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