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Privacy Policy

Privacy Policy



Welcome to privacy notice. respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our site and tell you about your privacy rights and how the law protects you.

This privacy notice aims to give you information on how collects and processes your personal data through your use of this Site, including any data you may provide through this Site when you sign up to our Site, browse or send a notification via our Site, enter a competition or engage with us on our Site or through emails you may receive from us or to the Vendor and clients.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. 



It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.



Rudisha Online Limited is the controller and responsible for your personal data (collectively referred to as "“", "”, “we", "”, “us"” or "“our"” in this privacy notice).




Full name of legal entity: Rudisha Online Limited

Email address:

Postal address: P.O.Box 34021 - 8011041228 – 80100 , Mombasa , Kenya


This version was last updated for January 2021. This policy may change and be updated from time to time. Please check back regularly.

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



This Site includes links to third-party Sites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party Sites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy notice of every website you visit.


Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:


  1. Profile Data:  includes your username and password, purchases or orders made by you, your interests, preferences, survey responses & feed backs.
  2. Identity Data: includes first name, Surname, username or similar identifier, marital status, title, date of birth and gender.
  3. Financial Data : includes bank account and payment card details.
  4. Transaction Data includes details about notification from you to retailers featured on our Site from time to time and other details of products and services you have purchases from such retailers via our Site.
  5. Contact Data : includes billing address, delivery address and email address..
  6. Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  7. Usage Data: includes information about how you use our Site, products and services.
  8. Technical Data: includes 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 Site. 


We also use, collect and share Aggregate Data such as demographic or statistical data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not indirectly or directly reveal your identity. However, if we combine Aggregate Data with your personal data so that it can directly or indirectly identify you. We treat this combination data as personal data which will be used in accordance with this privacy policy.


Except in limited circumstances which will be made clear to you, we do not collect any Special Categories of Personal Data about you. (This will includeincludes details care, ethnicity, sex life, political opinions, religions, trade union membership, health and genetic and biometric data) Nor do we collect any information about criminal convictions and offences.


Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the cashback service). In this case, you will not be able to join



We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:


  • Where we need to perform the contract, we are about to enter into or have entered into with you.
  • 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.




We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.




There are different methods we collect out data from and about you:- 


Direct interactions: You may give us your Identity, Contract, Transaction or Financial Data by filing in forms or by corresponding with our post, email or otherwise. This includes personal data you provide when you:  

  • create an account on our Site;
  • submit a claim or enquiry about a transaction via our Site;
  • enter a competition, promotion or survey;
  • give us some feedback; or


Automated interactions or technologies: - As you interact with our Site, we may automatically collect Technical Data about your browsing actions, patterns and equipment. The data is collected using server logs, cookies and other technologies. We also may receive Technical Data about you if you visit other sites employing our cookies. Please visit our Cookie Policy for more information. Navigating our site, we may collect Profile Data, Usage Data and Marketing and Communications Data as specified by you from time to time.


Essential Third parties.  In order to facilitate the cashback service, we need to receive personal data about you from various third parties as set out below:
Technical, Transactional, Identity and Contact Data from the following parties:

  • Retailersretailers featured on the Site from time to time; and 

On data matching providers (where you have subscribed to our cashback service).

  • To help improve the service we provide and the functionality of our Site we may receive personal data about you from various third parties as set out below:

  • 1) Contact Data received from third parties who operate our Broadband Comparison Tool.
  • 2) Technical Data from analytics providers such as Google;
  • 3) Profile Data in the form of a mosaic profile;
  • 4) Contact and Technical Data where you join our Site as a result of our marketing activities involving third parties; and

What is a legitimate interest?

Legitimate Interest  means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience on our Site. 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). 


Performance of Contract  means processing your data where it is necessary for the performance of a contract to which you are a party. If you fail to provide personal data that we require for the performance of a contract with you we cannot enter into a contract with you for the provision of our services.

  1. Provide our cashback service to you. This includes but is not limited to:
  • Processing and facilitating any cashback due to you
  • Subscribing to the 'online'‘online’ service
  • Using our 'Scan‘Scan code and Save'Save’ feature
  • Managing payments from your account 
  • Processing of missing cashback payments (once received from networks)


Answering and processing any claims or enquiries you may raise with us including:

  • submission and actioning of any enquiry from you
  • submission of a claim for missing cashback
  • contesting claims
  • escalating and formal complaints, in order to ensure your cashback process runs smoothly, provide any assistance with the Site and challenge and defend any claims or actions which may be detrimental to our business and performance of a contract with you

Type Of Data:  (1) Identity   (2) Transaction    (3) Financial       (4) Contact


  1. Answering and processing any claims or enquiries you may raise with us including:
  • submission and actioning of any enquiry from you
  • submission of a claim for missing cashback
  • contesting claims
  • escalating and formal complaints, in order to ensure your cashback process runs smoothly, provide any assistance with the Site and challenge and defend any claims or actions which may be detrimental to our business.

detrimental to our business.


