Spice Without Borders operates with a commitment to responsible and transparent handling of personal information. Our data protection practices are informed by:

• The Kenya Data Protection Act, 2019.
• The EU General Data Protection Regulation (GDPR), where applicable.
• Other applicable national and international data protection laws.

This Privacy Policy applies to personal information collected through our websites, programs, applications, nominations, events, digital platforms, communications, and other services operated or administered by SWOB and the Spicy Awards.

Spice Without Borders (SWOB)

P.O. Box 8512 – 30100
Eldoret, Kenya

Email:

info@spicewithoutborders.org

Spicy Awards is a program operated under Spice Without Borders and follows the same applicable data protection standards.

Where applicable under the GDPR, Spice Without Borders acts as the Data Controller for personal information collected through its programs, websites, and services.

We collect personal and non-personal information that is necessary to support our mission, administer programs, enable participation, communicate with our community, and improve our services.

3.1 | Information You Provide Directly

Depending on how you interact with us, we may collect:

• Full name and contact details.
• Location and demographic information.
• Applications, nominations, registrations, surveys, and forms.
• Photographs, biographies, CVs, professional profiles, and uploaded content.
• Feedback, inquiries, correspondence, and other communications.
• Social media identifiers that you voluntarily provide.
• Event registration and participation information.
• Donation and payment information where applicable.

Some information may be required in order to process an application, nomination, registration, transaction, or other requested service.

3.2 | Content You Upload or Submit

You may voluntarily submit photographs, videos, comments, profiles, biographies, stories, testimonials, applications, nominations, or other materials through our platforms. By submitting content, you grant SWOB a perpetual, irrevocable, worldwide, royalty-free license to use, publish, reproduce, adapt, share, distribute, and display that content for legitimate SWOB or Spicy Awards purposes, including communications, storytelling, promotional materials, social media, presentations, documentation, and archives. Submitted content must not:

• Be unlawful, offensive, defamatory, or materially misleading.
• Violate copyright, privacy, or other rights of third parties.
• Contain material that is harmful or inappropriate for its intended use.

SWOB reserves the right to remove or decline to publish submitted content where appropriate.

3.3 | Automatically Collected Information

When you visit our websites or use our digital platforms, certain technical information may be collected automatically, including:

• IP address and approximate location.
• Browser type and version.
• Device type and operating system.
• Pages visited and approximate time spent on pages.
• Navigation and usage patterns.
• Referring websites or search terms.
• Cookies and similar tracking technologies.

This information is generally used for website functionality, analytics, security, and service improvement and may not directly identify you.

3.4 | Publicly Available Information

Where relevant to our programs, communications, research, or engagement, we may use information that is already publicly available, including:

• Public professional profiles, including LinkedIn profiles.
• Public social media posts and profiles.
• Public directory or organizational listings.
• Publicly available information relevant to your interaction with SWOB.

3.5 | Sensitive Personal Data

In certain circumstances, and where voluntarily provided or otherwise permitted by applicable law, we may collect information that may constitute sensitive or special-category personal data. This may include:

• Demographic information, including ethnicity or disability status.
• Biographical information submitted through program applications.
• Impact, lived-experience, or community information relevant to program participation.

Sensitive personal information is handled with enhanced safeguards and collected only where there is a legitimate and appropriate purpose and lawful basis for doing so.

We may use personal information for the following purposes:

Service Delivery & Improvement

• Processing Spicy Awards nominations and applications.
• Managing programs such as accelerators, ambassador initiatives, and volunteer opportunities.
• Managing events, workshops, summits, and related activities.
• Evaluating submissions and communicating outcomes.
• Improving our programs, platforms, and participant experience.

Communication

• Responding to questions and inquiries.
• Providing program and event information.
• Sending newsletters and updates where you have opted in or where otherwise permitted by law.
• Communicating important information relating to services you have requested.

Legal, Compliance & Security

• Verifying information or identity where appropriate.
• Preventing fraud, abuse, or misuse.
• Maintaining website and platform security.
• Investigating suspected violations.
• Fulfilling legal, regulatory, or governmental obligations.

Organizational Development

• Conducting research and analytics.
• Evaluating programs and measuring impact.
• Preparing reports and organizational learning materials.
• Producing anonymized or aggregated impact information.

We do not use your personal information for automated profiling or automated decision-making that produces significant effects without appropriate human involvement.

Depending on the circumstances and applicable law, we process personal information on one or more of the following legal bases:

• Consent — where you voluntarily provide consent for a specific purpose.
• Contract or requested services — where processing is necessary to provide a service, process a registration, or fulfill a request.
• Legal obligation — where processing is necessary to comply with applicable law or regulatory requirements.
• Legitimate interests — where processing is necessary for appropriate program management, security, operations, reporting, fundraising, communications, or organizational development, while respecting applicable rights.

Where applicable law requires explicit consent for sensitive or special-category personal data, we will obtain that consent before processing such information.

