Terms & Conditions

Our Commitment

MIRIMO commits to respecting your privacy and protecting your Personal Information.

  • MIRIMO will be transparent about the information we are collecting and what we will do with it

  • MIRIMO will use the information you give for the purposes described in this Policy,

  • which include providing you with services you have requested and enhancing your experience with us

  • MIRIMO will also use the information collected to help us understand you better and so that we

  • can give you relevant offers

  • If at any time you inform us that you do not want to receive any further marketing messages

  • we will stop sending them. We may, however, continue to send important service messages

  • containing information relating to a product or service you have purchased to keep you

  • informed about your purchases

  • MIRIMO will put in place appropriate measures to protect your information and keep it secure

  • MIRIMO will at all times respect your data protection rights

If you have further questions please get in touch with us by writing to Data Protection Officer,

using the details provided in Section (T) below.

Without prejudice to your rights under applicable laws, the above and this Privacy Policy are not

contractual and do not form part of your contract with us.

Our Policy

This Policy is issued by each of the Controllers listed in Section (T) below

(together “MIRIMO”, “we”, “us” and “our”) and is addressed to individuals outside our organisation with

whom we interact, including customers, visitors to our Sites, users of our Apps, other users of our products

or services, and visitors to our premises (together, “you”). Defined terms used in this Policy are explained

in Section (U) below.

This Policy may be amended or updated from time to time to reflect changes in our practices with respect

to the Processing of Personal Information, or changes in applicable law. We encourage you to read

this Policy carefully, and to regularly check this page to review any changes we might make in accordance

with the terms of this Policy

Personal Information

Collection of Personal Information: We collect or obtain Personal Information below. In brief, it means

details which identify you or could be used to identify you. This includes information such as your name

and contact details, your age, your educational information and search history. This may also include

information about how you use our websites and mobile applications.

Collection of Personal Information: We collect or obtain Personal Information about you from the following

sources:

  • Information provided to us: We obtain Personal Information when that information is provided to

  • us (e.g., where you contact us via email or telephone, or by any other means, or when you provide

  • us with your business card, or when you create an online profile with us, or when you submit a job

  • application).

  • Relationship information: We collect or obtain Personal Information in the ordinary course of our

  • relationship with you (e.g., we provide a service to you, or to your employer). We collect your

  • Personal Information whenever you use our services (whether these services are provided

  • by us or by other companies or agents acting on our behalf), including when when you use our

  • website or mobile applications, or interact with us via email or our contact centres

  • Information you make public: We collect or obtain Personal Information that you manifestly

  • choose to make public, including via social media (e.g., we may collect information from your

  • social media profile(s), if you make a public post about us).

  • App data: We collect or obtain Personal Information when you download or use any of our Apps.

  • Site data: We collect or obtain Personal Information when you visit any of our Sites or use any

  •  features or resources available on or through a Site.

  • Registration details: We collect or obtain Personal Information when you use, or register to use,

  • any of our Sites, Apps, products, or services.

  • Content and advertising information: If you interact with any third party content or advertising

  • on a Site or in an App (including third party plugins and cookies) we receive Personal Information

  • from the relevant third party provider of that content or advertising.

  • Third party information: We collect or obtain Personal Information from third parties who provide

  • it to us (e.g., companies contracted by us to provide services to you, credit reference agencies;

  • law enforcement authorities; etc.).

Creation of Personal Information

We also create Personal Information about you in certain circumstances, such as records of your interactions

with us (including records of your telephone conversations with us), and details of your purchase history.

Categories of Personal Information we Process

We Process the following categories of Personal Information about you:

  • Personal details: given name(s); preferred name; and photograph.

  • Demographic information: gender; date of birth / age; nationality; passport details; salutation;

  • title; and language preferences.

  • Contact details: correspondence address; telephone number; email address; details of Personal

  • Assistants, where applicable; messenger app details; online messaging details; and social media details.

  • Consent records: records of any consents you have given, together with the date and time,

  • means of consent and any related information (e.g., the subject matter of the consent).

  • Payment details: invoice records; payment records; billing address; payment method;

bank account number or credit card number; cardholder or accountholder name; card or

account security details; card ‘valid from’ date; card expiry date; BACS details; SWIFT details;

IBAN details; payment amount; payment date; and records of cheques.

  • Information relating to our Sites and Apps: device type; operating system; browser type;

  • browser settings; IP address; language settings; dates and times of connecting to a Site; App

  • usage statistics; App settings; dates and times of connecting to an App; location data,

  • and other technical communications information (some of which may constitute Personal Information);

  •  username; password; security login details; usage data; aggregate statistical information.

