We value your trust and take the protection of your personal information very seriously. This document outlines the way in which we collect, hold, secure, use and share your personal information. We encourage you to read through it, so that you are comfortable with what we do with your personal information.

  1. Policy Statement

    1. We Ideal Ceramics Limited (the “Company” or “we”) value your trust and take the protection of your personal information very seriously. This Policy outlines the collection, holding, use, sharing and protection of your personal information by the Company (accessible both online at www.idealceramics.com and at all our stores). By adhering to this Policy, we aim to foster a secure and respectful environment for you. We understand the importance of safeguarding personal information (which for purposes of this Policy is any information relating to an identified or identifiable, natural person, who can be identified directly or indirectly and is in relation to the data subject’s information) not only to protect individuals’ privacy but also to maintain the trust and confidence you place in us.
    2. This Privacy Policy (Policy) outlines:
      1. The way in which we collect, hold and/or retain, secure, use, share and protect your personal information, in accordance with the Kenya Data Protection Act (the Act) and the Data Protection (General) Regulations, 2021 (the Regulations);
      2. What Personal Information we collect and the purposes we collect your Personal Information;
      3. Your rights as a data subject;
      4. Complaints handling mechanisms; and
      5. Payment Information, non-disclosure and transmission, use and sharing of your personal information.

Any Personal Information collected by the Company is subject to the relevant provisions of the Act and the Regulations as may be amended from time to time.

  1. Consent and Scope

    1. By visiting, using, browsing, signing in, creating an account, accessing this Website and/or by viewing our products and services and this Website or purchasing any goods and/or products from the Company or supplying to the Company and submitting any information (including personal information) to the Company, you (the data subject), acknowledge and agree that such conduct and all of these actions constitute, unequivocal, free, unconditional, specific, informed indication and voluntary consent to the collection, use, storing, processing and sharing of your information including personal information. If you visit, access, browse on or use this Website or procure or purchase our products or services, you consent to collection of your information including your Personal Information and agree to abide by this Policy without any exceptions.
    2. If you have any questions regarding its contents, we invite you to contact our Privacy Officer, the contact details for which are contained in Section 19 below.
    3. This Policy shall apply to purchasers and all users who access this Website and shall govern the use of our Website and related services. By using and accessing our Website you agree to the collection, use, storage, processing and sharing of your Personal Information in accordance with this Policy.
    4. The Company may change and or update this Policy from time to time under various circumstances and for whatsoever reason in order to comply with legal requirements or to meet the changing business needs and requirements for the Company. We encourage you to visit our website www.idealceramics.com regularly to stay updated of the purposes for which we collect your Personal Information and your rights as a data subject.

  1. Nature of Personal Information Collected by the Company

    1. The Company collects Personal Information necessary for business operations and service provision, including:
      1. Personal Identification Information: Name, contact details (email address, telephone number), physical address, delivery address and company KRA pin for corporate customers.
      2. Unique IDs such as your mobile device identifier or cookie ID on your browser;
      3. IP address and information that may be derived from IP address, such as geographic location;
      4. Certain location or geolocation information you provide directly or through automated means, if you choose to enable location-based services from your device;
      5. Information about your orders and purchases of our goods, products and/or services, including what, how, and when you buy from the Company;
      6. Querying if you have signed up or subscribed to any of our offerings such as any newsletters or loyalty program that we may at present may be offered;
      7. Information about your online browsing actions on our Websites and apps (if any), including any promotions you activated, as well as items you have added to your cart;
      8. Information, images and videos that you may post online in relation to our products or goods or to facilitate our service provision or any promotions of sales, which includes when you provide feedback or a review; and
      9. Transactional Data: Details about products purchased, payment history, payment method and information collected and held via our secure financial partners about the payment card and method you use for your purchases from us, except for any card payment details or details related to any other payment platform or means used by you. Payment processing for any products or goods purchased from us through our Website or apps or otherwise is conducted and handled through an external vender, PesaPal. We do not handle and neither do we have sight of any payment related information or in relation to the means and methods of payment used by you.
    2. Certain information about you or device information may originate from the use of cookies and similar tracking technologies (for example, pixel tags and device identifiers) on our Website or sites of third parties. Our Website, like many websites, have tracking technologies, such as cookies, which are used to obtain certain types of information such as activities, current location of your device, type and version of your browser, your device OS and other device metrics when you visit our websites, apps or certain third parties’ websites or apps. We collect this information because it helps with provision of services to you and functionality of the website or app (if any).
    3. It is possible that you may provide to the Company someone else’s personal information to us. Instances of this include:
      1. When you purchase a gift for someone else;
      2. When you place an order on behalf or someone else; or
      3. When you leave information in relation to someone else that may be interested in any of our products, goods or services.

