August 01, 2008

Privacy Policy of Genius Executive Centre

Information about our organization and websites

SoftLaw Limited and its Genius Executive Centre (“GEC”) respect your privacy and are committed to protecting it. We are providing this Privacy Policy to inform you of our Privacy Policy and practices and of the choices you can make about the way your information is collected online and how that information is used. We hope that this will remove any concerns you may have about supplying information to us and make visiting GEC websites a rewarding experience. By accessing and browsing this website, you are accepting the practices described in this Privacy Policy. Please read this Privacy Policy carefully and revisit this page from time to time to review any changes that may have been made.

Providing visitors with anonymous access
Initially, please note that you can access our websites home pages and browse each of our sites without disclosing your personal data. Also, our websites do not enable our visitors to communicate with other visitors or to post information to be accessed by other visitors to our website.

Sites covered by this Privacy Policy

This Privacy Policy applies to all GEC owned websites and domains. The GEC Websites may provide links to third-party websites for your convenience and information. If you access those links, you will leave the GEC Websites. We do not control those sites or their privacy practices, which may differ from our own privacy practices. This Privacy Policy does not cover any personal data that you choose to give to unrelated third parties. You acknowledge that we do not monitor or control the information collected by such sites or the privacy practices of any third parties, and we are not responsible for their practices or the content of their sites.

Types of information we collect

When browsing any of the GEC Websites, you are not required to provide any personal information. If you choose to register with the GEC Websites, then you will be requested to provide contact information (name, address, telephone number, email address, a unique login name, password). We use this information to contact you about the services on our site in which you have expressed interest. We may also use your contact information to send you information about other GEC products and services as well as promotional material that may be of interest to you from some of our marketing partners.

You also have the option to provide demographic information (such as type of business,
size of business, locations, etc.). GEC uses this demographic information to understand your needs and interests and to provide you a more personalized experience on our site. The information is used by GEC to process your orders, enable participation in promotions, and facilitate your relationship with us. Through the GEC Websites, you can order products or services, request information, or subscribe to marketing or support materials. In order to purchase a
product or service from us, we will request certain personally identifiable information from you. You will need to provide contact information (such as name, email and address) and financial information (such as MPESA account ). Financial information collected from you is used only to bill you for the products and services that you have purchased.

Communications from the GEC Website
Once you register, we will send you a welcoming email to verify your username and password. We will also respond to your inquiries, provide services you request and manage your account. We will communicate with you by email or telephone and will make every effort to honor your preference.
We will occasionally send you information on new products, services, special savings, promotions and general information.

If you wish to subscribe to our newsletters, we will use your name and email address to send the newsletter to you. You can sign up for these newsletters from us on our registration page.

When necessary, GEC will send you strictly service-related announcements, which are not promotional in nature.

By providing your personal data to the GEC Websites, you are acknowledging and agreeing that any of your personal data the GEC may be transferred across country borders for the purposes of data consolidation, storage, simplified customer information management, reporting and other
internal uses. GEC may process, disclose or transfer such personal data and in doing so, such personal data may be transferred across country borders. In addition, such personal data may be transmitted to other affiliates within the GEC.

Non-personal data is aggregated for reporting about the GEC Websites usability, performance and effectiveness. It is used to improve the customer experience, usability and site content. Pages and content may be changed based on feedback from visitors.

Credit card information is used only for payment processing and fraud prevention. Credit
card information and sensitive personal data are not used for any other purpose by GEC and will not be kept longer than necessary for providing the services, unless you ask us to retain your credit card information for future purchases.

Please note that we do not provide your email address to our business partners. However, we may send you offers on behalf of our business partners.

In the event that GEC is sold or acquired, customer information will be one of the assets transferred. In addition, we reserve the right to disclose information submitted by or concerning any user of this GEC Websites as required by law or when we reasonably believe that such disclosure is necessary to protect our systems, our business or the rights of others.

Sharing of information
GEC contracts with third-party service providers and suppliers to deliver complete products, services and customer solutions described above. These service providers may change or we may contract with additional service providers to better accommodate our customers. GEC will not share personal information with any other third parties without your permission, unless required by law enforcement action, subpoena, local law or when we reasonably believe that such disclosure is necessary to protect our systems, our business or the rights of others or as otherwise provided in this Privacy Policy.

How we collect information
The GEC Website collects data through a variety of different ways. For instance, we automatically log data by means of programming and we may link certain information as well. We also collect data through forms that allow users to request information about GEC and its services. GEC Websites may collect non-personal technical information about your session (such as browser type, Internet service provider, platform type, internet protocol (IP) addresses, referring/exit pages, operating system, date/time stamp). We use this information, which does not identify individual users, to analyze trends, diagnose problems with our server and administer the GEC Website, to track user movement and use, and to gather broad demographic information. One way we gather this information is through the use of cookies; we use cookies to store personal data and link information. Cookies are small computer files stored on your computer’s hard drive that save and retrieve information about your visit to the GEC Website. If you are uncomfortable regarding the use of cookies, you may disable cookies on your computer by changing the settings in the preferences or options menu in your browser. However, if you choose to disable cookies, you may not be able to access certain areas of the GEC Website.

Children’s privacy
GEC is committed to protecting the privacy needs of children and we encourage parents and guardians to take an active role in their children’s online activities and interests. GEC does not knowingly collect information from children under the age of 13 and GEC does not target its websites to children under 13.

Your choices and opting-out
GEC gives you the choice of receiving a variety of information that complements our products and services. You can subscribe to receive certain product- and servicespecific information and GEC-wide marketing communications. GECwide communications may include new product information, special offers, or an invitation to participate in market research. GEC provides you the opportunity to “opt-out” of having your personally identifiable information used for certain purposes when we ask for this information. For example, if you purchase a product from us but do not wish to receive any additional marketing material from us, you can indicate your preference. If you no longer wish to receive [our newsletters and/or] promotional communications, you may opt-out of receiving them by following the instructions included in each newsletter or communications or by emailing us at geniuscentre@softlaw.co.ke.

Access to and accuracy of your information
We will provide you with access to your information, including making reasonable effort to provide you with online access and the opportunity to change your information. To protect your privacy and security, we will also take reasonable steps to verify your identity, such as a password and user ID, before granting access to your data. We reserve the right to refuse to provide our visitors with a copy of their personal data, but will give reasons for our refusal.

Keeping your information secure
The security of your personal information is important to us; however, no security system is guaranteed to be 100% secure. While we strive to protect your personal information, GEC cannot guarantee or warrant the security of our servers nor can we guarantee that information you supply through the GEC Website will not be intercepted while being transmitted over the Internet. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.

Business transitions

In the event that GEC goes through a business transition, such as a merger, acquisition by another company or sale of all or a portion of its assets, your personally identifiable information will likely be among the assets transferred.

Changes to this Policy
If there are updates to the terms of this Privacy Policy, we will post those changes and update the revision date in this document, so you will always know what information we collect online, how we use it, and what choices you have. By continuing to use this GEC Websites after any changes are posted, you acknowledge your acceptance of such changes.

Terms and Conditions
If you choose to visit our GEC Websites, your visit and any dispute over privacy is subject to this Privacy Policy and our Terms and Conditions, including, but not limited to, disclaimers of warranty, limitations of liability, arbitration of disputes and application of the law of the Republic of Kenya.

Contacting us

We value your opinions. If you have comments or questions about this Privacy Policy,
please send them to geniuscentre@softlaw.co.ke