1. Introduction
Joly General Trading Company Ltd (“Joly”, “we”, “us” or “our”) respects your privacy and is committed to protecting the personal information and data you provide when using our website,
www.jolytrading.com. This Privacy Policy explains how we collect, use, store, protect and disclose information when you visit or interact with our website and services.
By using this website, you acknowledge that you have read and understood this Privacy Policy. Where applicable, we will obtain your consent before processing your personal data for purposes for which consent is legally required.
2. About Joly General Trading Company Ltd
Joly General Trading Company Ltd is a diversified trading and business enterprise headquartered in Nairobi, Kenya, with operations and business interests across East Africa, including Kenya, Uganda, Rwanda, the Democratic Republic of Congo and South Sudan.
Our business activities include distribution, logistics, education, retail, hospitality, real estate, financial services, manufacturing and other trading and investment activities.
3. Information We Collect
When you use our website, we may collect personal information and technical information relating to your use of the website. The information collected depends on how you interact with our website and the features you use.
Information may include:
- Your name;
- Email address;
- Telephone or mobile number;
- Company or organisation name;
- Job title or position;
- Business or postal address;
- Information contained in enquiries, messages or other communications you send to us;
- Information submitted through website forms;
- Information provided when requesting our products or services;
- Information provided through business, supplier, partnership or recruitment enquiries;
- IP address;
- Browser type and version;
- Device type and operating system;
- Pages visited and content viewed;
- Date and time of website visits;
- Referring website or source;
- General website usage and interaction information;
- Cookie and similar technology information; and
- Other information that you voluntarily provide to us.
4. Information Collected Through Website Forms
When you voluntarily submit information through a contact form, enquiry form, recruitment form or any other form on our website, we may collect the information you provide in order to respond to your request, provide the requested service or information, communicate with you, assess a business enquiry or otherwise handle the purpose for which the information was submitted.
Please do not submit passwords, payment card details, identity documents or sensitive personal information through a general website form unless we specifically request such information through an appropriate and secure process.
5. How We Use Your Information
We may use the information we collect for legitimate business, operational, legal and administrative purposes, including:
- Responding to enquiries and requests;
- Communicating with customers, suppliers, partners and other stakeholders;
- Providing information about our products, services and business activities;
- Managing business and commercial relationships;
- Processing supplier, partnership and business enquiries;
- Processing recruitment or employment enquiries where applicable;
- Providing and administering services;
- Improving our website, products, services and user experience;
- Understanding how visitors use and interact with our website;
- Measuring website traffic and performance;
- Maintaining website functionality and security;
- Detecting and preventing fraud, abuse, spam and unauthorised access;
- Maintaining appropriate business and administrative records;
- Complying with applicable laws, regulations and legal obligations;
- Establishing, exercising or defending legal claims; and
- Protecting the rights, property, safety and legitimate interests of Joly, our customers, employees, partners and other persons.
6. Lawful Basis for Processing Personal Data
Where applicable, we process personal data on one or more lawful grounds recognised under applicable data protection legislation.
These may include:
- Consent: where you have given us permission to process your personal data for a specified purpose;
- Contractual necessity: where processing is necessary to enter into or perform a contract with you;
- Legal obligation: where processing is necessary to comply with a legal or regulatory requirement;
- Legitimate interests: where processing is necessary for a legitimate business purpose and those interests are not overridden by your rights and freedoms; and
- Other lawful grounds: where processing is permitted under applicable data protection legislation.
Where we rely on consent, you may withdraw your consent at any time, subject to any legal or contractual limitations that may apply.
7. Cookies and Similar Technologies
Our website uses cookies and similar technologies to support website functionality, security, analytics, advertising, embedded content and the overall performance of the website.
Cookies are small files or identifiers that may be stored on your device when you visit a website.
The technologies used on our website may collect information such as your IP address, device information, browser information, pages visited, interactions with website content, approximate location information, referring source and information about how you interact with the website.
Depending on the technology involved, cookies and similar technologies may be used for essential website functionality, analytics, advertising, security, performance measurement and other legitimate purposes.
8. Google Analytics
We use
Google Analytics to help us understand how visitors use our website and to measure website traffic, engagement and performance.
Google Analytics may collect information such as your IP address, device and browser information, pages visited, approximate geographic information, referral information, interactions with the website and other usage data.
The information collected through Google Analytics may be processed by Google in accordance with Google’s applicable privacy policies and terms.
For more information about how Google processes information, please refer to
Google’s Privacy Policy.
9. Google Tag Manager
We use
Google Tag Manager to manage and deploy certain website tags and technologies.
Google Tag Manager itself is primarily a tag management system; however, tags and services deployed through it may collect and process information about website visitors.
The specific information collected through tags managed by Google Tag Manager depends on the technologies and configurations implemented on the website.
For more information about Google’s privacy practices, please refer to
Google’s Privacy Policy.
