Privacy policy

 

Ivy Grey Ltd trading as IvyGrey

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This policy explains how Ivy Grey Ltd, trading as IvyGrey, handles personal information when you visit www.ivygrey.africa, make an enquiry or communicate with us about our services. It also explains how to contact us about your information. We are based in Nairobi, Kenya.

 

1 Who is responsible

Ivy Grey Ltd is responsible for deciding how information collected for our own website and business enquiries is used. For privacy questions or requests, contact hello@ivygrey.africa, telephone +254 722 542 935, or write to P.O. Box 5257–00100, Nairobi, Kenya.

When we handle personal information solely on a client’s instructions during an engagement, the client may be the data controller and IvyGrey the processor. The client’s notice and our written processing arrangement govern that work. We will explain the appropriate contact if a request concerns information controlled by a client.

 

2 Information you provide

We collect the information you choose to send through our forms, email, phone or WhatsApp. This may include your name, business name, email address, telephone number, website or social-media address, preferred contact method, meeting preferences and the details of your enquiry. We also keep relevant correspondence and notes needed to handle the enquiry.

Fields marked as required are needed to process the particular request. Providing information is voluntary, but we may be unable to respond or arrange the requested contact without the necessary details. Optional fields can be left blank. Please avoid including sensitive personal information, identity documents, passwords or information about other people unless necessary and lawfully shared.

 

3 Information collected through the website

Wix hosts our website and provides form and contact-management functions. When you visit, technical information may be processed, including your IP address, device and browser information, pages requested, time of access and security or error records. Some information is needed to operate and protect the website.

Where you permit analytics, Wix Analytics helps us understand visits, referral sources and how people use the site. This can involve online identifiers and information about page activity. Cookie preferences affect the information collected. We do not need the contents of your enquiry to measure website traffic.

 

4 Why we use information

We use enquiry and communication details to respond, arrange meetings, assess whether our services fit your needs and prepare requested proposals. The relevant basis is taking steps at your request before a contract, performing a contract, or our legitimate interest in communicating with business representatives, as appropriate.

We also use necessary records to administer our business, protect systems, prevent misuse, resolve disputes and meet legal obligations. Where we rely on legitimate interests, we consider the purpose, necessity and effect on your rights. Optional analytics relies on your permission where required. Any marketing subscription requires a separate choice; an enquiry is not permission to add you to a marketing list.

Cookies recipients and retention

 

5 Cookies and your choices

Cookies and similar technologies support website functions and, with the relevant permission, analytics. Necessary technologies help deliver and protect the site. Optional categories are explained in the cookie controls, where you can accept, reject or change your preferences. Refusing optional analytics does not prevent you from making an enquiry.

You can also manage cookies through your browser, although blocking necessary cookies may affect site functions. Changing a preference applies going forward and does not undo information already lawfully processed. The cookie controls provide the current details of the technologies detected on the site. We update this policy when our use changes materially.

 

6 Who receives information

Access is limited to people and providers who need the information for the relevant purpose. These may include IvyGrey personnel and authorised specialists handling your enquiry, Wix for website hosting and form/contact management, our email and communications providers, and professional advisers where needed. We require service providers processing information on our behalf to handle it under appropriate instructions and protections.

If you contact us through WhatsApp, that service also processes information under its own privacy terms. Social-media and other external links take you to services with their own practices. We may disclose information when required by law or where lawfully necessary to establish, exercise or defend legal claims. We do not sell your personal information.

 

7 Processing outside Kenya

Cloud and communications providers may process information outside Kenya. Wix operates internationally and uses providers in multiple locations. The countries involved depend on the service and its arrangements.

Where a transfer is involved, we assess the applicable requirements under Kenyan law and use an appropriate lawful transfer basis and safeguards. These may include contractual protections and checks on the recipient’s security and data-protection arrangements. Contact us for information about the safeguards relevant to your data. Use of this website is not blanket consent to unrestricted international transfers.

 

8 How long we keep information

We keep personal information for as long as necessary for the purpose for which it was collected, taking account of legal obligations and legitimate record-keeping needs.

For enquiries that do not become engagements, we consider whether discussions are active, whether you have asked us to contact you later, and whether there is a documented reason to retain the correspondence. Client and transaction records may need to be retained for applicable tax, accounting or legal periods. Security records are retained according to their operational purpose. Cookie and analytics retention follows the settings and periods described in the relevant controls and service configuration.

When information is no longer required, we delete or anonymise it, subject to lawful preservation requirements and backup cycles. Creative-file delivery and storage arrangements are addressed separately in the client agreement; they are not a universal retention period for all personal information.

Security and your rights

 

9 Protecting information

We use reasonable technical and organisational measures appropriate to the information and the risks involved. These include limiting access to authorised people, protecting account access, using secure transfer methods where appropriate, and reviewing how information is stored and shared. No online service can guarantee complete security. If an incident affects personal information, we assess it and make any notifications required by applicable law.

 

10 Your choices and rights

Subject to the conditions and exceptions in applicable law, you may ask us to explain how your information is used, provide access, correct inaccurate information, delete information, restrict processing or provide data in a portable form. You may object to processing where the law allows and withdraw consent where we rely on it. Withdrawal does not affect the lawfulness of processing before withdrawal.

To make a request, email hello@ivygrey.africa and describe what you need. We may ask for proportionate information to confirm your identity or authority and locate the relevant records. Do not send identity documents unless we explain why they are needed and how to send them securely. We respond within the time required by applicable law and explain any lawful reason why a request cannot be met in full.

If you have separately subscribed to marketing, you can opt out through the message’s unsubscribe method or by contacting us. We may retain the minimum information needed to respect your preference.

 

11 Children

Our business enquiry service is intended for adults acting for themselves or an organisation. We do not intentionally seek children’s personal information through it. If you believe a child has supplied information without appropriate authority, contact us so we can assess and address it. Photography, education or other commissioned work involving children requires separate arrangements and the necessary permissions and protections.

 

12 Concerns and complaints

Please contact us if you have a concern about your personal information. You also have the right to raise a complaint with Kenya’s Office of the Data Protection Commissioner. Information about the complaint process is available at www.odpc.go.ke. You do not have to wait for our internal response before exercising a legal right to complain. Where another jurisdiction’s data-protection law applies, you may also have rights to approach its supervisory authority.

 

13 Changes to this policy

We review this policy when our services or information practices change. The latest version will appear on our website with its date. If a change requires a fresh notice or consent, we will take the steps required by applicable law.