In providing personal information to us in relation to someone else, you must have their prior consent and we are entitled to request you to provide evidence of that consent. Please do not share with, or provide someone else’s personal information, to us if you don’t have their consent, or for any malicious or wrongful purposes.

  1. How we Collect Your Personal Information

    1. The Company may collect your personal information directly from you physically or online, including when you create an account to access our products, goods and/or services or when you visit our online stores or when you activate or use our services, interact with us, either in person, over the telephone or electronically (for example and including via our website(s), apps (if any), social media posts and information, chats, telephone, emails. We may also collect personal information about you from third parties.
    2. Your personal Information may also be collected, from your IP Address logged when you visit or log in onto our Website. Your IP Address and Information allows us to understand how you use our Website and to enable us to make changes to our website in order to improve your shopping experience. Information regarding your computer/phone, your connection to our website such as your browser type, operating system and your user history including but not limited to your session information, page errors and the length of your visits to specific pages within our Website may also be collected.
    3. The Company wishes to provide you with the highest level of service at all times. As such, we collect and hold personal information that helps us to provide the information, goods, products and/or services you are using or that you might be searching. If we do not collect your personal information, we may not be able to provide service to this level.

  1. How we use your Personal Information

    1. We may use personal information for the following purposes:
      1. To fulfil contractual obligations to which you are a party to, including purchase of products, goods and/or services, purchase order management and delivery or in order to take steps at your request;
      2. To communicate with customers regarding their purchase orders, requests and other customer service inquiries relating to our services, products and/or goods or Website;
      3. To enhance and personalize the user experience on the Company’s digital platforms;
      4. To create and administer a single sign-in account and to deliver functionality on our Website;
      5. To engage in transactions with customers, vendors, suppliers and business partners and to process orders in respect of the Company’s products, goods and/or services;
      6. To analyze, develop, improve and optimize the use, function and performance of our Website, products, goods and/or services;
      7. To manage the security and operations of our Website, facilities and networks and systems;
      8. To comply with applicable laws and regulations and to properly operate our business;
      9. To perform maintenance and after-sales services;
      10. To conduct marketing activities including sending you marketing communications such as newsletters, product information, sale on products information and/or any other information in relation to the Company’s products, goods and/or services and the Company businesses, subject to obtaining consent from the data subject; and
      11. To process an opt-out request.

