Privacy Policy

1.About This Policy

Khushi Motors ("Khushi Motors", "we", "us" or "our") respects your privacy and is committed to protecting personal data entrusted to us.

This Privacy Policy explains how we collect, use, disclose, store, protect and otherwise process personal data when you:

• visit or use our website at https://khushimotors.com;
• enquire about a vehicle;
• request a vehicle quotation;
• book or enquire about a test drive;
• make or enquire about a vehicle reservation or deposit;
• communicate with us by telephone, email, WhatsApp or other communication channels;
• visit one of our branches;
• purchase or seek to purchase a vehicle from us;
• apply for or enquire about vehicle financing;
• interact with our marketing communications; or
• otherwise interact with Khushi Motors in connection with our products and services.

Khushi Motors operates in Kenya, Uganda and Tanzania. We seek to comply with the data protection and privacy laws applicable to the processing of personal data in the jurisdictions in which we operate.

This Policy should be read together with our Cookie Policy, which explains how we use cookies and similar technologies on our Website.

2.Who Is Responsible for Your Personal Data?

Khushi Motors is responsible for determining how and why personal data is processed in connection with our business and services, subject to the particular circumstances of the processing.

Where different Khushi Motors entities, branches, affiliates or service providers are involved in processing your personal data, responsibility for that processing will be determined in accordance with the applicable legal and contractual arrangements.

For purposes of this Policy, "Khushi Motors", "we", "us" and "our" refer to the relevant Khushi Motors entity responsible for the applicable processing activity.

Where required by applicable law, we will provide additional information identifying the relevant data controller or responsible entity.

3.What Is Personal Data?

"Personal data" means information relating to an identified or identifiable individual, or information that can reasonably be linked to an identifiable individual, as defined under applicable data protection law.

Depending on the circumstances, personal data may include information such as your name, contact details, identification information, financial information, vehicle preferences, communications with us, online identifiers and information about your interactions with our Website.

4.Personal Data We Collect

We collect personal data that you provide to us, information generated through your interactions with us, and certain information collected automatically when you use our Website.

5.What Information We Collect

Information you give us

When you contact us, you may share:

• Your full name
• Your email address
• Your phone number (this includes WhatsApp)
• Your address
• Your country, city, and the branch you prefer
• Details about the vehicle you want
• Any other information you choose to give us

Information we collect automatically

When you visit our website, some information is collected on its own:

• Your IP address
• Your browser type
• Your device type
• The pages you visit
• The date and time you visit
• The website that sent you to us
• General usage data

Cookies and Similar Technologies

We use cookies and similar technologies to operate, secure and improve our Website and, where permitted and where you have provided the required consent, to analyse Website usage and support advertising and marketing.

Our use of cookies is described in our Cookie Policy.

Where applicable law requires consent for non-essential cookies or similar technologies, we will obtain that consent before activating them.

We do not treat continued browsing or use of the Website as consent to non-essential cookies where affirmative consent is required.

6.Why We Use Your Information

We may use personal data for the following purposes:

6.1 Providing Products and Services

To:

• respond to vehicle enquiries;
• provide quotations;
• arrange vehicle viewings and test drives;
• process reservations and deposits;
• facilitate vehicle purchases;
• provide customer support;
• communicate with you about transactions;
• provide information requested by you; and
• perform our obligations under an agreement with you.

6.2 Vehicle Financing

Where you request or apply for financing, we may process information necessary to facilitate the financing process.

This may include sharing relevant information with banks, financial institutions, lenders, insurers or other financing partners involved in the transaction.

We will only share information reasonably necessary for the relevant financing purpose and in accordance with applicable law.

6.3 Website Operation and Improvement

We may process technical and usage information to:

• operate and maintain our Website;
• improve Website functionality;
• understand Website usage;
• identify technical problems;
• improve user experience;
• maintain security; and
• detect and prevent fraud, abuse or unauthorised activity.

6.4 Marketing

Where you have provided the required consent, or where another lawful basis permits the communication under applicable law, we may send you:

• information about vehicles;
• special offers;
• promotions;
• event invitations;
• branch updates;
• new vehicle announcements; and
• other marketing communications concerning our products and services.

You may withdraw your marketing consent or opt out of marketing communications at any time.

6.5 Legal and Regulatory Compliance

We may process personal data where necessary to:

• comply with applicable laws and regulations;
• respond to lawful requests from public authorities;
• comply with court orders;
• meet accounting, tax or regulatory obligations;
• establish, exercise or defend legal claims; and
• prevent, investigate or detect fraud or other unlawful conduct.

6.6 Corporate and Business Purposes

We may process personal data where reasonably necessary to:

• manage our business;
• maintain business records;
• protect our legal rights and interests;
• manage risk;
• conduct audits;
• improve our products and services;
• manage suppliers and service providers; and
• undertake a merger, acquisition, restructuring, sale or other corporate transaction.

We never sell your personal information to anyone.

7.Lawful Bases for Processing

Depending on the nature and circumstances of the processing, Khushi Motors may rely on one or more lawful bases recognised by applicable data protection law.

These may include:

7.1 Consent

We may rely on your consent where consent is required or is the appropriate lawful basis for processing.

