Privacy Policy
Last updated 11/12/2024
- Who we are
Eighty-Eight Nairobi Limited is the developer and proprietor of the tallest residential building in Africa, boasting luxurious amenities and breathtaking views. Standing at a height of 150 meters with 48 floors, this iconic tower features the highest quality finishes and designs.
Nestled in the heart of Upper Hill on 4th Ngong Avenue, lies the magnificent 88 Nairobi, an iconic 47-storey residential tower that embodies modern international design. Considered Nairobi’s premier luxury residential building, it features a prime and premium location that offers proximity to every essential amenity. Boasting the title of Africa’s tallest luxury residential tower, each of the ultra-modern serviced apartments within 88 Nairobi offers a breathtaking panoramic view of Nairobi’s pulsating city and the distant African horizons, perched high above Upper Hill and the City Center.
When we say ‘we’, ‘our’, ‘us’ or ’Eighty Eight Nairobi Limited’ in this policy, we are referring to all or any of the entities or which are affiliated to Eighty Eight Nairobi Limited, as the context requires.
- Privacy
We take your privacy seriously. Please read this privacy notice carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a request or a complaint.
We collect, use, analyse, store, and share your personal data in compliance with the Kenyan Data Protection Act, 2019 and all other laws that may govern our handling of your personal data.
When you visit our websites www.88nairobi.com and www.88nairobienhanced.com (the “Websites“) or our social media pages, use any of our services (the “Services“, which include the Websites), in a contractual engagement with us, or any other engagement , we appreciate you for trusting us with your personal information.
- Key terms
It would be helpful to start by explaining some key terms used in this notice:
| We, us, our | Eighty Eight Nairobi Limited, together with any trading name or names that may be more familiar to you and our group of companies. |
| Personal Data | Any information that may identify you directly or may be used to identify you. |
| Sensitive Personal Data | Data revealing your race, health status, ethnic social origin, conscience, belief, genetic data, biometric data, property details, marital status, family details including names of your children, parents, spouse or spouses, sex or your sexual orientation. |
| Data Controller | Eighty Eight Nairobi Limited, together with any trading name or names that may be more familiar to you and our group of companies which, alone or jointly with others, determines the purpose and means of processing of your personal data. |
| Data Processor | Means a natural or legal person, public authority, agency or other body which processes personal data on behalf of Eighty Eight Nairobi Limited, together with any trading name or names that may be more familiar to you and our group of companies. |
| Data Subject | Individual from whom we collect personal data. These include our:employees, consultants,suppliers, clients, users of our digital platforms, and attendees of our events. |
- Personal data we collect about you
The personal data we collect about you depends on the products or services we provide to you or the nature of contractual relationship between you and ourselves. We may collect and use the following personal data about you depending on our interactions with you:
| Personal Data: | Details: |
| Contact details | First name, surname, username, title, user ID, postal address, physical address, billing address, email address, office phone, cell phone number, Next of Kin details, and contacts for emergencies |
| Individual details | Sex, photo, nationality, date of birth, age, language, academic qualifications, employment history, reference checks, marital status, professional qualifications, child(ren) details in case of insurance dependent |
| Identification details | National identification number, passport number, driving license details, professional association number, National Health Insurance number, National Social Security Fund number, KRA PIN |
| Financial information | Financial history and well-being, pay details, pension details, tax details, bank details, insurance details, billing details. |
| Credit risk and anti-fraud details | Information which we may collect to assess the risk in providing a service or seeking your services. |
| Sensitive personal data | Sensitive personal data that we collect requires additional layers of protection which we have put in place as required under the Kenyan Data Protection Act. Sensitive personal data that we may collect from you includes data revealing your race, health status, ethnic social origin, conscience, belief, genetic data, biometric data, property details, marital status, family details including names of your children, parents, spouse or spouses, your sex or the sexual orientation |
| Website cookie data | Information stored on your device’s web browser while browsing our websites, digital platforms, and social media pages. |
- How your personal data is collected
We collect personal data directly from you—in person, by telephone, text or email or via our digital and social media platforms. However, we may also collect information:
- from publicly accessible sources, such as Business Registration Services (BRS) or Land Registry,
- directly from a third party, such as credit reference agencies, customer due diligence providers,
- from a third party with your consent, such as your bank, your employer, referee, your former employer, your insurance company,
- from cookies on our website—for more information on our use of cookies, please see our ‘Cookies Policy’ below,
- via our IT systems:
- from door entry systems and reception logs; or
- through automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems.