  1. Nature of Personal Information Collected by the Company

    1. The Company collects, holds, shares and uses your personal information to sell goods, and products to you and to provide services to you, or to promote products, goods and services that you have requested, or which the Company thinks may be of interest to you. This may also include products and services provided by third parties.
    2. The Company will only process data where the Company has a lawful basis to undertake such Processing. Reference to the term “Processing” shall means collecting, recording, organizing, structuring, storing or holding, adapting or altering, retrieving, using, restricting, combining, disclosing, erasing or destroying personal information and the terms “Processes”, “Processed”, “Process” shall be construed accordingly.
    3. In addition to the above, the Company collects, holds, shares and uses your personal information for purposes listed below and our data Processing is performed on the basis of:
      1. Contractual necessity for the fulfilment of service provision in order to engage in transactions with customers, suppliers and business partners, and to process purchases and downloads of our products and services, we need to Process personal information about you necessary to enter into or perform a contract with you;
      2. The legitimate interests of the Company, provided these interests do not override the fundamental rights and freedoms of your rights as a data subject;
      3. Consent, specifically for purposes such as direct marketing and certain types of data processing as applicable;
      4. To ensure compliance with any legal obligation to which the Company is subject;
      5. For purposes permitted or required by law;
      6. To protect your vital interests of as a data subject or another natural person;
      7. To perform a task carried out in the public interest or in the exercise of official authority vested in the Company;
      8. For the exercise, by any person in the public interest, of any other functions of a public nature;
      9. For the legitimate interests pursued by the Company by a third party to whom the personal information is disclosed, except if the Processing is unwarranted in any particular case having regard to the harm and prejudice to the rights and freedoms or legitimate interests of the data subject;
      10. For the purpose of historical, statistical, journalistic, literature and art or scientific research;
      11. To manage your online shopping account(s);
      12. To manage, action and fulfil your online orders and maintain your accounts on our websites and apps (if any);
      13. To give you any points and rewards for any promotions or loyalty programs we may have for shopping with us;
      14. To provide you customer support if and when needed or necessary;
      15. To communicate with you and to send you any offers we may have and any other communications and direct marketing that may be of interest to you. This may include email, SMS, in-app messages (if any), push notifications and ads;
      16. For purposes of advertising to identify your preferences, to recommend and advertise features, products, goods and/or services and to personalise your experiences on our Website;
      17. To ensure security and safety, and for purposes of fraud detection, and to protect our employees and staff, our customers, our premises and any of our products, goods, services and/or systems from violent, malicious or detrimental activity;
      18. For purposes of improving our services, and customer experience (including our Website and technology). We consistently test, review and improve the functionality of our systems, products, goods and services; and
      19. To understand shopping wants and patterns, behaviours and preferences of our customers and determine our trading performance and that of our suppliers.

Please take note that when you register an account with us or become a member of any of our programs, we may communicate with you by sending you direct emails relating to marketing of our Company, products, goods and/or services. We use various media and means of communication which include email, SMS, telephone, push notifications, chatbots and mailing if you have not subscribed out of or opted out of receiving such direct messages.

  1. Data Sharing and Disclosure

    1. We work with third parties to ensure we are able to properly provide products, goods and services to you. As such, we may share personal information we have collected and hold for you. To the best of the Company’s knowledge, information and belief personal information will not be shared with third parties for their independent marketing or business purposes, however, data may be shared with other third parties, service providers (whose services are necessary to perform the Company’s obligations) or suppliers of the Company under strict confidentiality agreements to facilitate business operations and to ensure that we are able to properly provide our products, goods and services.
    2. The Company’s employees are authorized to access personal information of any of our customers or any person that provides personal information to us only to the extent necessary to serve the applicable purpose(s) and to perform their contractual duties and functions.
    3. The Company may disclose your personal information to third parties in connection with and in compliance with legal obligations under the Act or the Regulations or any other prescribed law or for commercial purposes subject to procuring your consent, which is unequivocally given by you as indicated in this policy.
    4. We may disclose your personal information with the following :
      1. third party service providers including without limitation suppliers, delivery service providers, insurers, mobile and internet service providers and other service providers who work with us to provide you products, goods and services globally;
      2. third-party service providers such as credit card processing services, order fulfilment, analytics, event management, website management, information technology and related infrastructure provision, customer service, e-mail delivery, auditing, and other similar service providers, in order for these service providers to perform business functions or contractual duties for the Company and on behalf of and for the Company;
      3. Relevant third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock including in connection with any bankruptcy or similar proceedings;
      4. As required by law, such as to comply with a legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to government requests, including public and government authorities outside your country of residence, for national security and/or law enforcement purposes;
      5. with any third party with whom we may run a loyalty or rewards program and so that you can receive personalised offers from us and those partners;
      6. for the purpose of marketing and advertising;
      7. with any entities, bodies, companies or business within our group of companies or our immediate and related network;  
      8. with third parties who offer operational and technical services or technology and software providers. They assist in our in-store, online and back-end systems and technology);
      9. we work with financial service providers and businesses and may also work with other service providers to help detect and prevent fraud, theft, malicious actions, to verify your identity (if necessary). We also work with law enforcement and other businesses to share information relating to an investigation or legal proceedings or court cases; and
      10. if permitted or required by law to be compliant with the law.
    5. When third parties are given access to your Personal Iinformation, we will take appropriate contractual, technical and organizational measures designed to ensure that personal information is processed only to the extent that such Processing is necessary, consistent with this Policy, and in accordance with the Act and the Regulations.
    6. Whilst will do all things reasonably possible to protect your personal information, the Company shall not be liable for any loss or damage, howsoever arising, suffered by you as a result of the disclosure of your personal information to any such third parties.