Examples may include certain:

• marketing communications;
• non-essential cookies;
• advertising and remarketing technologies; and
• other processing activities for which applicable law requires consent.

Where we rely on consent, you may withdraw it at any time.

Withdrawal of consent will not affect the lawfulness of processing carried out before withdrawal.

7.2 Performance of a Contract or Steps at Your Request

We may process personal data where necessary to:

• provide a quotation you have requested;
• arrange a test drive;
• process a reservation;
• facilitate a vehicle purchase; or
• perform obligations under an agreement with you.

7.3 Legal Obligation

We may process personal data where necessary to comply with a legal or regulatory obligation applicable to Khushi Motors.

7.4 Legitimate Interests

Where recognised by applicable law, we may process personal data where necessary for legitimate interests pursued by Khushi Motors or a relevant third party, provided that those interests are not overridden by applicable privacy rights and interests.

Such interests may include:

• maintaining Website and information security;
• preventing fraud;
• protecting our property and systems;
• improving our products and services;
• managing business operations;
• defending legal claims; and
• maintaining appropriate business records.

Where we rely on legitimate interests, we will consider whether the processing is necessary and proportionate and whether the individual's rights and interests require additional safeguards.

7.5 Other Lawful Bases

We may rely on another lawful basis where one is available under the data protection law applicable to the relevant processing.

8.Sensitive or Special Categories of Personal Data

Certain categories of personal data receive enhanced protection under applicable law.

Khushi Motors does not ordinarily require sensitive or special-category personal data to provide vehicles or ordinary customer services.

Where we need to process such information, we will do so only where:

• the processing is necessary and lawful;
• an applicable legal basis exists;
• any additional conditions required by law are satisfied; and
• appropriate safeguards are implemented.

You should avoid providing sensitive personal information through ordinary Website enquiry forms unless we specifically request it.

9.Data Processors and Service Providers

We may appoint third-party service providers to process personal data on our behalf.

These may include providers of:

• website hosting;
• cloud storage;
• customer relationship management systems;
• communications;
• email;
• analytics;
• advertising;
• cybersecurity;
• payment processing;
• financing-related services;
• customer support; and
• other business-support services.

Where required by applicable law, we will enter into appropriate contractual arrangements with processors and service providers and require them to implement appropriate security and confidentiality measures.

Third-party providers may process personal data in countries outside Kenya, Uganda or Tanzania, subject to applicable legal requirements.

9.1 Why We Are Allowed to Use Your Information

We only use your information for a good reason. This reason may be:

• You said yes to it
• We need it to help you with something you asked for, like a quote
• The law tells us we must
• We have a fair business reason, such as making our service better

9.2 Who We Share Your Information With

Sometimes we share your information with:

We ask everyone we share your information with to keep it safe and use it the right way. We do not sell your information to anyone.

10.International and Cross-Border Data Transfers

Because Khushi Motors operates in Kenya, Uganda and Tanzania, personal data may be accessed, transferred, stored or otherwise processed across these countries.

Personal data may also be processed by certain technology, hosting, cloud, analytics, communications, advertising, financing or other service providers located outside East Africa.

Where personal data is transferred across borders, Khushi Motors will comply with applicable requirements governing international or cross-border transfers.

Depending on the jurisdiction and circumstances, appropriate safeguards may include:

• contractual protections;
• appropriate data-processing agreements;
• regulatory or legally recognised transfer mechanisms;
• adequacy or equivalent protections where recognised;
• appropriate technical and organisational safeguards; and
• other safeguards permitted or required by applicable law.

Where required, Khushi Motors will provide additional information concerning the relevant transfer and safeguards.

11.How We Keep Your Information Safe

We use reasonable steps to protect your information from being lost, misused, or seen by the wrong people.

But no website or system on the internet can be 100% safe. So we cannot promise that your information will always be completely secure.

12.How Long We Keep Your Information

We keep your information only as long as we need it. For example, to:

• Help you with the reason you contacted us
• Follow the law
• Solve any disagreement
• Keep our agreements

We will confirm an exact time period for this soon.

13.Your Rights

Depending on where you live, you may have the right to:

• See the information we have about you
• Ask us to fix wrong information
• Ask us to delete your information
• Take back your permission
• Say no to some ways we use your information
• Ask us to limit how we use it

To use any of these rights, please contact us.

When making a request, we may need sufficient information to verify your identity and ensure that personal data is disclosed or amended only for the appropriate individual.

We will respond to valid requests within the timeframe required by applicable law.

If we are unable to fulfil a request, we will, where required, explain the reason and inform you of any applicable complaint or review mechanism.

14.Marketing Messages

We may communicate with you about our products and services where permitted by applicable law.

Where marketing communications require consent, we will obtain the required consent before sending them.

Marketing communications may include:

• email;
• SMS;
• telephone;
• WhatsApp or other messaging services;
• digital advertising; and
• other electronic communication channels.

You may opt out of direct marketing at any time.

For email communications, you may use the unsubscribe mechanism included in the relevant communication.

You may also contact us using the details provided in the contacts section.