10. Meta Pixel
Our website uses the
Meta Pixel, a technology provided by Meta Platforms, Inc., to help us understand website activity, measure the effectiveness of our advertising and marketing activities, and understand interactions with our website.
The Meta Pixel may collect information such as information about your browser and device, pages visited, actions taken on the website, IP address and other information associated with your interaction with the website.
Information collected through the Meta Pixel may be transmitted to and processed by Meta in accordance with Meta’s applicable privacy policies and terms.
For more information, please review
Meta’s Privacy Policy.
11. Google reCAPTCHA
We use
Google reCAPTCHA on certain areas of our website to help protect forms and other website functionality from spam, abuse and automated activity.
reCAPTCHA may collect information about your device, browser, IP address, interactions with the website and other technical information necessary to assess whether activity is generated by a human user or an automated system.
The use of reCAPTCHA is subject to Google’s applicable terms and privacy practices.
For more information, please refer to
Google’s Privacy Policy and
Google’s Terms of Service.
12. YouTube Embedded Content
Our website may contain embedded videos provided by
YouTube, a service operated by Google.
When you view a page containing an embedded YouTube video, YouTube and Google may collect information about your device, browser, IP address and interaction with the embedded content.
Depending on how the YouTube service is configured and whether you interact with the embedded content, cookies or similar technologies may be used.
YouTube’s processing of information is governed by Google’s applicable privacy policies and terms.
For more information, please refer to
Google’s Privacy Policy.
13. Google Maps
Our website may use
Google Maps or related Google mapping services to display maps, locations or directions.
When a Google Maps feature is loaded or used, Google may collect technical information and information relating to your interaction with the map service. Depending on the functionality used, this may include IP address, device information, location-related information and usage data.
Google’s processing of this information is governed by its applicable privacy policies and terms.
For more information, please refer to
Google’s Privacy Policy.
14. Third-Party Services and Data Processors
Our website is hosted using third-party hosting services. As a result, information submitted to or generated through the website may be processed or stored on systems operated by third-party service providers.
We may also use third-party providers for website hosting, security, analytics, advertising, communications, embedded content, technical support and other website-related services.
These third parties may process personal data on our behalf or independently process information under their own privacy policies.
Where a third party processes personal data on our behalf, we take reasonable steps to ensure that the processing is governed by appropriate contractual, technical and organisational safeguards as required by applicable law.
15. Sharing of Personal Data
We may share personal data where necessary for legitimate business, operational or legal purposes.
Depending on the circumstances, information may be shared with:
- Authorised employees and representatives of Joly;
- Subsidiaries and affiliated companies;
- Website hosting and technology providers;
- Analytics and advertising service providers;
- Professional advisers;
- Suppliers, contractors and service providers;
- Business partners where disclosure is necessary and lawful;
- Financial institutions where necessary for legitimate transactions;
- Government authorities, regulators or law-enforcement agencies where required;
- Courts, tribunals or other lawful authorities; and
- Other parties where disclosure is authorised or required by law.
We do not sell your personal data.
We will not disclose personal data to third parties simply because they request it. Any disclosure will be based on a lawful purpose and, where required, appropriate safeguards or consent.
16. International and Cross-Border Transfers
Because Joly operates across multiple countries and uses international technology and service providers, personal data may be accessed, transferred or processed outside Kenya or outside the country where the information was originally collected.
Where personal data is transferred outside the applicable jurisdiction, we will take reasonable steps to ensure that the transfer complies with applicable data protection requirements and that appropriate safeguards are in place.
Where required by applicable law, international transfers may be based on an adequacy decision, appropriate safeguards, a lawful necessity for the transfer, explicit consent or another legally recognised basis.
17. Data Security
We take reasonable technical and organisational measures designed to protect personal data against unauthorised access, disclosure, loss, misuse, alteration, destruction and other unlawful processing.
These measures may include access controls, authentication controls, security monitoring, secure communications, system maintenance, backups, organisational procedures and other safeguards appropriate to the nature and sensitivity of the information.
However, no website, electronic transmission, information system or storage method can be guaranteed to be completely secure. You should therefore take reasonable precautions when communicating information online.
18. Data Retention
We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, unless a longer period is required or permitted by law.
The applicable retention period may depend on the nature of the information, the purpose for which it was collected, our relationship with you, legal and regulatory requirements, contractual obligations, accounting and audit requirements, dispute resolution and legitimate business requirements.
When personal data is no longer required, we will take reasonable steps to delete, anonymise or securely dispose of it in accordance with applicable law and our data retention practices.
19. Your Data Protection Rights
Subject to applicable law and any lawful limitations, you may have the right to:
- Be informed about how your personal data is collected and used;
- Request access to personal data that we hold about you;
- Request correction of inaccurate, incomplete, outdated or misleading personal data;
- Request deletion or erasure of personal data in circumstances permitted by law;
- Object to certain processing of your personal data;
- Request restriction of processing in circumstances permitted by law;
- Request portability of your personal data where applicable;
- Withdraw consent where processing is based on consent; and
- Lodge a complaint with the relevant data protection authority.