    1. How We Use Cookies on Our Website

The table below lists the cookies we collect and what information they store.

Cookie NameCookie Description
FORM_KEYStores randomly generated key used to prevent forged requests.
PHPSESSIDYour session ID on the server.
GUEST-VIEWAllows guests to view and edit their orders.
PERSISTENT_SHOPPING_CARTA link to information about your cart and viewing history, if you have asked for this.
STFInformation on products you have emailed to friends.
STOREThe store view or language you have selected.
USER_ALLOWED_SAVE_COOKIEIndicates whether a customer allowed to use cookies.
MAGE-CACHE-SESSIDFacilitates caching of content on the browser to make pages load faster.
MAGE-CACHE-STORAGEFacilitates caching of content on the browser to make pages load faster.
MAGE-CACHE-STORAGE-SECTION-INVALIDATIONFacilitates caching of content on the browser to make pages load faster.
MAGE-CACHE-TIMEOUTFacilitates caching of content on the browser to make pages load faster.
SECTION-DATA-IDSFacilitates caching of content on the browser to make pages load faster.
PRIVATE_CONTENT_VERSIONFacilitates caching of content on the browser to make pages load faster.
X-MAGENTO-VARYFacilitates caching of content on the server to make pages load faster.
MAGE-TRANSLATION-FILE-VERSIONFacilitates translation of content to other languages.
MAGE-TRANSLATION-STORAGEFacilitates translation of content to other languages.

  1. Linked Third Party Websites and Third-Party Content

    1. The Company may provide links to third party websites on the Website. These links are provided to you for convenience purposes only and the Company does not endorse, nor does the inclusion of any link imply the Company’s endorsement of such websites, their owners, licensees, administrators, content or security practices and operations.
    2. While the Company tries to provide links only to reputable websites or online partners of the Company, the Company cannot accept responsibility or liability for the information provided on these other websites or links. Linked websites or pages are not under, nor subject to, the control of the Company. The Company is not responsible or liable for and gives no warranties or makes any representations in respect of the privacy policies or practices of linked or any third party or advertised websites on the Website or on any of our platforms.
    3. You agree that the Company shall not be held liable, directly or indirectly, in any way whatsoever for the content, the use or inability to use or access any linked website or any link(s) contained in a linked website, nor for any loss or damage of any sort incurred as a result of any dealings with, or as the result of the presence of such third party linked websites on the Website or on any of our platforms. Any dealings that you may have with any linked websites, including advertisers, found on the Website or other platforms, are solely between you and the third-party website or link.

  1. Marketing

    1. If you are a past or current customer, we may contact you from time to time to inform you of products or services similar to those you have purchased from us before. We may also provide you with other material including adverts, write ups or newsletters with appropriate content as a value-added customer experience with our Company. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in all the emails we send.