Where you opt out of marketing, we may continue to send non-marketing communications that are necessary for an existing transaction, service, legal obligation or other legitimate purpose.

15.Children's Privacy

Our products and services are primarily intended for adults.

We do not intentionally seek to collect personal data from children through our Website except where permitted by applicable law and where appropriate safeguards are in place.

Where applicable law requires parental or guardian consent or other safeguards for the processing of children's personal data, Khushi Motors will comply with those requirements.

If you believe that a child has provided us with personal data in circumstances where such collection was not appropriate, please contact us so that we can assess and take appropriate action.

16.Complaints and Regulatory Rights

If you have a concern regarding our handling of your personal data, we encourage you to contact us first so that we can investigate and seek to resolve the matter.

You may also have the right to lodge a complaint with the relevant data protection authority in the jurisdiction applicable to you.

Depending on the circumstances, this may include the relevant data protection authority in:

• Kenya;
• Uganda; or
• Tanzania.

Nothing in this Policy limits any right you may have under applicable data protection law to contact or lodge a complaint with the relevant regulatory authority.

17.Third-Party Websites and Services

Our Website may contain links to third-party websites, applications, social-media platforms or other services.

We are not responsible for the privacy practices, security or content of third-party services that we do not control.

You should review the privacy notices of third-party services before providing personal data to them.

Where third-party technologies are integrated into our Website, additional information may be provided in our Cookie Policy.

18.Profiling and Automated Decision-Making

We may use certain personal data and online activity information to understand customer preferences, improve our services and, where permitted, support advertising or marketing activities.

Where applicable, this may involve profiling or audience segmentation.

We will not make decisions producing legal or similarly significant effects on you solely through automated processing unless permitted by applicable law and subject to any safeguards and rights required by law.

Where applicable law gives you rights concerning automated decision-making or profiling, you may exercise those rights in accordance with this Policy.

19.Payment and Financial Information

Where you make a payment, deposit or other transaction, payment-related information may be processed by Khushi Motors and/or relevant payment service providers.

Where vehicle financing is involved, additional financial information may be processed by the relevant financing institution.

We will seek to limit access to financial information to persons and service providers who require it for legitimate business, transaction, regulatory or legal purposes.

20.Data Retention

Khushi Motors does not retain personal data indefinitely.

We retain personal data for only as long as reasonably necessary to fulfil the purposes for which it was collected, including where necessary to:

• provide products or services;
• maintain business and transaction records;
• comply with legal, tax, accounting or regulatory obligations;
• resolve disputes;
• establish, exercise or defend legal claims;
• prevent fraud;
• enforce agreements; or
• protect our legitimate business interests.

Retention periods may vary depending on:

• the nature of the personal data;
• the purpose for which it was collected;
• the relationship between Khushi Motors and the individual;
• applicable legal or regulatory requirements;
• contractual requirements; and
• the need to establish, exercise or defend legal claims.

Where personal data is no longer required, we will securely delete, anonymise or otherwise dispose of it in accordance with our data-retention procedures and applicable law.

21.Data Security

Khushi Motors implements appropriate technical and organisational measures designed to protect personal data against:

• unauthorised access;
• unlawful processing;
• accidental loss;
• destruction;
• alteration;
• unauthorised disclosure; and
• other security threats.

Depending on the nature and risk of the processing, safeguards may include:

• access controls;
• authentication mechanisms;
• confidentiality obligations;
• secure systems and infrastructure;
• appropriate technical monitoring;
• employee awareness and confidentiality measures;
• supplier and processor controls; and
• procedures for responding to suspected data breaches.

No website, electronic communication or information-storage system can be guaranteed to be completely secure.

However, we take reasonable and appropriate measures to protect personal data against foreseeable risks.

22.Personal Data Breaches

Khushi Motors maintains procedures for identifying, assessing, responding to and, where required, reporting personal data breaches.

Where applicable law requires notification to a regulator, affected individual or other authority, Khushi Motors will make the required notification within the applicable timeframe and in accordance with the applicable legal requirements.

23.If Our Business Changes

If Khushi Motors undergoes a merger, acquisition, restructuring, financing, sale of assets, change of ownership or other corporate transaction, personal data may be transferred as part of that transaction where legally permitted.

Any such transfer will be handled in accordance with applicable data protection law.

Where appropriate, we will notify affected individuals of material changes to the entity responsible for their personal data or the purposes for which their personal data is processed.

24.Contact Us

If you have any questions about this policy or your information, please contact us:

You can also visit or call your nearest Khushi Motors branch in Kenya, Uganda, or Tanzania.

25.Changes to This Policy

We may update this policy sometimes. We may update this Privacy Policy from time to time to reflect:

• changes to our products and services;
• changes to our business operations;
• changes in the personal data we process;
• changes to third-party service providers;
• changes to applicable data protection and privacy laws;
• regulatory guidance; or
• changes to our privacy practices.

When we update this Policy, we will revise the Effective Date and Last Updated dates above.

Where a change is material and applicable law requires notification or additional consent, we will provide appropriate notice and, where required, obtain the necessary consent.

Your continued use of the Website following an update does not, by itself, constitute consent to processing for which consent is legally required.