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Privacy Policy

 

1. Introduction

This Privacy Policy outlines the way in which Old Mutual Thrive mobile application ("Old Mutual Thrive app") collect, use, disclose, and protect personal information in compliance with Kenya’s Data Protection Act, 2019 ("DPA"), and other relevant international privacy regulations, including the General Data Protection Regulation ("GDPR"). The Policy ensures that we uphold the privacy rights of individuals whose data we process while collaborating with Old Mutual Thrive app in providing digital health services.

 

Governing the collection, use, and processing of personal data for the services provided by Old Mutual Thrive app, Old Mutual Group, and Aktivolabs Pte. Ltd., this Privacy Policy is jointly developed by Aktivolabs Pte. Ltd. in collaboration with Old Mutual Group and its affiliates (collectively referred to as the "Data Controllers," "Data Controller Entities," "Old Mutual Thrive app," "we," "us," or "our").

 

Old Mutual Holdings Plc

Old Mutual Tower, Upper Hill Road P.O. Box 43013 - 00100, Nairobi, Kenya

Tel: + 254 20 2850000

Mobile: + 254 711 065 000

Fax: + 254 20 2719 030

E-mail: oldmutualholdings@oldmutual.co.ke

Website: www.oldmutual.co.ke

 

Old Mutual General Insurance Kenya Limited

Old Mutual Tower, Upper Hill Road P.O. Box 43013 - 00100, Nairobi, KENYA

Tel: + 254 20 2850 000

Mobile: + 254 711 065 000

Fax: + 254 20 2719 030

E-mail: oldmutualgeneralinsurance@oldmutual.co.ke

 

Old Mutual Life Assurance Kenya Limited

Old Mutual Tower, Upper Hill Road P.O. Box 23842 – 00100, Nairobi, Kenya

Tel: +254 20 2850 300

Mobile: +254 711 065 300

Fax: + 254 20 2719 030

E-mail: life@oldmutual.co.ke

 

Old Mutual Life Assurance Company Limited

Old Mutual Tower, Upper Hill Road PO Box 30059-00100, Nairobi, Kenya

Mobile: +254 (0) 711 065 100, +254 (0) 711 010 100

Email: clientservices@oldmutual.co.ke

 

Old Mutual Investment Group Limited

Old Mutual Tower, Upper Hill Road P.O. Box 11589-00400 Nairobi, Kenya

Tel +254 (20) 282 9800, 272 8881

Email: omigclientrelations@oldmutualkenya.com

 

Old Mutual Securities Limited

Old Mutual Tower, Upper Hill Road P.O. Box 50338-00200 Nairobi, Kenya

Tel +254 720 909 091, +254 (20) 224 1408, +254 73100 206

Email: omsclientservice@oldmutualkenya.com

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Faulu Microfinance Bank Limited

Head Office Address: Ngong lane, off Ngong Road P.O. Box 60240-00200 Nairobi, Kenya

Telephone: +254 711 074 000, +254 711 074 074

Email: info@faulukenya.com

 

Old Mutual East Africa Holdings Group Limited

Old Mutual Tower, Upper Hill Road PO Box 30059, GPO 00100, Nairobi, Kenya

Tel: +254 (20) 2211 87/8

 

Aktivolabs Pte. Ltd.

10 Anson Road #22-02, International Plaza,

Singapore 079903

Email: hello@aktivolabs.com

 

2. Data Collection

We collect personal data to provide and improve our services, support user functionality, and ensure compliance with legal obligations.

 

Types of Data Collected:

  • Personal Identification Information: This includes basic information like your full name, age, physical address, email address, phone number, date of birth. This data helps us to identify you and communicate with you effectively.

  • Health and Activity Data: This refers to any health-related data you provide (e.g., fitness levels, heart rate, activity logs, steps, movement, diet, sleep, smoking and drinking information and any health assessments) and allows us to offer personalized insights into your well-being.

  • Device Information: Information about the devices you use to access our services (e.g., IP address, device type, operating system) helps us provide a better experience and troubleshoot any issues.

  • Usage Data: We collect data on your interactions within our platform to understand how you use our services. This could include time spent on the platform, actions taken, logins, information entries and features used. This data is essential for improving user experience and optimizing our services.

  • Sensitive Data: In the course of providing health-related services, we may collect sensitive personal data, such as medical history, conditions, or health metrics. This data is protected with high-security standards and is processed only when necessary to fulfil our services.

