Privacy Policy

This Privacy Policy explains how Northfast Limited (“Northfast Limited”, “we”, “us” or “our”), the operator of TheSchicht at theschicht.com (the “Site”), collects, uses, discloses, retains and protects personal data when you visit the Site, subscribe to our newsletter, create an account, purchase a membership, post comments, or otherwise interact with us. It also describes the rights available to you and how to exercise them.

TheSchicht is a publication owned and operated by Northfast Limited, a private company limited by shares incorporated in the Republic of Kenya on 30 August 2023 (company number PVT-ZQUL52E6; KRA PIN P052252354X; corporate website northfast.co.ke), whose registered office is at Bute Town, Moyale–Mandera Road, Bute, Wajir North District, Wajir County, P.O. Box 141–70200, Wajir, Kenya. For the purposes of the Kenya Data Protection Act, 2019 and its Regulations, and — where it applies to visitors in the European Economic Area or the United Kingdom — the EU/UK General Data Protection Regulation (“GDPR”), Northfast Limited is the data controller responsible for your personal data.

Please read this Policy together with our Cookie Policy and Terms of Service, which form part of it.

1. Scope of this Policy

This Policy applies to personal data we process about visitors, newsletter subscribers, registered members, commenters, prospective and paying customers, and people who contact us. It does not apply to third-party websites, services or platforms that we link to or embed, each of which has its own privacy practices.

2. Information we collect

We collect the minimum personal data necessary to operate the publication. Depending on how you use the Site, this may include:

• Information you provide directly: your email address (newsletter sign-up, account or membership); your name or display name where you choose to provide it; comments and any other content you submit; and the contents of messages you send us.
• Membership and transaction data: if you take out a paid membership, your subscription status, plan, billing history and related records. Card details are processed by our payment provider — we do not store full card numbers on our systems.
• Information collected automatically: technical and usage data such as your IP address, approximate (city/country-level) location derived from it, browser type and version, device and operating system, referring URLs, pages viewed, and the date and time of access. Some of this is collected through cookies, local storage and privacy-respecting analytics — see our Cookie Policy.
• Information from third parties: limited data from our service providers, for example payment confirmation from our payment processor, or delivery and engagement metrics from our email provider.

We do not knowingly collect special categories of personal data (such as data revealing health, race, religion, or political opinions) and ask that you do not submit such data to us.

3. How and why we use your data (purposes and lawful bases)

We process personal data only where we have a lawful basis to do so. The bases we rely on under the Kenya Data Protection Act, 2019 and, where applicable, the GDPR include:

• Performance of a contract: to create and administer your account, deliver memberships and paid content, process payments, and provide customer support.
• Consent: to send you our newsletter and optional marketing, and to set non-essential (analytics, functional and marketing) cookies. You may withdraw consent at any time without affecting prior processing.
• Legitimate interests: to secure and maintain the Site, prevent fraud and abuse, understand which content is useful, measure and improve performance, and communicate essential service messages — balanced against your rights and freedoms.
• Legal obligation: to comply with applicable law, accounting and tax requirements, and lawful requests from public authorities.

4. Cookies and similar technologies

We and our providers use cookies, local storage and similar technologies to run the Site, remember your preferences, and — with your consent — measure usage. You can review and change your choices at any time using the Cookie settings control, which is also available in the footer of every page. Full details are in our Cookie Policy.

5. Sharing and disclosure

We do not sell your personal data. We share it only as necessary and with appropriate safeguards, including with:

• Service providers (data processors) who act on our instructions, such as our content-management and membership platform, payment processor, email/newsletter provider, analytics provider, and hosting and content-delivery infrastructure.
• Professional advisers (lawyers, accountants, auditors) where reasonably necessary.
• Authorities and third parties where required by law, to enforce our terms, or to protect the rights, safety and property of Northfast Limited, our users or the public.
• Advertising partners — where advertising is enabled, third-party partners including Google (Google AdSense) may use cookies to serve ads based on your prior visits to this and other sites. See the Cookie Policy for details and opt-out links (including Google Ads Settings).
• Successors in the event of a merger, acquisition, financing or sale of assets, subject to this Policy.

6. Advertising and Google AdSense

TheSchicht is supported by advertising. We use Google AdSense to serve ads on the Site. The following disclosures are made in accordance with Google’s publisher requirements:

• Third party vendors, including Google, use cookies to serve ads based on a user’s prior visits to this website or other websites.
• Google’s use of advertising cookies enables it and its partners to serve ads to our users based on their visit to this Site and/or other sites on the Internet.
• Users may opt out of personalised advertising by visiting Google Ads Settings. Alternatively, users may opt out of a third-party vendor’s use of cookies for personalised advertising by visiting aboutads.info or, in Europe, youronlinechoices.eu.
• Where we have not opted out of third-party ad serving, third-party vendors and ad networks other than Google may also serve ads on the Site. You may visit those vendors’ own websites to opt out of their use of cookies for personalised advertising, where they offer that choice.

Visitors in the EEA, the UK and Switzerland. Where required, we obtain consent for the use of cookies and the processing of personal data for personalised advertising in line with Google’s EU User Consent Policy, and we signal your choices to Google using Consent Mode. If you do not consent to personalised advertising, you may still see non-personalised or limited ads, which do not rely on your prior browsing to select what is shown. You can change your choice at any time via the Cookie settings control in the footer of every page.