Necessary for our legitimate Interests to provide the most effective service to the members and for evidential purposes in the event of a dispute.


Type Of Data:  (1) Identity   (2) Transaction   (3) Contact


  1. Utilising fraud prevention measures in order to protect the business, members and retailers featured on the Site from fraudulent activity and any resulting consequences. Necessary for our legitimate interests to prevent fraud.

Necessary for our legitimate interests to prevent fraud.


Type Of Data: 1) Identity    (2) Contact    (3) Transaction    (4) Technical     (5) Profile


  1. Managing our relationship with you, for example:
  • Notifying you about changes to our terms or privacy policy
  • Updating your details on our system, 
  • validating a pay-out request or resetting a security question in order to keep our records updated.


Necessary for our legitimate interests of updating customer details and preferences.


Type of Data: (1) Identity  (2) Contact  (3) Profile  (4) Marketing and Communications  (5) Technical


  1. Promoting features on the Site, such as:
  • enabling you to partake in a prize draw, competition or complete a survey
  • when you provide case studies for use in the media

in order to study how customers, use the products and services on Site;


to keep our records updated and to promote engagement with the Site; and 

to promote third party retailers on the Site in order to illustrate to the members that we are one of a cashback site.


Necessary for our legitimate interests of promoting the Site and building our brand and Communications


Type of Data: (1) Identity  (2) Contact  (3) Profile  (4) Usage  (5) Marketing


  1. Carrying out marketing campaigns to attract new members. To do this, we use different channels of lead generation.


Social Media marketing

We like to market the Site to new or existing members.

In order to ensure our marketing is appropriate and relevant, we find ways of ensuring any marketing promotions are targeted at the right people.

In order to do this, we may share your data with large social media pages to ensure our marketing reaches the target audience.


Lead generation campaigns

If you join our Site as a result of being redirected from a third party site, we may pay the referrer a commission. In order to do this, we share data with affiliate networks and tracking agencies in order to calculate and pay any commission due.


Pay per click

If you join our Site as a result of clicking on our webpage from a search engine such as Google or Bing, this will be tracked by a third party. Your data will be shared between us and the third party tracking company in order to calculate how many new members have joined the Site and how much commission is due.


Necessary for our legitimate interests to engage in marketing activities.


Type of Data: (1) Contact (2) Technical  (3) Marketing and Communications


  1. To administer and protect our business and this Site such as:
  • troubleshooting
  • data analysis
  • testing
  • system maintenance
  • support
  • reporting and hosting of data<
  • in order for the efficient running of the Site, provision of administration and IT services, network security and in the context of a business reorganisation or group restructuring exercise. 

Necessary for our legitimate interests of Site security


Type of Data:  (1) Identity  (2) Contact  (3) Technical  (4) Financial  (5)Transactional

  1. Providing business insight into how members use the Site. We do this by:


  • delivering relevant Site content and advertisements to you and by measuring or understanding the effectiveness of the advertising we serve to you 
  • using data analytics 
  • making suggestions to you about goods or services that may be of interest to you 
  • for the use of web analytics, profiling and personalisation in order to study how customers use our services, to develop them, to grow our business and to ensure our marketing strategy is as relevant and accurate as possible.


Necessary for our legitimate interests in order to produce the most effective Site and member experience.


Type of Data  (1) Identity  (2) Contact  (3) Profile  (4) Usage  (5) Marketing & Communications  (6) Technical




We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).


You will receive marketing communications from us if you have signed up to our Site and you have not opted out of receiving marketing emails.


We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Within your account you can view and make certain decisions about your personal data use in relation to marketing emails.



We will never sell your personal data to any company outside RudishaOnlineRudisha online Limited for marketing purposes. As referred to above, we may share your Contact or Identity Data with certain third parties e.g. sub-processors to facilitate the delivery of marketing emails to you and social media publishers, in order to ensure our marketing is targeted at and relevant to Rudisha online members.



You can ask us to stop sending you marketing emails at any time by logging into your account on the Site and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing email sent to you.



You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Site will become inaccessible or not function properly resulting in your cashback not tracking. For more information about the cookies we use, please see our Cookie Policy. Cookie Policy.




We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.


Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.



We may have to share your personal data with the parties set out below for the purposes set out in the table above.

  1. (a) External Third Parties as set out.


  1. 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 notice.


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 and only permit them to process your personal data for specified purposes and in accordance with our instructions.



We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised 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 any applicable regulator of a breach where we are legally required to do so.



We will retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data.

In some circumstances we may 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.



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

  • You have the right to:

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 overrides 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: (a) if you want us to establish the data'sdata’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.


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.


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.



You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.



We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.



We try to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.