 

We also collect, use and share aggregated data such as statistical or demographic data for any purpose ("Aggregated Data"). Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Mobile Application feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

 

3. How Personal Data is Collected

We will collect and process the following personal data about you:

  • Information that you give us. This is information (including Identity, Contact and Marketing and Communications Data) that you consent to giving us about you by providing information through the Channels, or by corresponding with us directly (for example, by email or chat) or through our third-party commercial partners. It includes information that you provide when you register to use the Mobile Application, download or register the Mobile Application, subscribe to any of our Services, as defined below, or enter a competition, promotion or survey and when you report a problem with the Mobile Application, the Channels or our Services. If you contact us, we will keep a record of that correspondence.

  • Information that we collect about you and your device. Each time you visit one of the Channels or use the Mobile Application we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see the section on cookies below for further details.

  • Location Data. We also use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your smartphone’s settings.

  • Information that we receive from your use of your device. We also collect personal data including Identity Data, Contact Data, Health Data, Location Data, Biometric Data, through the use of the Channels or Mobile Application to provide a progress report, which contains your score, steps taken, calories burned, resting heart rate, sleep and distance covered. When your device syncs with our servers (including through background syncs on your Mobile Application), the forms of Data recorded on your device and transferred from your device to our servers are as follows:

    • Device Data;

    • Usage Data;

    • Location Data;

    • Health Data;

  • Information that we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

    • Device Data, from the following parties:

      • our Services through unique application numbers, when they are Installed or updated;

      • analytics providers, including Google and Apple that have operations globally;

      • any other aggregator of wearables and fitness trackers.

    • Contact Data, from providers of technical and delivery services;

    • Identity and Contact Data, from data brokers or aggregators that may be based globally; and

    • Identity and Contact Data, from publicly available sources.

 

4. Cookies

  • We use cookies and/or other tracking technologies to distinguish you from other users of the Mobile Application, the distribution platform or the Channels and to remember your preferences. This helps us to provide you with a good experience when you use the Mobile Application or browse any of the Channels and also allows us to improve the Mobile Application and the Channels.

  • The Data Controller Entities generally uses such automatically collected information and data to estimate the audience size of the Channels, gauge the popularity of various parts of the Channels, track your usage/ traffic patterns and the number of sign-ups to the Data Controller Entities promotional activities and special events and administer the Channels.

  • The Channels' server software will also record the domain name server address and track the pages you visit and store such information in cookies, and gather and store information such as internet protocol (IP) addresses, browser type, referring/exit pages, operating system, date/time stamp, and clickstream data in log files.

 

5. Legal Basis for Processing

We process personal data under the following legal grounds to ensure compliance with data protection regulations:

  • Consent: When you use our services, you provide explicit consent for the collection and processing of your personal data. This is done through clear consent mechanisms, such as registration forms and consent tick boxes.

  • Contractual Necessity: We process your data to fulfil contractual obligations between you and us, such as offering our health-related services and delivering product improvements.

  • Legal Obligation: We may need to process personal data to comply with applicable laws, including health regulations and financial reporting requirements.

  • Legitimate Interest: where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;

  • Data Processing Consent: You have the right to withdraw your consent at any time, and if you choose to do so, we will stop processing your data for that purpose.

 

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us at <omthrive@aktivolabs.com>.

 

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

 

In the event that you fail to provide us with your personal data when requested, we may not be able to perform the contract we have or that we wish to enter into with you. In that case, we may have to cancel a product or service you have with us. You have the right to withdraw your consent to our processing of your personal data at any time but please note, that your withdrawal will not affect the lawfulness of our processing of your personal data which was based on prior consent before your withdrawal or which is based on other legal basis for processing of your personal data. Please further note we may not be able to provide you with our products and services if you withdraw your consent.

 

6. Purposes and basis of usage of data

The Data Controllers strives to collect only personal data which is necessary and adequate but not excessive in relation to the purposes set out above.

 

The Channels are not intended for children and we do not knowingly collect personal data relating to children.

 

If you are not a child but are under the age of 18, the Data Controllers will require the prior consent of your parent or guardian, who may contact the responsible personnel of the Data Controller’s Entity at omthrive@aktivolabs.com to register you as a member of the Channels. The parent or guardian concerned will be required to consent in each instance that consent is required during the course of your relationship with the Data Controllers

 

7. Data Processing outside of Kenya:

We may process and store your personal data outside Kenya, including in the European Union (EU) region, where our servers are securely located. Any transfer of your personal data outside Kenya is conducted in compliance with applicable data protection laws and regulations, ensuring that adequate safeguards are in place to protect your information. By using our services, you consent to the processing and storage of your personal data in the EU and any other jurisdictions where such processing is necessary for the purposes outlined in this Privacy Policy.

