TLG Trade Policy Center

Privacy Policy

This policy explains how TLG Trade Ecommerce Limited collects, uses, and protects your personal information when you use our marketplace.

1. Introduction

Welcome to TLG Trade Kenya. TLG Trade Ecommerce Limited ("Company," "we," "us," or "our") is committed to protecting your personal data and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website (tlgtrade.com), use our mobile applications, or interact with our marketplace (collectively, the "Services").

This Privacy Policy is designed to comply with the Kenya Data Protection Act, 2019 (DPA) and other applicable data protection laws. By accessing or using our Services, you consent to the data practices described in this policy.

2. Information We Collect

We may collect several types of information from and about users of our Services, including:

  • Personal Identification Information: Name, email address, phone number, postal address, date of birth, and identity documents (especially for sellers during onboarding).
  • Account Data: Username, password, and profile preferences.
  • Financial Information: Payment card details, mobile money (e.g., M-Pesa) numbers, and billing addresses required to process transactions.
  • Transaction Data: Details about payments to and from you, and other details of products or services you have purchased from or sold through our sellers.
  • Technical Data: Internet Protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Usage Data: Information about how you use our website, products, and services.
  • Marketing and Communications Data: Your preferences in receiving marketing from us and our third parties, and your communication preferences.

3. How We Collect Your Data

We use different methods to collect data from and about you, including through:

  • Direct Interactions: You may give us your Identity, Contact, and Financial Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes data provided when you create an account, purchase products, subscribe to our publications, or request marketing to be sent to you.
  • Automated Technologies or Interactions: As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies.
  • Third Parties or Publicly Available Sources: We may receive personal data about you from various third parties such as payment gateways, delivery partners, and analytics providers (like Google Analytics).

4. Legal Basis for Processing

Under the Kenya Data Protection Act, 2019, we process your personal data under the following lawful bases:

  • Consent: You have given clear consent for us to process your personal data for a specific purpose (e.g., direct marketing).
  • Contract: The processing is necessary for a contract you have with us, or because you have asked us to take specific steps before entering into a contract (e.g., fulfilling an order).
  • Legal Obligation: The processing is necessary for us to comply with the law (not including contractual obligations).
  • Legitimate Interests: The processing is necessary for our legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect your personal data which overrides those legitimate interests.

5. How We Use Your Information

We use the information we collect for various purposes, including to:

  • Register you as a new customer or vendor.
  • Process and deliver your orders, including managing payments, fees, and charges.
  • Manage our relationship with you, which will include notifying you about changes to our terms or privacy policy, and asking you to leave a review or take a survey.
  • Administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data).
  • Deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
  • Use data analytics to improve our website, products/services, marketing, customer relationships, and experiences.
  • Prevent, detect, and mitigate fraud and other illegal activities.

6. Disclosure of Your Information

We may share your personal data with the parties set out below for the purposes set out in Section 5:

  • Vendors/Sellers: We share necessary order details (e.g., name, delivery address, phone number) with independent sellers on our platform so they can fulfill your orders.
  • Service Providers: Third-party companies that provide services such as payment processing (e.g., M-Pesa, IntaSend, credit card gateways), logistics and delivery, IT and system administration, and marketing support.
  • Professional Advisers: Including lawyers, bankers, auditors, and insurers based in Kenya or elsewhere who provide consultancy, banking, legal, insurance, and accounting services.
  • Legal and Regulatory Authorities: Where required by law or to respond to legal process (such as a subpoena, warrant, or court order), or to protect our rights or the rights of our users.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes.

7. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and the Office of the Data Protection Commissioner (ODPC) of a breach where we are legally required to do so.

8. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

9. Your Legal Rights

Under the Kenya Data Protection Act, 2019, you have the following rights regarding your personal data:

  • Right to be Informed: To know the use to which your personal data is to be put.
  • Right to Access: To request access to your personal data.
  • Right to Object: To object to the processing of all or part of your personal data.
  • Right to Rectification: To request correction of false or misleading data.
  • Right to Erasure: To request deletion of false or misleading data about you.
  • Right to Data Portability: To receive personal data concerning you in a structured, commonly used, and machine-readable format.

If you wish to exercise any of the rights set out above, please contact us using the details provided below. You can also export or request deletion of your data directly from your Account Dashboard.

10. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service. For more details, please see our Terms & Conditions.

11. Changes to the Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "updated" date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes.

12. Contact Details

If you have any questions about this Privacy Policy or our privacy practices, please contact us:

You have the right to make a complaint at any time to the Office of the Data Protection Commissioner (ODPC) in Kenya. However, we would appreciate the chance to deal with your concerns before you approach the ODPC, so please contact us in the first instance.