- How and why, we use your personal data
Under the Kenyan data protection law, we can only use your personal data if we have a proper lawful reason or basis
- where you have given consent,
- to comply with our legal and regulatory obligations,
- public interest
- for the performance of a contract with you or to take steps at your request before entering into a contract, or
- for our legitimate interests for those of a third party.
The table below explains what we use your personal data for and why.
| Lawful basis for processing your personal data | Our Activity |
| Consent | Any freely given specific, informed, and unambiguous indication of your wishes with regards to processing of your personal data. We will expressly require your consent before we process your sensitive personal data and, in the event we wish to process your personal data for a commercial purpose. |
| Contract | We will process your personal data in relation to the performance of a contract or agreement between you and ourselves. Such contract may include employment contract, service contract, consultancy contract, joint venture contract, tenancy agreement, or supply contract. |
| Legal obligation | It is where the processing is necessary to comply with the law and regulatory oversight. Relevant laws may include laws on taxation, social security, insurance, banking, anti-money laundering, fraud prevention, employment, cyber regulation, data protection, intellectual property, health, construction, land use and planning, estate management, and regulation of professionals. |
| Vital interest | It implies the protection of your life such as in a health emergency. |
| Legitimate interest | Where the processing is necessary for our legitimate interests, such as where we collect data analytics to improve our digital platforms, services, and marketing activities. Our legitimate interests also include prevention and detection of fraud, protection of our intellectual property and trade secrets, compliance with our internal policies, and providing a safe environment for our data subjects. Our legitimate interests also includes research and development of new products and services. |
- Marketing
We may use your personal data to send you updates by email, text message, telephone or post about our products and services, including exclusive offers, promotions or new products and services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not always need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by using the ‘unsubscribe’ link in emails or ‘STOP’ sending an email to dpo@lordshipafrica.com
We will always treat your personal data with the utmost respect and never sell it to other organisation or entity.
- Who we share your personal data with
Any disclosure of your personal data shall be in accordance with applicable law and regulations. We shall assess and review each application for personal data and may decline to grant such information to the requesting party.
We may share personal data with:
- companies within our affiliates or group of companies.
- Statutory institutions, law enforcement agencies, regulatory authorities, courts or other statutory authorities in response to a demand issued with the appropriate lawful mandate and where the form and scope of the demand is compliant with the law;
- Law enforcement agencies as provided for in law and in compliance with set out statutory procedures.
- Third parties for the purposes listed above such as lawyers, banks, insurance companies, pension funds, auditors, consultants, security companies who provide services such as consultancy, banking, legal, marketing, accounting, auditing, pension, web development, and security services.
- Debt collection agencies or other debt recovery organisations.
- Other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised, but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.
We may also disclose your data:
- Where we have a duty or a right to disclose as required by law, and
- Where we believe it is necessary to protect our rights.
We only allow those organisations to handle your personal data if we are satisfied that they take appropriate measures to protect your personal data. We also impose contractual obligations on them to ensure they can only use your personal data to provide services to us and to you.
- Cookies Policy
Our website uses cookies to distinguish you from other users and to improve your experience when accessing this site.
- What is a cookie?
Cookies are small data files that your browser places on your computer or device. Cookies help your browser navigate a website and the cookies themselves cannot collect any data stored on your computer or your files. When a server uses a web browser to read cookies they can help a website deliver a more user-friendly service. To protect your privacy, your browser only gives a website access to the cookies it has already sent to you.
- Why do we use cookies?