  • Employer details: where you interact with us in your capacity as an employee of a third party,

  • the name, address, telephone number and email address of your employer, to the extent relevant.

  • Content and advertising information: records of your interactions with our online advertising and

  • content, records of advertising and content displayed on pages or App screens displayed to

  • you, and any interaction you may have had with such content or advertising (e.g., mouse hover,

  • mouse clicks, any forms you complete in whole or in part) and any touchscreen interactions.

  • Views and opinions: any views and opinions that you choose to send to us, or publicly post

  • about us on social media platforms.

  • Other interactions with us: information if you have entered a competition or registered for a promotion.

If you provide us with another individual’s Personal Information, you must ensure that you have the

permission of that individual before you provide it to us (for example, if you are making a booking

for another individual). When you are making a purchase for someone else, we may collect your payment

details but may communicate with the other individual directly about the purchase.

Sensitive Personal Information

We may collect and Process Sensitive Personal Information in the ordinary course of our business. MIRIMOB will limit

the circumstances where we collect and process Sensitive Personal Information. Examples of when we may collect

and process Sensitive Personal Information include situations where:

  • you make an application for a job which requires you to provide that Sensitive Personal Information;

  • such information to us or it has been passed to us by a third party;

  • you have requested services which may imply or suggest your religion, health or other information

  • (e.g. when you disclose your dietary requirements to us).

Where it becomes necessary to Process your Sensitive Personal Information for any reason, we rely on one of the

following legal bases:

  • Compliance with applicable law: We may Process your Sensitive Personal Information where

  • the Processing is required or permitted by applicable law (e.g., to comply with our diversity

  • reporting obligations);

  • Detection and prevention of crime: We may Process your Sensitive Personal Information where

  • the Processing is necessary for the detection or prevention of crime (e.g., the prevention of fraud);

  • Establishment, exercise or defence of legal rights: We may Process your Sensitive Personal

  • Information where the Processing is necessary for the establishment, exercise or defence of legal rights;

  • or consent: We may Process your Sensitive Personal Information where we have, in accordance

  • with applicable law, obtained your prior, express consent prior to Processing your Sensitive

  • Personal Information (this legal basis is only used in relation to Processing that is entirely voluntary

  • – it is not used for Processing that is necessary or obligatory in any way).

If you provide Sensitive Personal Information to us, you must ensure that it is lawful for you to disclose such

information to us, and you must ensure a valid legal basis applies to the Processing of those Sensitive Personal Information.

Purposes of Processing and legal bases for Processing

The purposes for which we Process Personal Information, subject to applicable law, and the legal bases

on which we perform such Processing, are as follows:

Processing activity Legal basis for Processing

Provision of Sites, Apps, products, and services: providing our Sites, Apps, products, or services; providing promotional items upon request; and communicating with you in relation to those Sites, Apps, products, or services.

The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or

We have a legitimate interest in carrying out the Processing for the purpose of providing our Sites, Apps, poducts and services (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or

We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

Compliance checks: fulfilling our regulatory compliance obligations; and confirming and verifying your identity; use of credit reference agencies; and screening against government and/or law enforcement agency sanctions lists and other legal restrictions.

The Processing is necessary for compliance with a legal obligation; or

The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or

We have a legitimate interest in carrying out the Processing for the purpose of fulfilling our regulatory and compliance obligations (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or

We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

Operating our business: operating and managing our Sites, our Apps, our products, and our services; providing content to you; displaying advertising and other information to you; communicating and interacting with you via our Sites, our Apps, our products, or our services; and notifying you of changes to any of our Sites, our Apps, our products, or our services.

The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or

The Processing is necessary for compliance with a legal obligation; or

We have a legitimate interest in carrying out the Processing for the purpose of providing our Sites, our Apps, our products, or our services to you (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or

We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

Communications and marketing: communicating with you via any means (including via email, telephone, text message, social media, post or in person) news items and other information in which you may be interested, subject always to obtaining your prior opt-in consent to the extent required under applicable law; maintaining and updating your contact information where appropriate; and obtaining your prior, opt-in consent where required.

The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or

We have a legitimate interest in carrying out the Processing for the purpose of contacting you, subject always to compliance with applicable law (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or

We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

Management of IT systems: management and operation of our communications, IT and security systems; and audits (including security audits) and monitoring of such systems.

The Processing is necessary for compliance with a legal obligation; or

We have a legitimate interest in carrying out the Processing for the purpose of managing and maintaining our communications and IT systems (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).

Financial management: finance; corporate audit; and vendor management.

