Privacy Policy

1. Introduction
1.1 Overview

Cestol (“Cestol,” the “Company,” “we” or “us”) is sensitive to privacy issues. As such, it is important to us to protect the information provided to us by our clients, customers, visitors and guests. It is for this reason that Cestol provides this privacy and information practices policy to inform you about our online information practices, the kinds of information we may collect, how we intend to use and share that information, and how you can correct or change such information (“Privacy Policy”). By using the Cestol Platform, you expressly consent to the information handling practices described in this notice.

1.2 Scope

This Privacy Policy applies to Personal Information that is Processed by Cestol in the course of our business, including on the Cestol Platform (together with any and all future websites operated by or on behalf of Cestol, the “Websites”). All individuals whose responsibilities include the Processing of Personal Information on behalf of Cestol are expected to protect that data by adherence to this Privacy Policy. This Privacy Policy is intended to meet requirements globally, including those in Kenya, Africa, and other jurisdictions.

This Privacy Policy is incorporated into and is subject to the Cestol Platform Terms of Use. Your use of the Cestol Platform and any Personal Information you provide through the Cestol Platform are subject at all times to this Privacy Policy and the Terms of Use. Terms for “Cestol” and the “Cestol Platform” apply to any site or mobile application owned and operated by Cestol, including cestol.com and the Cestol mobile application.

2. Personal Information Collection

To help us serve you better, Cestol may collect Personal Information about you. The type of Personal Information we may collect (directly from you or from Third-Party Sources) and our privacy practices depend on the nature of the relationship you have with Cestol and the requirements of applicable law. We endeavor to collect information only relevant for the purposes of Processing. The legal bases and some of the ways we collect information and how we use it are as explained here-under.

2.1 Individuals

Cestol collects Personal Information regarding its current, prospective and former clients, customers, visitors and guests (collectively “Individuals”).

2.2 Information Collected

The data we collect from Individuals includes information that may be deemed Personal Information, such as title, name, address, phone number, email address, user name, Internet Protocol address, and credit card and other financial information related to payments for services or goods. We may also collect other information that is not Personal Information, such as demographic information you choose to provide (e.g., your business or company information, professional experiences, educational background, nationality, ethnic origin, gender, interests, preferences and favorites) and answers to a security question and password.

2.3 How Information is Collected

Some of the ways that Cestol may collect your Personal Information include:

i. Through interactive channels, including the Websites, in surveys, during business or marketing events, and when delivering programs and services to you.

ii. When you use the Websites, Cestol may provide you with opportunities to sign up to receive specific information or services and may ask for your contact information (e.g. name, e-mail address or personal email address), so that we can send you specific information about our products, services and specific health conditions, with your consent.

iii. As you navigate the Websites, certain passive information may also be collected, including Internet Protocol addresses, cookies, navigational data, the name of the domain and host from which you access the Internet, the browser software you use and your operating system, the date and time you access our Websites, and the Internet address of the website from which you linked directly to our Websites. This type of information is used for the purposes of gathering data to provide improved administration of our Websites, and to improve the quality of your experience when interacting with our Websites.

2.4 Information from Third-Party Sources

We may collect information about you from third-party sources to supplement information provided by you. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you information about our business, products and services.

We may also offer you the ability to use Third-Party services to enable additional features on Cestol. If you choose to do this, Cestol may receive information about you from these Third-Parties.

2.5 Research & Survey Solicitations

From time to time, Cestol may perform research (online and/or offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf.  All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide.

The survey responses may be utilized to determine the effectiveness of our Websites, various types of communications, advertising campaigns and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous individual and aggregate data for research and analysis purposes.

2.6 How Your Personal Information is Used

Depending on how you interact with Cestol, we and our Third-Party service providers may also use your Personal Information in a variety of ways, including:

i. Providing Information and Services You Requested. Cestol may use the Personal Information about you to provide you information that you may request, e.g. information about a product or program we are offering. Cestol may also use your Personal Information to deliver a specific program or service to you, when you enroll to receive the program or service. Such use may include: (i) generally managing your information and accounts; (ii) responding to questions, comments and requests; (iii) providing access to certain areas and features of the Cestol Websites; and (iv) permitting you to register for events or participate in webinars.