  1. Exemption from Digital Service Tax (DST)

    1. The Company is exempt from Digital Service Tax (DST) under the guidelines provided by the Kenya Revenue Authority (KRA), because:
      1. The Company sells tangible products and goods that are not digital services.
      2. Invoices include the standard rate sixteen percent (16%) VAT and are processed through the same SAP system for both online and in-store transactions or any other prescribed rate as maybe revised by the relevant competent authority from time to time.
      3. The Company operates under the same KRA PIN and utilizes its proprietary platform and Website for sales, not a public marketplace.

  1. Retention Period

    1. The Company your personal information only as long as may be reasonably necessary to satisfy the purpose for which the personal information was processed unless the retention is:
      1. required or authorised by law;
      2. reasonably necessary for a lawful purpose;
      3. authorised or consented by the data subject; or
      4. for historical, statistical, journalistic literature and art or research purposes.
    2. The Company will ensure the deletion of personal information or the anonymisation of personal information to the extent that the user can no longer be identified, once the Company no longer has a legitimate need for such information.
    3. To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we Process your personal information and whether we can achieve those purposes through other means, the need to comply with our internal policy and the applicable legal, regulatory, tax, accounting, or other requirements.

  1. Data Retention Schedule

    1. The Company confirms that it retains personal information only for as long as necessary to fulfil the purposes for which it was collected, comply with legal obligations, undertake our businesses, resolve disputes, and enforce our agreements. Our Data retention schedule is as follows:
      1. Data subject data: We retain personal information related to data subjects for the duration of the business relationship and for a period afterwards as required by contractual, legal, or regulatory obligations.
      2. Website usage data: Website usage data is retained for a period necessary to analyse traffic, ensure website security, and improve user experience. The retention period may vary based on the nature and purpose of the data.
      3. Marketing data: Marketing data, including preferences, purchase history, and feedback, is retained for a period necessary to deliver targeted marketing logistic, track customer preferences, and improve marketing strategies. The retention period may vary based on the effectiveness and relevance of the data for marketing purposes.

  1. Data Security Measures

    1. Your personal information is important to us and we take steps to create systems and procedures with your security and privacy in mind. Any of your personal information that we hold is generally stored electronically in computers or cloud systems operated by us or by our service providers.
    2. The Company employs robust security measures to protect your Personal Information against accidental or unlawful damage, loss, modification, unauthorized access, alteration, disclosure, or destruction, in accordance with the Act and the Regulations. These measures are:
      1. Encryption, access control, secure software development practices, and regular security assessments;
      2. Maintaining measures such as physical and technical security access controls or other safeguards, security technologies to keep information secure, policies and procedures and training programs on security;
      3. Only personnel who have a need to know and are authorised to use personal information can access it;
      4. Treating your personal information as confidential;
      5. Maintaining certain technical and organisational measures to protect your personal information;
      6. As soon as reasonably possible after the discovery of a compromise, and insofar as we can establish your identity, notify you that there are reasonable grounds to believe that your personal information has been accessed or acquired by an unauthorised person; and
      7. Upon your reasonable written request, return or destroy any of your personal information which may be in our possession or control.
    3. Despite these measures, you acknowledge that the internet and online websites are not a secure medium, as such, personal information may be accessed by an unauthorised third In the event of a data breach leading to the accidental or unlawful damage, loss, modification, unauthorised disclosure or any unauthorised access to any Personal information that has been transmitted, stored or otherwise collected by the Company, the Company shall not guarantee or accept any liability whatsoever for accidental or unlawful damage, loss, modification, unauthorised or unlawful disclosures of your Personal information.