We have a legitimate interest in carrying out the Processing for the purpose of managing and operating the financial affairs of our business (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or

We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

Surveys: engaging with you for the purposes of obtaining your views on our Sites, our Apps, our products, or our services.

We have a legitimate interest in carrying out the Processing for the purpose of conducting surveys, satisfaction reports and market research (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or

We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

Security: physical security of our premises (including records of visits to our premises); CCTV recordings; and electronic security (including login records and access details).

The Processing is necessary for compliance with a legal obligation; or

We have a legitimate interest in carrying out the Processing for the purpose of ensuring the physical and electronic security of our business and our premises (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).

Investigations: detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law.

The Processing is necessary for compliance with a legal obligation; or

We have a legitimate interest in carrying out the Processing for the purpose of detecting, and protecting against, breaches of our policies and applicable laws (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).

Legal proceedings: establishing, exercising and defending legal rights.

The Processing is necessary for compliance with a legal obligation; or

We have a legitimate interest in carrying out the Processing for the purpose of establishing, exercising or defending our legal rights (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).

Legal compliance: compliance with our legal and regulatory obligations under applicable law.

The Processing is necessary for compliance with a legal obligation.

Improving our Sites, Apps, products, and services: identifying issues with our Sites, our Apps, our products, or our services; planning improvements to our Sites, our Apps, our products, or our services; and creating new Sites, Apps, products, or services.

We have a legitimate interest in carrying out the Processing for the purpose of improving our Sites, our Apps, our products, or our services (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or

We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

Fraud prevention: Detecting, preventing and investigating fraud.

The Processing is necessary for compliance with a legal obligation (especially in respect of applicable employment law); or

We have a legitimate interest in carrying out the Processing for the purpose of detecting, and protecting against, fraud (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).

Recruitment and job applications: recruitment activities; advertising of positions; interview activities; analysis of suitability for the relevant position; records of hiring decisions; offer details; and acceptance details.

The Processing is necessary for compliance with a legal obligation (especially in respect of applicable employment law); or

We have a legitimate interest in carrying out the Processing for the purpose of recruitment activities and handling job applications (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or

We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

Disclosure of Personal Information to third parties

We disclose Personal Information to other entities within the MIRIMO group, for legitimate business purposes

and the operation of our Sites, Apps, products, or services to you), in accordance with applicable law.

 In addition, we disclose your Personal Information to:

  • you and, where appropriate, your appointed representatives;

  • legal and regulatory authorities upon request, or for the purposes of reporting any actual

  • or suspected breach of applicable law or regulation;

  • accountants, auditors, lawyers and other outside professional advisors to MIRIMO,

  • subject to binding contractual obligations of confidentiality;

  • third party Processors, located anywhere in the world, subject to the requirements noted below

  • in this Section (H);

  • any relevant party, law enforcement agency or court, to the extent necessary for the establishment,

  • exercise or defence of legal rights;

  • any relevant party for the purposes of prevention, investigation, detection or prosecution of

  • criminal offences or the execution of criminal penalties;

  • any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion

  • of our business or assets (including in the event of a reorganization, dissolution or liquidation);

  • any relevant third party provider, where our Sites and our Apps use third party advertising,

  • plugins or content. If you choose to interact with any such advertising, plugins or content, your

  • Personal Information may be shared with the relevant third party provider. We recommend that

  • you review that third party’s privacy policy before interacting with its advertising, plugins or content.

If we engage a third-party Processor to Process your Personal Information, the Processor will be

subject to binding contractual obligations to: (i) only Process the Personal Information in accordance with

our prior written instructions; and (ii) use measures to protect the confidentiality and security of the

Personal Information; together with any additional requirements under applicable law.

Government Access to MIRIMO records

Further information about these arrangements, including measures to safeguard your Personal Information can

be obtained if you click here [INSERT LINK] (this link is an external website, not Kenya-airways.com.

Please note that MIRIMO isn't responsible for the information contained on this website, and that different terms

and conditions may apply).

What information do you hold about me which may be accessed?

MIRIMO holds information about you which is required for the purpose of conducting business with you.

This may include details you have told us about any medical, disability, or health conditions you may have;

payment details; contact information; and, any special requirements you have specified.

Who will you pass the information to, and who will they share it with?

The information will be given to the Border Control authorities, for example, Customs, of countries which

have a legal right to acquire the information. They may share it with other enforcement authorities for the

purposes of preventing and combating terrorism and other serious criminal offences.

What if I refuse you permission to release my information to the authorities?

If the information is required by the authorities, MIRIMOwill have to cancel your profile and will be

unable to continue to provide you the services it offers.

What will the authorities be using the data for?