ii. Administrative Purposes. Cestol may use the Personal Information about you for its administrative purposes, including, without limitation, to: (i) measure your interest in Cestol’s Websites, programs or services; (ii) perform internal quality control; (iii) verify identity; (iv) send communications regarding the Cestol Websites, programs or services, your account, or any changes to any Cestol policy or terms of service; (v) process payments; (vi) prevent potentially prohibited or illegal activities; and (vii) enforce our Terms of Use.

iii. Marketing Products and Services. Cestol may use the Personal Information about you to provide you with materials about offers, products and services offered by us, including new content or services on Cestol Websites. Cestol may provide you with these materials by phone, postal mail, or email, as permitted by applicable law. If you do not wish us to use your Personal Information for marketing purposes, you may contact us at any time to opt out of the use of your Personal Information for such purposes, as further described below.

iv. Research and Development. Cestol may use your Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and services or develop new products, processes and services.

v. Information Submitted Via Websites. You agree that Cestol is free to use the content of any communications or other information submitted by you via the Websites, including any narratives, images, ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or services. However, Cestol does not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (i) you grant us permission to do so; (ii) we first send notice to you that the materials or other information you submit to a particular part of a site will be published or otherwise used with your name on it; or (iii) we are required to do so by law.

vi. Sharing Content with Friends or Colleagues. Cestol’s Websites may offer various tools and functionalities. For instance, Cestol may provide functionality on its Websites that will allow you to forward or share certain content with a friend or colleague. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by Cestol or any other Third-Parties for any other purpose.

vii. Pseudonymous Data. Including as discussed below in Section 2.10, Cestol may use and share your anonymized or aggregated information within the Cestol Websites or with Third-Parties for, research, analytics and any other legally permissible purposes.

viii. Other Uses. Cestol may use Personal Information for other purposes for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.

2.7 Direct Mail, Email and Outbound Telemarketing

Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third-Parties, may receive periodic emails, newsletters, mailings or phone calls from us with information on Cestol or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the individual by following the instructions in Section 3 below.

2.8 Social Media

Online social media resources are interactive tools that enable Data Subjects to collaborate and share information with others. Cestol may collect Personal Information to enable Data Subjects to use online social media resources offered either by Cestol or a Third-Party. We may also enable you to use these social media resources to post or share Personal Information with others. When using social media resources, you should take into careful consideration what Personal Information you share with others.

2.9 Cookies, Pixel Tags, and Analytic Information

We, as well as Third-Parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a "device") that allow us to record certain pieces of information whenever you visit or interact with our sites, services, applications, messaging, and tools, and to recognize you across devices.

i. Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly. To learn more about how Cestol uses cookies, go to our Cookie Policy.

ii. Pixel Tags. A pixel tag (also known as a web beacon) is a piece of code embedded on the Websites that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.

iii. Analytic Information. We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.

2.10 Anonymous and Aggregated Information

Cestol may use your Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access the Cestol Websites or other online services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Websites.

Anonymized or aggregated information is not Personal Information, and Cestol may use such information in a number of ways, including research, internal analysis, analytics and any other legally permissible purposes. We may share this information within Cestol and with Third-Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.

3. Your Personal Data Rights

Cestol gives you the right to opt out of certain uses and disclosures of your Personal Information, as set out in this Privacy Policy.

3.1 General

Where you have consented to Cestol’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt out by following the instructions in this Section. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will provide information regarding the new purpose and give you the opportunity to opt-out.

3.2 Email and Telephone Communications

An “Unsubscribe” button will be provided at the top or bottom of each email communications sent by Cestol so that you can easily opt-out if you wish to do so. However, we may continue to send transaction-related emails regarding products or services you have requested in response to such request. We may need to send you certain communications regarding the Cestol programs and services and you will not be able to opt out of those communications, including but not limited to, communications regarding updates to our Terms of Use or this Privacy Policy.

Prior to disclosing Sensitive Data to a Third-Party or Processing Sensitive Data for a purpose other than its original purpose or the purpose authorized subsequently by the Data Subject, Cestol will endeavor to obtain each Data Subject’s explicit consent (opt-in). Where consent of the Data Subject for the Processing of Personal Information is otherwise required by law or contract, Cestol will comply with the law or contract.

3.3 “Do Not Track”

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their web page visits collected over time and across websites or online services. Cestol does not recognize or respond to browser-initiated DNT signals. For more information about “do-not-track”, visit http://www.allaboutdnt.org.

