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PRIVACY POLICY

THIS PRIVACY POLICY IS EFFECTIVE OCTOBER 2017.

Your use of this Seven Square Advisors Limited (together with its affiliates, "Seven Square" or "the Company") website operated from URL "www.sevensquareadvisors.com" and the information contained therein (including any password-protected sections, the "Website") is subject to the following terms and conditions as may be amended by Seven Square from time to time (these "Terms"). The Website is owned and operated by Seven Square.

BY USING THE WEBSITE, YOU SIGNIFY YOUR CONSENT TO ABIDE BY THE TERMS AND REGULATORY RESTRICTIONS HEREIN GOVERNING ITS USE. ON EACH OCCASION YOU ACCESS THE WEBSITE YOU WILL BE DEEMED TO HAVE ACCEPTED THESE TERMS. IF YOU DO NOT ACCEPT THESE TERMS, YOU MAY NOT USE THE WEBSITE. IF YOU DO NOT AGREE WITH ANY TERM OF THIS PRIVACY STATEMENT ("POLICY"), YOU MUST CEASE YOUR ACCESS OF THIS WEBSITE IMMEDIATELY.

1. Definitions and Interpretation

"Personal Information" means information or data relating to an identifiable, living, natural person and where it is applicable, identifiable, existing juristic person, including all information as defined under applicable law.

"Processing" means the creation, generation, communication, storage, destruction of personal information or data as may be defined under applicable law.

You" or the "user" means any person who accesses and browses this website for any purpose.

"Website" or "Site" means the website URL www.sevensquareadvisors.comor such other URL as Seven Square may choose from time to time.

"we"/ "us"/"our" means Seven Square, formally identified registered as Seven Square Advisors Limited, a limited company registered in Kenya under registration number CPR/2011/39769.

2. Status and Amendments

Seven Square understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and our obligations under the law.

This Policy applies to the use of any and all data collected by us in relation to your use of our Site. This Policy governs the processing of personal information provided to Seven Square through your use of our Site.

Please read this Policy carefully and ensure that you understand it. Your acceptance of this Policy is deemed to occur upon your first use of our Site. If you do not accept and agree with this Policy, you must stop using our Site immediately.

The date indicated above is the effective date that governs the browsing and use of this Policy from that date until the next revision of this Policy becomes effective.

You accept that it is your duty to remain appraised of the current version of this Policy.

Continuing to browse our Site or use this Privacy Policy after a revised/ new policy becomes effective constitutes your agreement to observe our Policy as stated/ amended.

3. Processing of Personal Information

By providing your personal information to Seven Square you acknowledge that it has been collected directly from you and consent to its processing by Seven Square.

Where you submit Personal Information (such as name, address, telephone number and email address) via the website (e.g. through completing any online form) the following principles are observed in the processing of that information:

- Seven Square will only collect personal information for a purpose consistent with the purpose for which it is required. The specific purpose for which information is collected will be apparent from the context in which it is requested.
- Seven Square will only process personal information in a manner that is adequate, relevant and not excessive in the context of the purpose for which it is processed.
- Personal information will only be processed for a purpose compatible with that for which it was collected, unless you have agreed to an alternative purpose in writing or Seven Square is permitted in terms of local laws generally applicable dealing primarily with the protection of personal information.
- Seven Square may keep records of all personal Information collected and the specific purpose for which it was collected for a period of 1 (one) year from the date on which it was last used.
- Seven Square will not disclose any personal information relating to you to any third party unless your prior written agreement is obtained or Seven Square is required to do so by law.
- If personal information is released with your consent Seven Square may retain a record of the information released, the third party to which it was released, the reason for the release and the date of release, for a period of 1 (one) year from the date on which it was last used.
- Seven Square will destroy or delete any personal information that is no longer needed by Seven Square for the purpose it was initially collected, or subsequently processed.

Pursuant to applicable legislation, Seven Square may use personal information collected to compile profiles for statistical purposes. No information contained in the profiles or statistics will be able to be linked to any specific user.

4. Collection of anonymous data

Seven Square may use standard technology to collect information about the use of this website. This technology is not able to identify individual users but simply allows Seven Square to collect statistics and use them for the purposes of improving Website functionality as well as informing you of our products and services.

Seven Square may utilise temporary or session cookies to keep track of users' browsing habits. A cookie is a small file that is placed on your hard drive in order to keep a record of your interaction with this Website and facilitate user convenience. Such cookies by themselves will not be used to identify users personally but may be used to compile data and specific statistics relating to use of services offered or to provide Seven Square with feedback on the performance of this website.

By using our Site, you may also receive certain third-party cookies on your computer or device. Third party cookies are those placed by websites, services, and/or parties other than us. We may use third party cookies on our Site for advertising and other purposes, however,these Cookies are not integral to the functioning of our Site.

Subject to applicable laws, the following forms of information may be collected in respect of users who have enabled cookies:
- Date and time of activities while visiting the website;
- URLs of internal pages visited;

- Name, date of birth, gender
- business/company name, job title, profession
- contact information such as email addresses and telephone numbers
- demographic information such as post code, preferences and interests
- financial information such as credit / debit card numbers
- IP address (automatically collected)
- web browser type and version (automatically collected)
- operating system (automatically collected)
- a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected)

If you do not wish cookies to be employed to customize your interaction with this Website it is possible to alter the manner in which your browser handles cookies. Please note that, if this is done, certain services or functions on this Website may not be available for your use or enjoyment.

5. Security

Seven Square takes reasonable measures to ensure the security and integrity of information submitted to or collected by this Website but shall not under any circumstances accept or be held liable for any loss or other damage sustained by you as a result of unlawful access to or dissemination of any personal information by a third party.

6. Links to other websites

Seven Squarehas no control over and accepts no responsibility for the privacy practices of any third-party websites to which hyperlinks may have been provided and Seven Square strongly recommends that you review the privacy policy of any website you visit before using it further.

7. Queries

If you have any questions about our Site or this Policy, please review our Cookie Policy and Legal Disclaimer which are available on this Site. Alternatively, you may contact us by email at info@sevensquareadvisors.com. Please ensure that your query is clear.

8. Changes to Our Privacy Policy

As stated above, we may change this Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on our Site and you will be deemed to have accepted the terms of this Policy and any other Policy stated on our Website upon your first use of our Site following any changes. We recommend that you check this Policy page regularly to keep up-to-date.