We do not serve advertising that is targeted on the basis of sensitive categories, and we do not knowingly serve personalised ads to anyone under 18.

7. International transfers

Northfast Limited is based in Kenya, and some of our providers operate servers or process data in other countries. Where personal data is transferred across borders, we take steps to ensure it receives an adequate level of protection consistent with the Kenya Data Protection Act, 2019 and, where applicable, the GDPR — for example through appropriate contractual safeguards or transfer to jurisdictions offering adequate protection.

8. Data retention

We keep personal data only for as long as necessary for the purposes described in this Policy, including to meet legal, accounting or reporting requirements. Newsletter data is kept until you unsubscribe; account and membership records are kept for the life of the account and for a reasonable period afterward; transaction records are kept for the period required by tax and accounting law. When data is no longer needed, we delete or anonymise it.

9. Security

We apply appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse or alteration, including encryption in transit (HTTPS), access controls, and reputable providers. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

10. Your rights

Subject to applicable law, you have the right to: access a copy of your personal data; rectify inaccurate data; erase data (“right to be forgotten”); restrict or object to processing; data portability; and withdraw consent at any time. To exercise any right, email [email protected]. We will respond within the timeframes required by law and may need to verify your identity first.

If you believe we have not handled your data lawfully, you may lodge a complaint with the Office of the Data Protection Commissioner (ODPC), Kenya (odpc.go.ke), or — if you are in the EEA/UK — with your local supervisory authority. We would appreciate the chance to address your concerns first.

11. Children

The Site is intended for adults and is not directed to children under 18. We do not knowingly collect personal data from children. If you believe a child has provided us data, contact us and we will delete it.

12. Automated decision-making

We do not make decisions producing legal or similarly significant effects about you based solely on automated processing.

13. Third-party links and embeds

The Site links to and embeds third-party content (for example market-data widgets and social platforms). We are not responsible for the privacy practices of those third parties; please review their policies.

14. Changes to this Policy

We may update this Policy from time to time. The “Last updated” date reflects the latest version, and material changes will be notified through the Site or by email where appropriate.

15. Contact us

For any privacy question or request, contact our data protection contact at [email protected] or [email protected]. Postal enquiries can be addressed to Northfast Limited at the address in our Imprint.

This Cookie Policy explains how Northfast Limited uses cookies, local storage and similar technologies on TheSchicht (theschicht.com), what each category does, and how you can control them. It supplements our Privacy Policy.

1. What are cookies and local storage?

Cookies are small text files placed on your device by a website. “Local storage” is a related browser technology used to store small amounts of data (such as your theme preference) on your device. Together we refer to them as “cookies” in this Policy. They can be set by us (“first-party”) or by third parties whose services we use (“third-party”), and can last for a single session or persist between visits.

2. Your choices and control

When you first visit, we ask for your consent to non-essential cookies through a banner. Strictly necessary cookies do not require consent and cannot be switched off. You can change your preferences at any time using the Cookie settings control here or in the footer of any page, and you can also block or delete cookies through your browser settings.

3. Categories of cookies we use

• Strictly necessary — required for the Site to function and to remember your privacy choices; for example keeping you signed in to your membership, enabling secure checkout, and storing your consent selection. Always active.
• Functional / preferences — remember choices you make to personalise your experience, such as your selected display theme (“mood”).
• Analytics / performance — help us understand how visitors use the Site so we can improve it, using privacy-respecting, aggregate measurement.
• Marketing — used to make content and any promotions more relevant. We keep these to a minimum and set them only with your consent.

4. Specific cookies and storage we set

• sch-consent (first-party, local storage, necessary) — records your cookie preferences so we do not ask again.
• sch-mood (first-party, local storage, functional) — remembers your chosen display theme.
• Membership session (first-party, necessary) — keeps you signed in and enables members-only and paid content via our membership platform.
• Payment provider (third-party, necessary for purchases) — set by our payment processor to enable secure checkout and fraud prevention.
• Analytics (analytics) — privacy-respecting, aggregate usage measurement; set only with your consent.
• Embedded content (third-party, functional/marketing) — market-data and social embeds may set their own cookies when displayed.

5. Advertising and third-party partners (including Google)

Where advertising is enabled on the Site, we may work with third-party advertising partners, including Google (Google AdSense):

• Third-party vendors, including Google, use cookies to serve ads based on a user’s prior visits to this Site and other websites.
• Google’s use of advertising cookies enables it and its partners to serve ads to users based on their visits to this Site and/or other sites on the internet.
• You can opt out of personalised advertising by visiting Google Ads Settings, or opt out of third-party vendors’ use of cookies for personalised advertising at aboutads.info/choices.
• For details on how Google uses cookies in advertising, see Google’s advertising technologies notice.

Advertising cookies are set only where advertising is active and, where consent is required, only after you allow the “Marketing” category in our cookie settings.

6. Managing cookies in your browser

Most browsers let you view, block and delete cookies through their settings. Blocking strictly necessary cookies may cause parts of the Site (such as sign-in or checkout) to stop working. Guidance is available in your browser’s help pages.

7. “Do Not Track”

Some browsers offer a “Do Not Track” signal. Because there is no common industry standard for interpreting it, we do not currently respond to such signals, but we honour the choices you make through our consent tool.

8. Changes

We may update this Cookie Policy as our use of cookies changes. Please check back for the latest version.