We do not sell, rent, or trade your personal information. We may share information where reasonably necessary to operate our programs, provide requested services, fulfill legal obligations, or support legitimate organizational activities. This may include sharing information with:

• Program partners and sponsors, where necessary and appropriate.
• Selection committees, reviewers, juries, and awarding panels.
• Professional advisers and authorized representatives.
• Service providers such as cloud storage, email, communications, payment, ticketing, and event-management providers.
• Legal, regulatory, or governmental authorities where required by law.
• International partners assisting with legitimate program delivery.

Where appropriate, third-party service providers are expected to maintain confidentiality and implement reasonable data protection safeguards.

Because SWOB and the Spicy Awards may work with international partners and service providers, your information may be processed or stored outside Kenya, including in jurisdictions such as the European Union, United Kingdom, or United States. Where applicable, international transfers will be carried out using appropriate safeguards required by applicable data protection law. Depending on the circumstances, safeguards may include:

• Adequacy decisions or equivalent recognized protection.
• Standard Contractual Clauses or other appropriate contractual safeguards.
• Explicit consent where permitted and appropriate.
• Other lawful transfer mechanisms recognized under applicable law.

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, or as required or permitted by applicable law. This may include retaining information to:

• Deliver program and event services.
• Fulfill legal, regulatory, or contractual obligations.
• Conduct research, reporting, and impact assessments.
• Maintain historical award records and organizational archives.
• Resolve disputes or maintain appropriate records for accountability.

When information is no longer required, we will take reasonable steps to securely delete, destroy, or anonymize it, subject to applicable legal and operational requirements.

Depending on your location and the applicable law, you may have rights relating to your personal information, including:

• Accessing personal information we hold about you.
• Requesting correction of inaccurate or incomplete information.
• Requesting deletion of personal information where legally applicable.
• Restricting or objecting to certain processing.
• Withdrawing consent where processing is based on consent.
• Requesting data portability where applicable.
• Rights relating to automated decision-making where applicable.
• Lodging a complaint with a relevant data protection authority where applicable.

To exercise your privacy rights, contact:

privacy@spicewithoutborders.org | info@spicewithoutborders.org

We may request reasonable information to verify your identity before processing certain requests.

Our websites may use cookies and similar technologies to improve functionality, security, performance, and user experience. Cookies may be used to:

• Enhance website functionality and security.
• Remember preferences and settings.
• Analyze website traffic and usage patterns.
• Support analytics services.
• Enable social media embeds and other third-party functionality.
• Improve the performance and usability of our websites.

You can control or disable cookies through your browser settings. Disabling certain cookies may affect website functionality. For additional information, please review our Cookie Policy .

We implement reasonable technical and organizational measures designed to protect personal information against unauthorized access, loss, misuse, alteration, disclosure, or destruction. These measures may include:

• Encrypted storage and transmission where appropriate.
• Access controls and authorization procedures.
• Secure servers and hosting environments.
• Staff and collaborator confidentiality requirements.
• Security monitoring and maintenance.
• Periodic reviews and audits of relevant systems and processes.

However, no electronic system, transmission, storage environment, or internet connection can be guaranteed to be completely secure. If you become aware of suspected unauthorized access, disclosure, or misuse of personal information relating to our services, please notify us promptly.

We take the privacy of children and young people seriously. We do not knowingly collect personal information from children below the applicable age threshold without an appropriate lawful basis, consent, authorization, or safeguards required by applicable law. If we become aware that personal information has been collected in a manner that does not comply with applicable requirements, we will take reasonable steps to address the situation, which may include deleting the information where appropriate.

Our websites and communications may contain links to external websites, platforms, payment providers, ticketing systems, social media networks, or other third-party services. Spice Without Borders does not control and does not necessarily endorse the content, availability, security, or privacy practices of third-party services. Information submitted directly to a third-party platform is governed by that platform’s own privacy policy, terms, and conditions. We encourage you to review the privacy policies of external services before providing them with personal information.

We are committed to responsible communication and do not intentionally use personal information to send unsolicited communications in violation of applicable law. Emails and other communications may be sent:

• With your consent.
• As part of a service, program, registration, or request you initiated.
• Where necessary to communicate important operational information.
• Where otherwise permitted or required by applicable law.

Where applicable, promotional or newsletter communications will include an unsubscribe or opt-out mechanism. We do not sell our mailing lists.

If you believe your personal information has been improperly accessed, disclosed, misused, or processed in violation of this Privacy Policy, please contact us as soon as possible.

privacy@spicewithoutborders.org

We will review reported concerns and take reasonable steps to investigate and address confirmed or suspected privacy incidents.

We may update this Privacy Policy from time to time to reflect changes in applicable law, technology, organizational practices, programs, services, or data processing activities. When changes are made, the revised policy will be published on this website and the Last Updated date will be revised where appropriate. Your continued use of our websites or services following publication of an updated policy constitutes acknowledgment of the revised policy to the extent permitted by applicable law.

If you have questions, concerns, requests, or complaints regarding this Privacy Policy or the handling of your personal information, please contact:

Data Protection Officer (DPO)

Spice Without Borders (SWOB)
P.O. Box 8512 – 30100
Eldoret, Kenya

Email:

privacy@spicewithoutborders.org

info@spicewithoutborders.org

Websites:

www.spicewithoutborders.org

www.spicyawards.com