only be shared on a strictly need-to-know basis. 
• With third parties that we have either contracted to perform services for us and will ensure that we put the necessary security and third-party contracts and agreements in place.
• If we or our parent company is involved in a merger, acquisition or asset sale, your Personal Data may be transferred.

If you require details of the third parties your data has been shared with and how this information is used please contact the Data Protection Supervisor email: hello@chasesprings.com or Hotlines: +233 507209271

Security safeguards

We have implemented commercially reasonable physical, administrative, and technical safeguards in an effort to protect your personal information from unauthorized access, use, alteration and deletion. These safeguards may vary depending on the sensitivity, format, location, amount, distribution and storage of the personal information, and include measures designed to keep personal information protected from unauthorized access. However, as effective as our security measures are, no security system is impenetrable. We cannot guarantee the security of our systems, nor can we guarantee that information you supply will not be intercepted while being transmitted to us.

Personal information retention

We will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Personal information transfer

Your personal information, may be transferred to, and maintained on computers located outside of your country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

We will take all the steps reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Policy and no transfer of your personal information will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Your Rights as a data subject

The Data Protection Act, 2012 (Act 843) provides some basic rights to data subjects. These are

Right to be informed

You have the right to be informed about the processing of your personal information that we perform. This privacy notice is a way of ensuring we meet our obligations to enable you exercise your right to be informed.

Right to Access Your Personal Information

You have the right to access the personal information that we hold about you. This is sometimes termed a ‘Data Subject Access Request’. We will ask for proof of identity and sufficient information about your interactions with us so that we can locate your personal information when you make such a request. If you want to exercise this right, please contact us at as set out below.

Right to rectification, object, erasure, and destruction

Where information we hold about you is inaccurate, incomplete, or out of date, you may ask us to correct or update it. You also have the right to restrict us from further processing of your personal data where we do not have any legitimate or legal basis for processing your personal data. In certain circumstances, you may also instruct us to delete your personal data. The right of erasure or destruction is not absolute and only applies in certain cases. If you would like to exercise this right, please get in touch with us as set out below.

Right to prevent processing 

Under this right, you can give us notice in writing to cease or not to start processing your personal data for a specific purpose or manner which will cause or is likely to cause any unwarranted damage or distress. You can also prevent us from processing your information for direct marketing purposes. 

Right in relation to automated decision taking

Under this right, you can at any time by notice in writing to us require us to ensure that any decision taken by or on behalf of our organization which significantly affects you is not based solely on the processing by automatic means.

Right to prevent processing of personal data for direct marketing

You are entitled at any time by notice in writing require us not to process your personal data for the purposes of direct marketing.

Right to complain and compensation

As with all the other rights above, you may write to complain if you believe any of your rights have not been met or we fail to meet our obligations as a data controller.

Right to give and withdraw consent

Where we rely on your consent to process your personal data, you have the right to withdraw it at any time by contacting us or using any details provided in our communication with you. 

Notice to Exercise Rights

You can at any time give notice in writing to us to exercise your rights. We will within twenty-one (21) days after receipt of a notice and confirmation of your identity, inform you in writing that we have complied or intend to comply with your notice or the reasons if we cannot comply with the request. If you would like to exercise this right, please contact the Data Protection Supervisor email: hello@chasesprings.com or Hotlines: 0507209271

Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes or if we change our business in a way that affects personal data protection. Any changes we make will be published and indicated by version number.