Privacy & Data Protection Statement

1. Introduction

The Avocado Society of Kenya (ASOK) is committed to protecting the privacy, confidentiality and security of personal information entrusted to us by our members, avocado growers, exporters, industry stakeholders, partners, event participants, website visitors and other persons who interact with the Society.

This Privacy & Data Protection Statement explains how ASOK collects, uses, stores, shares, protects and otherwise processes personal data through its website, membership activities, events, programmes, communications and other operations.

ASOK processes personal data in accordance with applicable laws including:

• The Constitution of Kenya, 2010, particularly Article 31 on the right to privacy;
• The Data Protection Act, 2019 (Kenya);
• The Data Protection (General) Regulations, 2021;
• Applicable guidance issued by the Office of the Data Protection Commissioner (ODPC); and
• Where applicable, internationally recognised privacy principles including the EU General Data Protection Regulation (GDPR).

ASOK is committed to processing personal data lawfully, fairly, transparently and securely.

2. Scope of this Statement

This Statement applies to personal data processed by ASOK through:

• kenyaavocados.co.ke and associated digital platforms operated by ASOK;
• Membership applications and membership administration;
• Conferences, exhibitions, workshops, training programmes and field days;
• Avocado Africa Conference and related activities;
• Kenya Avocado Excellence Awards and related activities;
• Online registration and enquiry forms;
• Email, telephone and other communications;
• Surveys, research and stakeholder consultations;
• Newsletters and industry communications;
• Social media platforms;
• Photographs, video and other media captured during ASOK activities; and
• Other legitimate activities undertaken by ASOK.

3. Personal Data We May Collect

Identity Information

Your name, organisation, job title, membership details and other information necessary to identify you.

Contact Information

Your email address, telephone number, postal address, physical address and other contact information.

Professional and Business Information

Information relating to your organisation, profession, avocado farming, exporting activities, industry role, business interests and areas of expertise.

Membership Information

Membership category, membership status, application details, payment status and records relating to participation in ASOK activities.

Event Information

Registration information for conferences, exhibitions, awards, workshops, training sessions, field days, webinars and other ASOK events.

Transaction Information

Information relating to membership fees, event registration fees, sponsorships, exhibitions and other transactions.

Where electronic payments are used, payment information may be processed by authorised third-party payment service providers. ASOK does not ordinarily store complete payment-card details where payments are processed through external payment gateways.

Communication Information

Messages, enquiries, correspondence, feedback, complaints and other communications sent to ASOK.

Website and Technical Information

When you visit our website, certain information may be collected automatically including:

• IP address;
• Browser type and version;
• Device type;
• Operating system;
• Pages visited;
• Referring website;
• Date and time of access;
• Website interaction information;
• Approximate geographical information derived from IP address; and
• Cookie and similar technology identifiers.

Images and Media

ASOK may capture photographs, audio recordings and video footage during conferences, awards ceremonies, exhibitions, workshops, training sessions and other events.

4. How We Collect Personal Data

We may obtain personal data:

• Directly from you;
• Through website forms;
• Through membership applications;
• Through event registrations;
• Through email, telephone and other communications;
• During conferences, exhibitions and other ASOK activities;
• From organisations that you represent;
• From ASOK partners and service providers where lawful;
• From publicly available professional or business sources;
• Through cookies and website analytics technologies; and
• From other legitimate sources permitted by applicable law.

5. Purposes for Processing Personal Data

ASOK may process personal data for purposes including:

• Administering ASOK membership;
• Communicating with members and stakeholders;
• Processing membership applications and renewals;
• Organising conferences, exhibitions, awards and training programmes;
• Managing registrations and attendance;
• Providing information about avocado industry developments;
• Facilitating networking and industry collaboration;
• Supporting growers, exporters and other avocado value-chain stakeholders;
• Conducting research, surveys and industry consultations;
• Providing newsletters, announcements and industry updates;
• Responding to enquiries and requests;
• Managing partnerships and sponsorship relationships;
• Maintaining financial and administrative records;
• Processing payments and confirming transactions;
• Improving website functionality and user experience;
• Measuring website performance and usage;
• Maintaining website and information-system security;
• Preventing fraud, abuse and cybersecurity threats;
• Complying with legal and regulatory obligations; and
• Protecting the legitimate interests, rights and property of ASOK.

6. Lawful Basis for Processing

ASOK processes personal data only where an appropriate lawful basis exists.

7. Data Protection Principles

ASOK seeks to ensure that personal data is:

• Processed lawfully, fairly and transparently;
• Collected for explicit, specified and legitimate purposes;
• Adequate, relevant and limited to what is necessary;
• Accurate and reasonably up to date;
• Retained only for as long as reasonably necessary;
• Protected against unauthorised access, loss, disclosure or destruction; and
• Processed in a manner that respects individual privacy rights.

8. Cookies and Similar Technologies

The ASOK website may use cookies and similar technologies to provide website functionality, remember preferences, understand website usage, improve performance and enhance security.

Essential Cookies

Required for the website to operate correctly.

Functional Cookies

Used to remember visitor preferences and improve functionality.

Analytics Cookies

Used to understand how visitors interact with the website and help improve its performance.

Marketing or Third-Party Cookies

Where applicable, these may support embedded content, social media, advertising or campaign measurement.

Where required by applicable law, non-essential cookies will be activated only after obtaining appropriate consent.