 

8. Sharing of Personal Data

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table above:

  • Third Parties as set out in the Glossary;

  • Third parties who are advertisers on the Channels; and

  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

 

You acknowledge that the Data Controller Entities may receive money or other property in return for providing your personal data to third parties. You also acknowledge that your personal data may be shared with your employer or third parties that contract with your employer. The Data Controller Entities however remove personal data from which you may be directly identified before it shares personal data with any third parties.

 

The Data Controllers shall take all practicable steps to keep all of your personal data confidential and/or undisclosed other than in accordance with this Privacy Policy.

 

Personal data collected via the Channels may be transferred, stored, and processed in any country in which the Data Controller Entities operates. By using the Channels, you agree to, consent to, and authorise the Data Controller Entities to disclose and/or transfer your personal data under the circumstances stated above, as well as to any transfer of your personal data outside of the country in which you are located.

 

Types of Data Sharing:

  • Internal Sharing: Data shared between the Data Controllers and Old Mutual Thrive app for service provision, customer support, and business operations.

  • Third-Party Sharing: We may also share your data with trusted third-party providers who assist in providing services, including cloud service providers and analytics companies. These third parties are obligated to maintain confidentiality and adhere to the same data protection standards.

  • Regulatory Authorities: We may share data with government authorities or regulatory bodies as required by law (e.g., in the case of health data reporting or fraud prevention).

 

Data Sharing Agreement: A data-sharing agreement between the Data Controllers ensures both companies abide by appropriate data protection measures and clearly defines their responsibilities in handling personal data.

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9. Amendment of your Personal Data by Third Parties

Pursuant to our commercial arrangements with our partners, you may have been provided access to the Mobile Application. In the event that you were provided access to the Mobile Application by your insurer, your insurer will have access to edit your personal information. In the event that you were provided access to the Mobile Application by your employee through their insurance broker, your employer will have access to edit your personal information. The list of relevant personal information is as follows:

  • department and team assignment;

  • first, middle and last name;

  • gender;

  • contact information; and

  • area of interest.

 

10. Data Security

The security of your personal data is important to the Data Controllers. The Data Controllers has implemented appropriate electronic and managerial measures in order to safeguard, protect, and secure your personal data.

 

All personal data provided by you is only accessible by the authorised personnel of the Data Controller Entities or its authorised third parties, and such personnel shall be instructed to observe the terms of this Privacy Policy when accessing such personal data. You should safeguard your unique username and password by keeping them secret and confidential and by never sharing these details with anyone.

 

The Data Controller Entities follows generally accepted industry standards to protect the personal data submitted by you to the Channels, both during transmission and once the Data Controllers receives it. However, no method of transmission over the internet, or method of electronic storage, is completely secure. Therefore, while the Data Controller Entities strives to protect your personal data against unauthorised access, the Data Controllers cannot guarantee its absolute security.

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

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11. Automated Decision Making​

We may utilize automated decision-making processes to enhance user experience and service delivery. This includes profiling your activity data to assess your fitness patterns, preferences, and potential needs for tailored recommendations. Automated assessments may influence suggestions for workouts, diet plans, or other health-related services.

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Users can request not to rely solely on automated processes; however, this may limit the personalized features available to them.

 

12. Retention of Personal Data

Once the Data Controllers has obtained your personal data, it will be maintained securely in the Data Controller Entities system. Subject to legal requirements, your personal data will be retained by the Data Controllers after deactivation of the relevant service until you request the Data Controllers in writing to erase your personal data from the Data Controller Entities database or terminate your membership of the Channels or is no longer necessary for the fulfilment of the declared, specified, and legitimate purpose.

 

In some circumstances you can ask us to delete your data: see the section on your legal rights below for further information.

 

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

13. Changes to this Privacy Policy

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The Data Controller Entities reserves the right to update, revise, modify, or amend this Privacy Policy at any time as the Data Controllers deems necessary.

 

This version was last updated on 1 March 2025. It may change and if it does, these changes will be posted on this page and where appropriate, notified to you by email OR when you next start the Mobile Application. The new policy may be displayed on- screen and you may be required to read and accept the changes to continue your use of the Mobile Application or Channels.

