Lake Turkana Wind Power Limited (“us”, “we”, “our” “Lake Turkana Wind Power”) operates the www.ltwp.co.ke website (the “Website”). This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Website and the choices you have associated with that data. We use your data to provide and improve the Website. By using the Website, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from www.ltwp.co.ke.

Definitions

Cookies: Means small pieces of data stored on your device (computer or mobile device). 

Comply with a legal obligation: Means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Data Controller Data: Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data. 

Data Processors (or Service Providers):  Means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively. 

Data Subject (or User): Data Subject is any living individual who is using our Website and is the subject of Personal Data.

Legitimate Interest: Means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.

Personal Data or Personal Information: Means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession). 

Usage Data: Data collected automatically either generated by the use of the Website or from the Website infrastructure itself (for example, the duration of a pagevisit). 

Website: Is the www.ltwp.co.ke Website, operated by Lake Turkana Wind Power

Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Website for you.

Types of Data Collected

Personal Data

While using our Website, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

We do not collect any special categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data), nor do we collect any information about criminal convictions and offences.

Usage Data

We may also collect information how the Website is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Location Data

We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Website, to improve and customize our Website. You can enable or disable location services when you use our Website at any time, through your device settings.

Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Website and hold certain information. Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyse our Website. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Website. Examples of Cookies we use:

Use of Data

Lake Turkana Wind Power uses the collected data for various purposes:

Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR).

If you are from the European Economic Area (EEA), the legal basis for Lake Turkana Wind Power collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it. Lake Turkana Wind Power may process your Personal Data because:

Data Retention

Lake Turkana Wind Power will retain your Personal Data only for as long as is reasonably, necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data 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. Lake Turkana Wind Power will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Website, or we are legally obligated to retain this data for longer time periods.

Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. If you are located outside Kenya and choose to provide information to us, please note that we transfer the data, including Personal Data, to Kenya and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. Lake Turkana Wind Power will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data 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.

Disclosure of Data

Business Transaction: If Lake Turkana Wind Power is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy. 

Disclosure for Law Enforcement: Under certain circumstances, Lake Turkana Wind Power may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency). 

Legal Requirements: Lake Turkana Wind Power may disclose your Personal Data in the good faith belief that such action is necessary to:

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Do Not Track Signals

Do Not Track” (“DNT”) is a preference you can set in your web browser to let us know you do not want us collecting data about you. At this time, this Site does not respond to DNT or similar signals. Please refer to the “ Tracking Cookies Data”  section of this Privacy Statement for more information about how you can decline the use of cookies on your device.

Your Rights under the Privacy Policy

You have the right to:

Note that some of these rights are limited by other’s rights to data protection.

Service Providers

We may employ third party companies and individuals to facilitate our Website (“Service Providers”), to provide the Website on our behalf, to perform Website -related services or to assist us in analysing how our Website is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyse the use of our Website. Google Analytics: Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Website. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Website available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en Advertising: We may use third-party Service Providers to show advertisements to you to help support and maintain our Website. Google AdSense: DoubleClick Cookie Google, as a third party vendor, uses cookies to serve ads on our Website. Google’s use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Website or other websites on the Internet. You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/ Bing Ads: Bing Ads is an advertising service provided by Microsoft, Inc. You can opt-out of Bing Ads remarketing by visiting: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads For more information about Bing Ads, please visit their Privacy Policy: https://privacy.microsoft.com/en-us/PrivacyStatement StartApp: StartApp is provided by StartApp, Inc. You can opt-out from interest-based ads served by StartApp by following the instructions on their Privacy Policy, section “8. Your Choices and Controls”: https://www.startapp.com/policy/privacy-policy/ For more information on what information StartApp collects and how it’s used, please read their Privacy Policy: https://www.startapp.com/policy/privacy-policy/ AdButler: AdButler is an advertising service provided by Sparklit Networks, Inc. For more information about AdButler, please visit their Privacy Policy: https://www.sparklit.com/agreements.spark?agreement=privacy

Behavioural Remarketing

Lake Turkana Wind Power uses remarketing services to advertise on third party websites to you after you visited our Website. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Website. Google AdWords: Google AdWords remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en Twitter: Twitter remarketing service is provided by Twitter Inc. You can opt-out from Twitter’s interest-based ads by following their instructions: https://support.twitter.com/articles/20170405 You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy Facebook: Facebook remarketing service is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950 To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217 Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings. For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation Pinterest: Pinterest remarketing service is provided by Pinterest Inc. You can opt-out from Pinterest’s interest-based ads by enabling the “Do Not Track” functionality of your web browser or by following Pinterest instructions: http://help.pinterest.com/en/articles/personalization-and-data You can learn more about the privacy practices and policies of Pinterest by visiting their Privacy Policy page: https://about.pinterest.com/en/privacy-policy AdRoll: AdRoll remarketing service is provided by Semantic Sugar, Inc. You can opt-out of AdRoll remarketing by visiting this AdRoll Advertising Preferences web page: http://info.evidon.com/pub_info/573?v=1nt=1nw=false For more information on the privacy practices of AdRoll, please visit the AdRoll Privacy Policy web page: http://www.adroll.com/about/privacy Perfect Audience: Perfect Audience remarketing service is provided by NowSpots Inc. You can opt-out of Perfect Audience remarketing by visiting these pages: Platform Opt-out (http://pixel.prfct.co/coo) and Partner Opt-out (http://ib.adnxs.com/optout). For more information on the privacy practices of Perfect Audience, please visit the Perfect Audience Privacy Policy Opt-out web page: https://www.perfectaudience.com/privacy/index.htmAppNexus: AppNexus remarketing service is provided by AppNexus Inc. You can opt-out of AppNexus remarketing by visiting the Privacy the AppNexus Platform web page: http://www.appnexus.com/platform-policy#choices For more information on the privacy practices of AppNexus, please visit the AppNexus Platform Privacy Policy web page: http://www.appnexus.com/platform-policy/

Links to Other Sites

Our Website may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Children’s Privacy

Our Website does not address anyone under the age of 18 (“Children”). We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Updates to this Privacy Policy

We may change, modify, or amend this Privacy Policy from time to time. We will notify you of material changes to this Privacy Policy by posting the amended terms on the Lake Turkana Wind Power Website at least thirty (30) days before the effective date of the changes. In addition, you will be required to affirmatively accept the new Privacy Policy the first time you visit the Website. If you do not agree with the proposed changes, you should discontinue your use of the Website prior to the time the new Privacy Policy takes effect. If you continue using the Website after the new Privacy Policy takes effect, you will be bound by the modified Privacy Policy.

Contact Us

If you have any questions or complaints regarding Lake Turkana Wind Power’s processing of your personal information in terms of this privacy policy, please contact us. If you are not satisfied with the response that you receive from Lake Turkana Wind Power, you may, where applicable, contact the relevant data protection regulator in your jurisdiction.

Lake Turkana Wind Power will provide information on the manner in which complaints to regulators may be made, if requested to do so.

March 2022

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