We use cookies to learn more about the way you interact with our content and help us to improve your experience when visiting our website. Cookies remember the type of browser you use and which additional browser software you have installed. They also remember your preferences, such as language and region, which remain as your default settings when you revisit the website.
Cookies also allow you to rate pages and fill in comment forms. Some of the cookies we use are session cookies and only last until you close your browser, others are persistent cookies which are stored on your computer for longer. Below is a list of the cookies we use:
- Sessions Cookies: temporary cookies that are deleted once you exit your browser.
- Persistent Cookies: these remain in your device for a defined period of time or until you delete them.
- First-Party Cookies: set by our website or digital platforms.
- Third Party Cookies: set by domains other that our website or digital platforms and are often used for advertising, tracking and statistical purposes.
Information that cookies contain includes your IP address, the fact that you have viewed our website, your social media handles, the links you click, and the information you share while interacting with our website or social media platforms.
- How are third party cookies used?
For some of the functions within our websites we use third party suppliers, for example, when you visit a page with videos embedded from or links to other platforms. The videos or links (and any other content from third party suppliers) may contain third party cookies and you may wish to consult the policies of these third-party websites for data regarding their use of cookies.
- How do you manage, reject and delete cookies?
We shall not use cookies to collect personally identifiable data about you. However, should you wish to do so, you can choose to manage, reject or block the cookies set by the websites of any third-party suppliers by changing your browser settings or our sites cookie settings. Note that if you reject the use of cookies, you shall still be able to visit our websites but some of the functions may not work correctly.
- Where your personal data is held
Personal data may be held at our premises and those of our group of companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).
Some of these third parties may be based outside Kenya with adequate data protection safeguards.
For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of Kenya]’.
- How long your personal data will be kept
We will not keep your personal data for longer than we need it for the purpose for which it is used, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
- Transferring your personal data out of Kenya
Kenya has differing data protection laws with other countries, some of which may provide lower levels of protection of privacy.
It is sometimes necessary for us to transfer your personal data to countries outside Kenya. In those cases, we will comply with applicable Kenyan laws designed to ensure the privacy of your personal data.
We will transfer your personal data to our service providers located outside Kenya (our Server Providers and Cloud Storage Providers).
We will only transfer your personal data to a country outside Kenya where:
- the data controller or data processor has given proof on the appropriate safeguards with respect to the security and protection of your personal data,
- you have given explicit consent to the proposed transfer, after having been informed of the possible risks of the transfer such as the absence of appropriate security safeguards, or
- the transfer is necessary for performance of a contract.
Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.
- Your rights
You have the following rights in relation your personal data:
| Access | The right to be provided with a copy of your personal data |
| Rectification | The right to require us to correct any mistakes in your personal data |
| Erasure | The right to require us to delete your personal data which will be done in compliance with the Data Protection and Data Protection (General Regulations) |
| Restriction of processing | The right to require us to restrict processing of your personal data in certain circumstances, eg if you contest the accuracy of the data |
| Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party— which will be done in compliance with the Data Protection and Data Protection (General Regulations) |
| To object | The right to object:at any time to your personal data being processed for direct marketing (including profiling);in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims |
| Not to be subject to automated individual decision making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. |
| The right to withdraw consent | If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any timeWithdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn. |
For more information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below)
If you would like to exercise any of those rights, please:
- email, call or write to us—see below: ‘How to contact us’; and
- let us know what right you want to exercise and the information to which your request relates.
- Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures including firewall protections and encryption technologies to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
- How to make requests
Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
- Changes to this privacy policy
This privacy notice was published on 11/12/2024 and last updated on 11/12/2024.
We may change this privacy notice from time to time—when we do we will inform you via [insert mechanism for informing the data subject of changes to the notice, e.g. our website or other means of contact such as email].
- How to contact us
You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a request.
Our contact details are shown below:
| Our contact details |
|---|
| dpo@lordshipafrica.com |
You may also contact the Office of the Data Protection Commissioner in the remote case we have not dealt with your request to your satisfaction:
| Office of the Data Protection Commissioner |
|---|
| info@odpc.go.ke |