9. Analytics and Third-Party Technologies

ASOK may use reputable technology providers to operate, secure, analyse and improve its website and digital services.

Such services may include:

• Website hosting;
• Website analytics;
• Email delivery;
• Cloud storage;
• Cybersecurity services;
• Event management systems;
• Online forms;
• Payment processing;
• Social media platforms;
• Video conferencing;
• Website backups; and
• Content delivery services.

10. Sharing and Disclosure of Personal Data

Personal data may nevertheless be disclosed where reasonably necessary to:

• Authorised ASOK staff and officials;
• Technology and website service providers;
• Event management and registration providers;
• Professional advisers;
• Payment processors;
• Conference and programme partners;
• Regulatory authorities;
• Government agencies where legally required;
• Law-enforcement agencies where required by law; or
• Other parties where you have authorised the disclosure.

11. International and Cross-Border Data Transfers

Some technology platforms, cloud services, email systems, analytics tools or service providers used by ASOK may process or store information outside Kenya.

Where personal data is transferred outside Kenya, ASOK will seek to ensure that such transfers comply with applicable Kenyan data protection requirements and appropriate safeguards are implemented.

12. Data Security

ASOK takes reasonable administrative, organisational, physical and technical measures designed to protect personal information.

Measures may include:

• Access controls and user authentication;
• Password protection;
• Encryption;
• Secure website connections using SSL/TLS;
• Firewalls and security monitoring;
• Malware protection;
• Software updates and security patching;
• Secure backups;
• Role-based access controls;
• Staff confidentiality obligations;
• Data minimisation; and
• Incident response procedures.

No internet-based system can guarantee absolute security. ASOK therefore seeks to continually improve its technical and organisational safeguards.

13. Personal Data Breaches

ASOK maintains procedures for identifying, investigating, containing and responding to suspected personal-data breaches.

Where a breach presents a legally reportable risk, ASOK will notify the Office of the Data Protection Commissioner (ODPC) and affected data subjects as required under applicable law.

14. Data Retention

ASOK retains personal data only for as long as reasonably necessary for the purpose for which it was collected or as required by law.

Retention periods may depend on:

• The nature and purpose of the information;
• Membership duration;
• Contractual obligations;
• Financial and statutory record-keeping requirements;
• Legal limitation periods;
• Security considerations; and
• Legitimate organisational requirements.

15. Your Data Protection Rights

Subject to applicable law and lawful exemptions, individuals may have the right to:

• Be informed about how their personal data is used;
• Request access to personal data held about them;
• Request correction of inaccurate or misleading information;
• Request deletion or erasure where legally applicable;
• Object to certain processing activities;
• Request restriction of certain processing activities;
• Withdraw consent where processing relies on consent;
• Request portability of personal data where applicable; and
• Lodge a complaint regarding processing of their personal information.

16. Marketing and Electronic Communications

ASOK may communicate with members and stakeholders regarding industry news, conferences, events, training programmes, awards, membership matters, research, market developments and partnership opportunities.

Where consent is required for electronic marketing, ASOK will obtain appropriate consent. Recipients may unsubscribe from non-essential communications using the unsubscribe mechanism provided.

17. Children's Personal Data

ASOK's website and services are primarily intended for adults and organisations operating within the avocado and agricultural value chain.

ASOK does not knowingly seek to collect personal data from children through its website without appropriate authorisation.

18. Photography, Video and Events

ASOK conferences, exhibitions, awards ceremonies, workshops and other events may be photographed or recorded for documentation, reporting, educational, promotional and communication purposes.

Where practicable, attendees will be informed when photography or recording is taking place.

19. Links to External Websites

The ASOK website may contain links to websites, platforms or services operated by third parties.

ASOK is not responsible for the privacy practices, security, availability or content of independent third-party websites.

20. Automated Decision-Making and Artificial Intelligence

ASOK may from time to time adopt digital technologies, including automated tools or Artificial Intelligence (AI), to improve administrative efficiency, communication, analysis or service delivery.

Where such technologies process personal information, ASOK will seek to apply appropriate privacy, security, human-oversight and data-minimisation safeguards.

ASOK will not ordinarily make decisions producing significant legal or similar effects on individuals solely through automated processing without an appropriate lawful basis and applicable safeguards.

21. Social Media

ASOK may maintain profiles on social media and digital communication platforms. When individuals interact with ASOK through these platforms, both ASOK and the relevant platform provider may process information.

Users are encouraged to review the privacy policies and privacy settings of those platforms.

22. Changes to this Privacy Statement

ASOK may update this Privacy & Data Protection Statement periodically to reflect changes in law, regulation, technology, cybersecurity practices, organisational operations or website functionality.

The latest version will be published on the ASOK website together with the applicable revision date.

23. Contacting the Avocado Society of Kenya

24. Complaints to the Data Protection Commissioner

Individuals who believe their personal information has been processed contrary to applicable Kenyan data protection law may raise the matter with ASOK for investigation.

Individuals also have the right to lodge a complaint with the Office of the Data Protection Commissioner (ODPC), Kenya.

Visit: www.odpc.go.ke

25. Governing Law

This Privacy & Data Protection Statement is primarily governed by the laws of the Republic of Kenya, including the Data Protection Act, 2019 and applicable regulations made under it.

Where ASOK activities involve individuals in other jurisdictions, additional data protection requirements may apply where required by relevant law.