ODPC Kenya
DPA 2019 Compliant
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1. Statement of Compliance
ClearBridge Logistics Platform is firmly committed to protecting your privacy and handling your data securely. This Privacy Policy outlines our data processing practices in strict compliance with the Kenya Data Protection Act (DPA) 2019, guidelines issued by the Office of the Data Protection Commissioner (ODPC), and international standards including GDPR where applicable. We believe that safeguarding personal data is fundamental to our core operational integrity.
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2. The Data Subject Rights
- Right to be informed of the use to which personal data is to be put.
- Right to access personal data currently in our possession.
- Right to object to the processing of all or part of your personal data.
- Right to correction of false or misleading data without undue delay.
- Right to deletion of false or misleading data, or where data is no longer necessary.
- Right to data portability, enabling transfer of your data to another entity in a structured, machine-readable format.
- Right to not be subject to a decision based solely on automated processing.
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3. Nature of Personal Data Collected
| Category / Item | Description & Implementation |
|---|---|
| Identity Data | Full Name, Job Title, Identification Numbers, Company Name |
| Contact Data | Work Email, Phone Number, Billing Address, Postal Codes |
| Financial Data | Bank details for billing (processed securely via PCI-DSS compliant third-parties, we do not store full card records) |
| Technical Data | IP addresses, login timestamps, browser types, session durations, and telemetry (for security monitoring) |
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4. Purpose & Lawful Basis of Processing
- Contractual Necessity: To maintain your access to ClearBridge and facilitate logistics shipments, invoicing, and fleet tracking.
- Legal Obligation: For tax, fraud-prevention, financial audits, and regulatory compliance per Kenyan government guidelines.
- Explicit Consent: For promotional communications relevant to industry updates, for which you may easily withdraw consent via your Settings module.
- Legitimate Interest: To improve and refine our analytics engine and predictive shipping models using anonymized, aggregate datasets.
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5. Data Retention & Safeguarding
Personal data is retained only as long as necessary to fulfill the operational, tax, or legal requirements it was collected for, typically for the duration of your active subscription plus 7 years for financial records per Kenya Revenue Authority (KRA) mandates. ClearBridge uses strict encryption-in-transit (TLS 1.3) and encryption-at-rest (AES-256) methods across our cloud environment.
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6. Cross-Border Transfers
To provide resilient, high-availability services, our servers may be located outside of Kenya (e.g. AWS eu-central). In accordance with the Data Protection (General) Regulations 2021, any cross-border data transfer is heavily governed by strict legal frameworks and Standard Contractual Clauses mapping to ODPC equivalence.
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7. Data Breach Protocols
In the unlikely event of a data breach compromising personal identifiable information (PII), we maintain swift incident response plans and are mandated to notify the ODPC within 72 hours, alongside individual notification for elevated-risk breaches.
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8. Contact Our Data Protection Officer (DPO)
For inquiries, objections, requests for porting, or any assertion of your rights under the Data Protection Act 2019, please email our registered Data Protection Officer directly at privacy@clearbridge.co.ke. Please allow up to 14 days for a formal DPO response.
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