Vellum, an offering run by the Public Policy Department at Oxygene Marketing and Communication Ltd., is a leading publication dedicated to exploring the political, socio-economic, and policy issues shaping Kenya and the broader African region. Through insightful articles, reports, and events, Vellum brings critical public policy matters to the forefront, providing valuable analysis on emerging trends and regulatory shifts. Focused on public affairs, reputation management, and policy analysis, Vellum is your go-to source for staying informed and ahead in the dynamic regulatory and policy landscape.
For the purposes of this Privacy Policy:
Account means a unique account created for You to access our Offerings or parts of our Service.
Advertising ID refers to a unique, anonymized user identifier assigned to a device such as a smartphone, tablet, or laptop whose apps can then access it. This can be the Apple Identifier for Advertising (“IDFA”), or Google Advertising Identifier (“GAID”), depending on the operating system that your device runs on.
Cookies are small files that are placed on your computer, mobile device or any other device by a website, containing the details of your browsing history on that website among its many uses.
Data Controller refers to a natural or legal person, public authority, agency, or other body which alone, or jointly with others, determines the purpose and means of processing of personal data.
Data Processor refers to a natural or legal person, public authority, agency, or other body which alone or jointly with others processes personal data on behalf of the data controller.
Device means any device that can access the Offerings, such as a computer, a cellphone or a digital tablet.
Offerings refer to the services and publications under vellum such as The Vellum Weekly Publication, The Vellum Podcast, our website at vellum.co.ke, as well as our pages or ads on social media networks, like our Linkedin, X and Instagram pages.
“Organisation,” “We,” “Our,” “Ours,” and “Us” refer to Vellum and include its successors in title and assigns, its affiliates and/or its subsidiaries as may from time to time be specified.
Personal Data is any information about an individual that can be used to identify them.
Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Website refers to the Vellum Website, accessible from vellum.co.ke
You means the individual accessing or using the offerings, or the company, or other legal entity on behalf of which such individual is accessing or using the offerings, as applicable.
Velllum respects your privacy and is committed to protecting your data. Vellum collects and processes personal data on you when you interact with our offerings on our website (regardless of where you access it from), whether you are a visitor or subscriber. This policy describes our policies and procedures on how we handle your personal information when you use, access and engage with us through the following “Vellum Offerings”:
We use your data to provide and improve our offerings. Consequently, by using and interacting with our offerings, you agree to the collection and use of information per this Privacy Policy.
You must read this privacy policy to ensure that you are fully aware of how and why we are using your data.
The information we collect about you will be for specified and legitimate purposes and will not be further processed in a manner incompatible with those purposes. We may collect, store, process, use, and transfer different kinds of personal data about you as per the following:
4.1. Data that We Collect Automatically
4.1.1. Device and Location Data
We collect data from your device. Examples of such data include: language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, and hardware ID. We also record the ads on our Website with which you interact (and the Internet links to which those ads lead).
4.1.2. Usage data
We record how you interact with our Offerings, such as the pages and content you interact with, how often you use the Website, and how much time you spend on the site.
4.1.2. Advertising IDs
We collect your device’s Advertising ID when you access our Website. These allow advertisers to track user behaviour while adhering to data protection laws, enabling targeted advertising and performance measurement.
4.1.3. Transaction Data
When you make payments through the site, you would need to provide financial account data, such as your credit card number, to our third-party service providers. We do not collect or store full credit card number data. However, we may receive credit card-related data, data about the transaction, including the date, time, amount of the transaction, and the type of payment method used.
4.1.4. Cookies
The use of cookies on our site is in so far as is necessary. Cookies can be either session cookies or persistent cookies. A session cookie expires when you close your browser and is used to make it easier for you to navigate our Service. A persistent cookie remains on your hard drive for an extended period. We also use tracking pixels that set cookies to assist with delivering online advertising.
Cookies are used, in particular, to automatically recognize you the next time you visit our website. As a result, the information which you have earlier entered in certain fields on the website may automatically appear the next time when you use our Service. Cookie data will be stored on your device and, most of the time only for a limited period.
You have the right to delete or reject cookies. However, this could affect certain features or services of our websites. If you choose to delete cookies, settings and preferences controlled by those cookies, including advertising preferences, may be deleted and may need to be recreated.
4.2. Data that You Give Us
The types of personal data that we may collect, store, process, use, and transfer are grouped as follows:
5.1. Within The Organisation
Our affiliates may access your information for the purposes listed here.
5.2. With Service Providers
We work with various service providers to carry out certain tasks, including the following business purposes:
When performing these tasks, service providers may have access to your personal information. We sometimes allow them to use aggregated or de-identified information for specified purposes, per applicable laws.
Any disclosure of your data shall be per applicable laws and regulations. Each application for disclosure and sharing of data shall be assessed and reviewed, and depending on the circumstances, the application may be declined. However, we may disclose your personal information to:
We may need to transfer your data outside of the Republic of Kenya. When we send your data outside Kenya, we will ensure that your data is properly protected per the applicable Data Protection Laws.
We will only retain your data for as long as necessary to fulfil the purposes we collected it for, including to satisfy 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 data, the purposes for which we process your data and whether we can achieve those purposes through other means, and the applicable legal requirements.
We protect your personal information with appropriate legal, organisational, technological and physical safeguards. However, we cannot guarantee its absolute security. We recommend that you use complex and unique passwords for your accounts and third-party accounts linked to them. Do not share your password with anyone.
If you have reason to believe your interaction with us is no longer secure, notify us immediately.
You may be required to opt in or give any other form of explicit consent before receiving marketing messages from us. You can ask us to stop sending you marketing messages at any time by writing to us at info@vellum.co.ke or compliance@oxygene.co.ke or by following the opt-out links on any marketing message sent to you or by contacting us at any time through the provided contacts.
Subject to legal and contractual exceptions, you have the following rights under the data protection laws concerning your data:
If you wish to exercise any of the rights set out above, please contact us at info@vellum.co.ke or compliance@oxygene.co.ke
We may need to request specific information from you to help us confirm your identity and ensure your right to access your 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 about your request to speed up our response.
Our website may provide hyperlinks to other locations or websites on the internet. These hyperlinks lead to websites published or operated by third parties who are not affiliated with or in any way related to us and have been included in our website to enhance your user experience and are presented for information purposes only.
We do not endorse, recommend, approve or guarantee any third-party products and services by providing hyperlinks to an external website or webpage and do not have any co-operation with such third parties unless otherwise disclosed.
We are not in any way responsible for the content of any externally linked website or webpage. By clicking on a hyperlink, you will leave the Vellum webpage, and accordingly, you shall be subject to the terms of use, privacy and cookie policies of the other website that you choose to visit.
If you would like to contact us on any topics in this privacy policy, you can email us at info@vellum.co.ke or compliance@oxygene.co.ke or submit a request via our digital platforms.
As a Data Controller and Processor, below are the contact details of our Data Protection Officer:
Oxygene Marketing Communications Ltd (MCL)
5th Floor, South Tower, Two Rivers
P.O Box 348623 – 00100
Nairobi, Kenya
You have the right to complain to the relevant supervisory authority that is tasked with personal data protection within the Republic of Kenya.
Vellum reserves the right to amend or modify this statement at any time. If any amendments are made to this statement, you can access the most current version of the privacy statement by checking the Vellum website. Any amendment or modification to this statement will take effect from the date of notification on the website.
