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Privacy policy

1. Introduction

SGHI, as a data processor and data controller, respects your privacy and is committed to protecting your personal and sensitive information. This privacy notice is a summary of our data privacy policy and describes how we collect, use, disclose, transfer, store, and process your personal data. The notice tells you about your privacy rights and how the law protects you. Personal data means any information about you as an identifiable natural person. For us to offer the required services to you, we collect and process your personal data.


2. The types of personal data that we collect

We may collect and process your personal data including name, D.O.B., gender, identity number or passport number, nationality, contact information such as email address, postal  address, telephone number, health data such as diagnosis, vitals, and cancer screening



3. How we collect personal data

We may collect your personal data on the Empower platform (Web or mobile applications) during registration and screening.

4. How do we use personal data and what legal basis do we have for processing personal data?

We use information collected through tracking technologies, such as log files, cookies and

web beacons when you use the Website. For example:

  • We track the number and activities of visitors using certain portions or features of the Website to make changes that may be necessary to improve or optimize the Website’s functionality and identify areas of interest to our visitors;

  • We track the popularity of features on the Website to inform the development of new ones;

  • We identify the types of devices our visitors use so that we can improve and optimize our systems and services;

  • We identify the type of visitors to the Website to determine whether such users are existing clients or prospective clients for marketing and sales generation purposes; and

We assess how users become aware of or access the Website to gauge the quality and methods of our marketing. By continuing to use our Website, including by remaining on the landing page, you consent to the use of cookies.

  • If you provide us with your information in connection with your interest in our products or services (e.g., through web forms), we will use such information to reach out to you about our products or services

  • If you provide us with your information, we may use it for informational purposes, including solicitations, invitations, newsletters, awareness campaigns, and announcements

  • When you provide information on our Website or have an account with us, we may use your information for feedback collection and research purposes

SGHI and its service providers enter into agreements that require that care and precautions be taken to prevent loss, misuse, or disclosure of your information. Nevertheless, transmission via the Internet is not completely secure and we cannot guarantee the security of information about you.


Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.

5. In this regard, we rely on the following lawful basis for processing personal data

  1. Performance of a contract: with relevant Business partners

  2. Legal and regulatory obligations: Compliance with our legal and regulatory obligations under different regulatory bodies such as the Kenyan Data Protection Act (DPA) 2019 and the General Data Protection Regulation (GDPR)

  3. Consent: SGHI will rely on your consent as a lawful basis for processing your personal data.

  4.  Legitimate interests: SGHI's Legitimate business interests include product and service improvements, prevention, and detection of fraud.

  5. Data Security​

SGHI has put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an authorized way, altered, or disclosed. We have also enacted data breach procedures and notification procedures as applicable to relevant regulators.

6. Retention and storage of personal data

SGHI will retain your personal data for as long as may be necessary to fulfill the purpose we collected it for, including purposes related to legal, and regulatory obligations.

7. Your legal rights

  • Right to be informed

  • Right to access personal data within 7 days

  • Right to rectification of personal data

  • Right to object to all or part of their personal data being processed

  • Right not be subject to automated decision-making

  • Right to erasure/deletion

  • Data Portability


8. Contact

If you have any concerns about the use of your personal data and questions or comments about this policy, please contact us using the details below:

Telephone Number: +254 790 360 360

Email Address:

Physical Address: SGHI, 5th Floor, One Padmore Place, off George Padmore Road

We will respond to your questions or concerns on time and in compliance with relevant laws.

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