Effective Date: 31 January 2025 | Last Updated: 1 June 2025
Applies to: www.spicewithoutborders.org, www.spicyawards.com, and all SWOB & Spicy Awards programs, events, and digital platforms.
At Spice Without Borders (SWOB), including its flagship program Spicy Awards, we are committed to protecting your privacy and safeguarding your personal information. This Privacy Policy explains how we collect, use, store, and protect your personal data when you visit our websites or engage with our programs, platforms, or events. By using our websites or submitting your information, you consent to the practices described in this policy.
1. Introduction
SWOB operates in compliance with:
- The Kenya Data Protection Act (2019)
- The EU General Data Protection Regulation (GDPR)
- Other applicable international data protection laws
This Policy applies to all personal data collected via our websites, programs, events, and other digital services.
2. Who We Are (Data Controller)
Spice Without Borders (SWOB)
P.O. Box 8512 – 30100, Eldoret, Kenya
Email: info@spicewithoutborders.org
Spicy Awards is a program operated under SWOB and follows the same data protection standards.
For GDPR purposes, SWOB is the Data Controller for all personal data collected.
3. Information We Collect
We collect personal and non-personal information to support our mission, enable program participation, and improve your experience.
3.1 Information You Provide Directly
- Full name, contact details, location, and demographic information
- Applications, nominations, registrations, surveys, or forms
- Photos, biographies, CVs, professional profiles, or uploaded content
- Feedback, inquiries, or communications with us
- Social media identifiers (voluntarily provided)
- Event registrations, donations, and payment information
Some fields may be mandatory to provide our services.
3.2 Content You Upload
By uploading content (photos, videos, comments, profiles, etc.), you grant SWOB a perpetual, irrevocable, worldwide, royalty-free license to use, publish, modify, share, and display such content for SWOB or Spicy Awards purposes, including promotions, social media, presentations, and archives.
Content must not:
- Be offensive, defamatory, or misleading
- Violate copyrights or third-party rights
- Be inappropriate or harmful
SWOB may remove content at its discretion.
3.3 Automatically Collected Data
- IP address and approximate location
- Browser type and version
- Device type and operating system
- Pages visited, time spent, and navigation patterns
- Referring websites or search terms
- Cookies and similar tracking technologies
This information does not personally identify you and helps improve our services.
3.4 Publicly Available Information
- LinkedIn profiles
- Public social media posts
- Public directory listings relevant to your interaction with SWOB
3.5 Sensitive Personal Data
We may collect sensitive information (special categories) only when voluntarily provided, such as:
- Demographics (ethnicity, disability status, etc.)
- Biographical and impact information submitted for program applications
Sensitive data is handled with enhanced safeguards and collected only for legitimate purposes.
4. How We Use Your Information
Your data may be used for:
Service Delivery & Improvement
- Processing applications (Spicy Awards, Accelerator, Ambassadors, Volunteers)
- Managing events, workshops, and programs
- Evaluating submissions and communicating outcomes
Communication
- Responding to inquiries
- Providing updates, newsletters, and program information (opt-in only)
Legal, Compliance, and Security
- Verifying identity
- Preventing fraud or abuse
- Maintaining website and service security
- Fulfilling legal or regulatory obligations
Organizational Development
- Research, analytics, and program evaluation
- Impact reporting (using anonymized or aggregated data)
We do not use your data for automated profiling or decision-making without human involvement.
5. Legal Basis for Processing
We process personal data under the following legal bases:
- Consent – when voluntarily provided
- Contract – to deliver services requested
- Legal obligation – to comply with applicable laws
- Legitimate interests – program management, security, fundraising, reporting, and operations
Sensitive data collection requires explicit consent where applicable.
6. Sharing of Information
We do not sell, rent, or trade your personal information. We may share data with:
- Program partners and sponsors (when necessary)
- Selection committees, reviewers, and awarding panels
- Service providers (e.g., cloud storage, email platforms, event management tools)
- Legal authorities as required by law
- International partners assisting with program delivery
All third parties are bound by confidentiality agreements and data protection safeguards.
7. International Data Transfers
Your information may be processed or stored outside Kenya (e.g., EU, UK, USA). Transfers occur only if:
- The country has adequate protection, or
- Standard Contractual Clauses (SCCs) are in place, or
- You provide explicit consent
All transfers comply with GDPR and the Kenya Data Protection Act.
8. Data Retention
We retain personal data only as long as necessary to:
- Deliver program services
- Fulfill legal or contractual obligations
- Conduct research, reporting, or impact assessments
- Maintain historical award records and audits
Data is securely deleted or anonymized when no longer required.
9. Your Rights
Depending on your jurisdiction, you may have rights including:
- Access, correction, or deletion of personal data
- Restrict or object to processing
- Withdraw consent
- Data portability
- Right not to be subject to automated decision-making
To exercise your rights:
📧 privacy@spicewithoutborders.org | info@spicewithoutborders.org
Proof of identity may be required.
10. Cookies & Tracking
We use cookies to:
- Enhance functionality and security
- Remember preferences
- Analyze traffic and usage patterns
- Support analytics, social media embeds, and third-party services
You can control or disable cookies in your browser. See our separate Cookie Policy for details.
11. Data Security
We implement technical and organizational measures including:
- Encrypted storage
- Access controls
- Secure servers
- Staff confidentiality training
- Regular audits
No system is completely secure. Notify us of any suspected unauthorized use.
12. Children’s Privacy
We do not knowingly collect personal information from children under 13 (or local majority age). If such data is discovered, it will be deleted promptly.
13. Third-Party Links
Our websites may contain links to external sites. SWOB is not responsible for their:
- Content
- Privacy practices
- Security standards
Information submitted via third-party platforms is governed by their privacy policies.
14. Anti-Spam Policy
Emails are sent only:
- With consent
- As part of service delivery
- As legally required
Every email includes an unsubscribe option. Mailing lists are never sold or shared.
15. Violations & Misuse
Report any suspected violations or misuse to:
📧 privacy@spicewithoutborders.org
16. Updates to This Policy
We may update this Privacy Policy to reflect legal, organizational, or technological changes. Updates will be posted with a revised date. Continued use of our websites or services signifies acceptance of changes.
17. Contact Us
For questions, concerns, or to exercise your rights:
Data Protection Officer (DPO)
Spice Without Borders (SWOB)
📧 privacy@spicewithoutborders.org | info@spicewithoutborders.org
🌐 www.spicewithoutborders.org | www.spicyawards.com