 

It is important that the personal data that we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

 

14. Third Party Links

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Our Channels may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that the Data Controller Entities does not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services. Please check these policies before you submit any personal data to these websites or use these services.

 

15. Your Legal Rights

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Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

  • Request access to your personal data.

  • Request correction of your personal data.

  • Request erasure of your personal data.

  • Object to processing of your personal data.

  • Request restriction of processing your personal data.

  • Request transfer of your personal data.

  • Right to withdraw consent.

  • Right to damages.

 

Please refer to the Glossary below to find out more about these rights.

You also have the right to ask us not to continue to process your personal data for marketing purposes.

 

You can exercise any of these rights at any time by contacting us at omthrive@aktivolabs.com.

 

16. Governing Law and Jurisdiction

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Nothing in this Privacy Policy shall limit your rights under the Kenyan Data Protection Act, Personal Data Protection Act 2012 of Singapore, the General Data Protection Regulation or any other data protection or privacy related law that is applicable to you. This Privacy Policy shall be governed jointly by the laws of the Republic of Kenya and the Republic of Singapore and you agree to submit to the exclusive jurisdiction of the Kenyan and Singapore courts.

 

 

GLOSSARY

 

LAWFUL BASIS

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

 

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. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

 

Performance of Contract means processing your personal data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

 

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.

 

THIRD PARTIES

Service providers, acting as processors based in Singapore and other jurisdictions globally who provide IT and system administration services.

 

Data Intermediaries, being organisations that process data on our behalf. Such processing services include recording, retrieval, organisation and destruction of data.

 

Professional advisers including lawyers, bankers, auditors and insurers based in Singapore and other jurisdictions globally, who provide consultancy, banking, legal, insurance and accounting services to the Data Controller Entities or its clients.

 

Tax and other authorities who require reporting of processing activities in certain circumstances based on Data Controllers jurisdictions.

 

Third parties involved in any situation in which the Data Controllers needs to protect and defend its rights and property.

Third parties to which the Data Controllers considers disclosure necessary in order to comply with the applicable laws and regulations, including without limitation, compliance with a judicial proceeding, court order or legal process served on the Channels.

 

Third parties, such as our commercial partners, or selected providers of wearables and fitness trackers (such as mobile phones) compatible with the Mobile Application to whom the Data Controllers considers disclosure necessary in order to maintain, provide, or improve the Services.

 

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YOUR LEGAL RIGHTS

You have the right to:

 

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

 

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

 

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

 

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

 

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • if you want us to establish the personal data's accuracy;

  • where our use of the personal data is unlawful but you do not want us to erase it;

  • where you need us to hold the personal data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

  • you have objected to our use of your personal data but we need to verify whether we have overriding legitimate grounds to use it.

 

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

 

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

 

Right to damages which means the right to be indemnified for any damages sustained due to such inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of personal data, taking into account any violation of your rights and freedoms as data subject.

 

DESCRIPTION OF CATEGORIES OF PERSONAL DATA

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Identity Data: first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender, photographs, video images. We may also collect your government-issued identification number, but we recognize that this is highly sensitive in nature and will only do so when this is necessary to verify your identity to a high degree of fidelity, and only when permitted by applicable laws.

 

Contact Data: billing address, delivery address, email address, mobile or other telephone numbers.

 

Device Data: includes the type of mobile device you use, device model number, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, and time zone setting.

 

Content Data: includes information stored on your Device, including friends' lists, login information, photos, videos or other digital content and check-ins.

 

Profile Data: includes your username and password, your interests, preferences, feedback and survey responses and any other relevant information concerning your user profile.

 

Usage Data: includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.

 

Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.

 

Location Data: includes your current location disclosed by GPS technology.

 

Health Data: includes

  • physiological data, activity, sleep, and exercise data (such as calories burnt, steps walked, distance and speed travelled), and drinking and smoking profiles, and also includes common risk factors or markers for diabetes, such as biological sex, waist circumference, height, weight, blood pressure, blood or glucose levels, high-density lipoprotein cholesterol and low-density lipoprotein cholesterol levels, triglyceride levels, total cholesterol levels, food consumption, medication history, and family health history.

  • Mental health data, including the results and self-created notes from self-assessments and records of mental-wellness exercises conducted.

 

Biometric Data: includes thumbprints, facial images, voice recording or any personal data resulting from specific technical processing relating to the physical, physiological or behavioural characteristics of a natural person, which allow or confirm the unique identification of that natural person.

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