3.4 Advertising Choices

We may use certain tools offered by Third-Parties that enable such Third-Party to collect or receive information about actions users take on: (i) our Websites and elsewhere on the internet through use of cookies, pixel tags and other storage technologies; or (ii) a Cestol mobile application and other mobile applications, in order to provide interest-based advertising.

Interest-based advertising is advertising that tries to make the ads you see more interesting and relevant to you based on the types of sites you visit online and other information that does not personally identify you. Advertisements on Third-Party websites that contain the AdChoices link and that link to this Privacy Policy may have been directed to you based on anonymous, non-Personal Information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt-out of the advertising partners’ use of this information for interest-based advertising purposes.

You can opt out of the collection and use of your information for interest-based advertising by going to http://optout.aboutads.info,  http://www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/ to limit collection through the Website or by configuring the settings on your mobile device to limit ad tracking through the mobile applications.

Even if you opt-out, we may still collect and use non-Personal Information regarding your activities on our Websites and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.

4. Personal Information Retention

Cestol retains the Personal Information we receive about you as described in this Privacy Policy for as long as you use our Websites or as necessary to fulfill the purpose(s) for which it was collected, provide our products and services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws.

5. Personal Information Security

The security of all Personal Information provided to Cestol is important to us, and Cestol takes reasonable steps designed to protect your Personal Information. Unfortunately, no data transmission over the Internet or storage of information can be guaranteed to be 100% secure. As a result, while Cestol strives to protect your Personal Information, we cannot ensure or warrant the security of any information you transmit to Cestol, and you do so at your own risk. You are responsible for maintaining the secrecy of your own passwords. If you have reason to believe that your passwords or Personal Information is no longer secure, please promptly notify us at privacy@cestol.com.

6. Compliance And Accountability

If, after reviewing this Privacy Policy, you wish to submit a request or you have any questions or privacy concerns, please feel free to contact us at privacy@cestol.com.

Cestol will address your concerns and strive to resolve any privacy issues in a timely and satisfactory manner.

7. Other Rights And Important Information
7.1 Information Regarding Children

Due to the nature of Cestol’s business, services and benefits are not marketed to persons less than 13 years of age.

If you are under 13 years of age, then please do not use or access the Cestol platform at any time or in any manner.

Protecting the privacy of young children is especially important. For that reason, Cestol does not knowingly collect or maintain personally identifiable information from minors. If Cestol learns that personally-identifiable information of minors has been collected on or through the Cestol platform, then Cestol will take the appropriate steps to delete this information.

If you are the parent or legal guardian of a minor who has become Cestol platform member, then please contact Cestol at privacy@cestol.com to have that minor’s account terminated and information deleted.

7.2 Links to Third-Party Websites

Please note that our Websites may contain links to other websites for your convenience and information. Cestol does not control Third-Party websites or their privacy practices, which may differ from those set out in this Privacy Policy. Cestol does not endorse or make any representations about Third-Party websites.

Any Personal Information you choose to give to unrelated Third-Parties is not covered by this Privacy Policy. Cestol encourages you to review the privacy policy of any company or website before submitting your Personal Information. Some Third-Parties may choose to share their users’ Personal Information with Cestol; that sharing is governed by that company’s privacy policy, not this Privacy Policy.

7.3 Amendments to the Privacy Policy

Cestol may update this Privacy Policy from time to time as it may deem necessary in its sole discretion. If there are any material changes to this Privacy Policy, Cestol will notify you by email or as otherwise required by applicable law. Cestol encourages you to review this Privacy Policy periodically to be informed regarding how Cestol is using and protecting your information and to be aware of any policy changes. Your continued relationship with Cestol after the posting or notice of any amended Privacy Policy shall constitute your agreement to be bound by any such changes. Any changes to this Privacy Policy take effect immediately after being posted or otherwise provided by Cestol.

7.4 Contact Information

Please contact Cestol regarding any questions, clarifications or comments about this Privacy Policy, your Personal Information, and our Third-Party disclosure practices or your consent choices at: cestol.com, or by email: privacy@cestol.com. We will respond to your inquiry within 7 days of its receipt.

Cestol Privacy Policy (Effective: March 10, 2019)

Copyright © 2019 Cestol.com. All Rights Reserved.