20. How to Exercise Your Rights
You may exercise your applicable data protection rights by contacting us using the details provided in the
Contact Us section of this Privacy Policy.
To help us process your request, we may ask you to provide sufficient information to identify you and verify that the request relates to your personal data.
We may also need to request additional information where reasonably necessary to protect personal data from unauthorised disclosure.
We will respond to valid requests within the timeframes required by applicable law.
21. Direct Marketing
Where permitted by law, we may use personal data to communicate with you about our products, services, business activities, events or other information that may be relevant to you.
Where consent is required for direct marketing, we will obtain the appropriate consent before sending such communications.
You may opt out of direct marketing communications at any time by contacting us or by using the unsubscribe mechanism provided in the relevant communication.
An opt-out from marketing communications will not necessarily prevent us from sending important service-related, transactional, legal or administrative communications.
22. Children’s Privacy
Our corporate website is primarily intended for businesses, customers, suppliers, partners, professionals and members of the general public seeking information about Joly and its activities.
We do not knowingly collect personal data from children through general website forms unless such collection is necessary for a legitimate purpose and is carried out in accordance with applicable law and appropriate safeguards.
Where personal data is processed in connection with education-related activities operated by Joly or its affiliated entities, additional privacy requirements and safeguards may apply.
23. Third-Party Websites
Our website may contain links to websites, platforms or services operated by third parties.
These websites are not controlled by Joly and may have their own privacy policies, terms and data-processing practices.
We are not responsible for the privacy practices, content or security of third-party websites. We encourage you to review the privacy policy of any third-party website before providing personal information.
24. Social Media and External Platforms
Joly may use social media platforms and other third-party digital services to communicate with customers, partners and members of the public.
When you interact with us through these platforms, the relevant platform may independently collect and process your personal data under its own privacy policy and terms.
Your use of those platforms is therefore also subject to the privacy policies and terms of the relevant third-party provider.
25. Recruitment Information
Where our website or related digital channels allow you to submit employment or recruitment information, we may process the information you provide for recruitment, assessment, communication, verification and related employment purposes.
Recruitment information may include your name, contact information, CV or résumé, education, employment history, qualifications and other information that you voluntarily provide for recruitment purposes.
Such information will be accessed only by authorised personnel and service providers where necessary and lawful.
Recruitment information will be retained only for as long as reasonably necessary for the relevant recruitment process, future recruitment consideration where permitted, legal obligations or legitimate business purposes.
26. Data Breaches
We maintain reasonable procedures for identifying, investigating, containing and responding to personal data breaches and security incidents.
Where a personal data breach is subject to notification requirements under applicable law, we will take the necessary steps to notify the relevant regulatory authority and affected individuals within the applicable legal timeframes.
Where Kenyan data protection law applies, qualifying personal data breaches will be handled in accordance with the notification requirements under the Data Protection Act, 2019 and applicable regulations.
27. Data Protection by Design and Default
We seek to incorporate privacy and data protection considerations into the design, development and operation of systems and processes that involve personal data.
Where appropriate, we consider the amount of personal data collected, the purposes for which it is processed, access controls, retention periods, security risks and other safeguards.
28. Automated Decision-Making and Profiling
Our corporate website is not intended to make decisions about individuals solely through automated processing unless such processing is implemented in accordance with applicable law.
If automated decision-making or profiling that produces legal or similarly significant effects is introduced, we will implement the safeguards and provide the information required by applicable law.
29. Accuracy of Personal Data
We take reasonable steps to ensure that personal data we hold is accurate, complete and up to date where necessary for the purposes for which it is processed.
If you believe that personal information we hold about you is inaccurate, incomplete or outdated, you may contact us and request that it be corrected.
30. Complaints
If you have a concern about how we have collected, used or otherwise processed your personal data, we encourage you to contact us first so that we can investigate and attempt to resolve your concern.
If you are in Kenya and remain dissatisfied with the way your personal data has been handled, you may have the right to lodge a complaint with the
Office of the Data Protection Commissioner (ODPC).
More information about the ODPC and its complaints process is available at
https://www.odpc.go.ke/.
31. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes to our business activities, website functionality, technology, data-processing practices or applicable legal and regulatory requirements.
When we make changes, the updated version will be published on this page.
We encourage you to review this Privacy Policy periodically to remain informed about how we process personal data.
32. Contact Us
If you have questions about this Privacy Policy, wish to exercise your data protection rights, or have a concern about how your personal data is being processed, please contact us:
Joly General Trading Company Ltd
Regional Headquarters: Nairobi, Kenya
Email: [info@jolytrading.com](mailto:info@jolytrading.com) Telephone: +254 701 570 356 / +256 778 060 333
Website: [www.jolytrading.com](http://www.jolytrading.com)
Regional Offices: Uganda | Kenya | Rwanda | DRC