Informationis used for enforcement purposes, including use in threat analysis to identify and interdict

potential terrorists, and other threats to national and public security; and to focus government resources

on high risk concerns, thereby facilitating and safeguarding its nationals.

Are my credit card details included?

Where payments were made by credit card and this information is included in your profile information

record, the authorities may view such details.

How long will information be held?

Each country should hold the information for no longer than is required for the purpose for which it was stored.

Will the information be transmitted in a secure fashion?

Yes, MIRIMO will pass the information to the authorities by secure means

Profiling

We Process Personal Information for the purposes of automated decision-making and Profiling,

which is carried out for the following purposes:

Profiling activity

Logic of the Profiling activity

Consequences for you

Credit scoring

Where we engage a third party (e.g., a credit reference agency) to provide us with information about your credit score and/or credit history. This information is analysed to determine the most appropriate terms on which to offer you credit, where applicable.

This Profiling activity may affect whether you are able to obtain credit, and the interest rates applicable to any such credit.

Customised discounts

[Where we analyse your purchasing activity and your interests. This information is analysed to determine the most appropriate promotions and discounts to offer you.]

[This Profiling activity may mean that you receive discounts that are not available to others, and that others receive discounts that are not available to you.

(K) International transfer of Personal Information

Because of the international nature of our business, we transfer Personal Information within the MIRIMO,

and to third parties as noted in Section (H) above, in connection with the purposes set

out in this Policy. For this reason, we transfer Personal Information to other countries that may have

different laws and data protection compliance requirements to those that apply in the country in which

you are located.

Where we transfer your Personal Information from the EEA to recipients located outside the EEA who

are not in Adequate Jurisdictions, we do so on the basis of Standard Contractual Clauses. You are

entitled to request a copy of our Standard Contractual Clauses using the contact details provided in

Section (T) below.

Please note that when you transfer any Personal Information directly to a MIRIMO entity established

outside the EEA, we are not responsible for that transfer of your Personal Information. We will

nevertheless Process your Personal Information, from the point at which we receive the information,

in accordance with the provisions of this Policy.

Information security

We have implemented appropriate technical and organisational security measures designed to protect your

Personal Information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure,

unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable

law. Because the internet is an open system, the transmission of information via the internet is not

completely secure. Although we will implement all reasonable measures to protect your Personal Information,

we cannot guarantee the security of the information transmitted to us using the internet –

any such transmission is at your own risk and you are responsible for ensuring that any Personal Information

that you send to us is sent securely

(M) Information accuracy

We take every reasonable step to ensure that:

  • Personal Information of yours that we Process is accurate and, where necessary, kept up to date; and

  • Any Personal Information of yours that we Process that is inaccurate (having regard to the purposes

  • for which they the information is Processed) is erased or rectified without delay.

From time to time we may ask you to confirm the accuracy of your Personal Information.

(N) Information minimisation

We take every reasonable step to ensure that your Personal Information that we Process is limited

to the Personal Information reasonably necessary in connection with the purposes set out in this Policy.

(O) Information retention

We take every reasonable step to ensure that your Personal Information is only Processed for the minimum

period necessary for the purposes set out in this Policy. The criteria for determining the duration for which we will

retain your Personal Information is as follows:

(1) We will retain Personal Information in a form that permits identification only for as long as:

(a) We maintain an ongoing relationship with you (e.g., where you are a customer, a member of the Flying Blue reward program, or you are lawfully included in our mailing list and have not unsubscribed); or

(b) your Personal Information is necessary in connection with the lawful purposes set out in this Policy, for which we have a valid legal basis (e.g., where your Personal Information is included in a contract between us and your employer, and we have a legitimate interest in processing that information for the purposes of operating our business and fulfilling our obligations under that contract; or where we have a legal obligation to retain your Personal Information),

plus:

(2) the duration of:

(a) any applicable limitation period under applicable law (i.e., any period during which any person could bring a legal claim against us in connection with your Personal Information, or to which your Personal Information is relevant); and

(b) an additional two (2) month period following the end of such applicable limitation period (so that, if a person brings a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any Personal Information that is relevant to that claim) and (3) in addition, if any relevant legal claims are brought, we continue to Process Personal Information for such additional periods as is necessary in connection with that claim.

During the periods noted in paragraphs (2)(a) and (2)(b) above, we will restrict our Processing of your Personal

Information to storage of, and maintaining the security of, that information, except to the extent that the information

needs to be reviewed in connection with any legal claim, or any obligation under applicable law.

Once the periods in paragraphs (1),(2) and (3) above, each to the extent applicable, have concluded, we will either:

  • permanently delete or destroy the relevant Personal Information; or

  • anonymize the relevant Personal Information.