      1. Reporting Personal information Breaches

        1. The Act requires the Company to notify the Office of the Data Protection Commissioner (ODPC) established under Section 5 of the Act, of any Personal information Breaches and in certain instances, the data subject. In line with the Act, the Company will notify the ODPC of any notifiable Personal information Breaches within seventy-two (72) hours of becoming aware of such breaches.
        2. Any discovered or suspected Personal information Breaches including any losses comprising Personal information must immediately be reported to the designated office or through contact privacy information provided in section 19;

Reference to the term “Personal information Breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal information transmitted, stored or otherwise processed and the term “Personal Data Breaches” shall be construed accordingly.

  1. Data Subject Rights

    1. Data subjects are entitled to various rights under the Act and the Regulations. The Company shall ensure that it can facilitate any reasonable request made by the data subject to exercise their rights under the Act and Regulations including the right to:
      1. Request information about how their Personal information is being Processed, including whether that Personal information is being Processed and the right to be allowed access to Personal information which is in the Company’s custody and to be provided with a copy of their Personal information along with the right to obtain the following information:
        1. The purpose of the Processing and the use to which their Personal information is to be put;
        2. The categories of Personal information being Processed;
        3. The recipients to whom the Personal information has been disclosed or which may be disclosed;
        4. The retention period of the Personal information;
        5. The right to lodge a complaint with the office of the Data Protection Commissioner;
        6. The source of the information if not collected direct from the Data subject; and
        7. The existence of any automated decision making.
      2. Allow the Data subject to rectify inaccurate, false or misleading Personal information concerning them.
      3. Have Personal information erased and to have confirmation of erasure, but only where:
        1. The Personal information is no longer necessary in relation to the purpose for which it was collected;
        2. Consent to Process the Personal information is withdrawn expressly by the data subject;
        3. There is no legal basis for the Processing; or
        4. There is a legal obligation to delete the Personal information.
      4. Ask for certain Processing to be restricted in the following circumstances:
        1. if the accuracy of the Personal information is being contested;
        2. if the Company’s Processing is unlawful but the data subject does not want it erased;
        3. if the Personal information is no longer needed for the purpose of the Processing but it is required by the data subject for the establishment, exercise or defence of legal claims; or
        4. if the data subject has objected to the processing, pending verification of that objection.
      5. Receive a copy of Personal information which has been provided by the data subject and which is Processed by automated means in a format which will allow the data subject to transfer the data to another data controller.
      6. Object to the Processing of all or part of their Personal information unless the Company demonstrates compelling legitimate grounds for the Processing which overrides the interests of the Data subject or for the establishment, exercise or defence of a legal claim.
    2. If you believe that any of your Personal information is inaccurate, out of date, incomplete, irrelevant or misleading, please contact our Privacy Office using the Contact information in section 19.

  1. Children’s privacy

    1. As a company focused on serving the needs of our customers, this Website is not directed to minors and the Company does not promote or market its products or services to minors, except with parental permission and consent.
    2. If you believe that we have mistakenly or unintentionally collected personal information of a minor through our Website without appropriate consent, please notify us through our privacy contact information provided in section 19 so that we may immediately delete the information from our servers and make any other necessary corrections.

  1. Amendments to the Privacy Policy

    1. This Privacy Policy shall be updated periodically to reflect changes in legal, regulatory, or operational requirements. Continued use of the Company’s services and Webiste after any such updates constitutes acceptance of the revised privacy policy. It is possible that there may be additional privacy circulars, information, notices and terms relevant to you depending on the nature of your interactions and dealings with us and on our business.
    2. The Company will constantly review and revise the contents of this Policy from time to time. Any changes to this Policy will be posted online on our website www.idealceramics.com. Any changes to this Policy will become effective when we post the revised Policy on our website.

  1. Contact Information and Complaints

    1. For any inquiries or complaints regarding your Personal information or this Policy, please contact:
      • Email: sales@idealceramics.com
      • Telephone: +254 718 000 006/7/8
      • Head Office: Ideal Ceramics Ltd, Shimanzi, Mombasa, P.O.Box 82271-80100, Kenya
    2. The Company will acknowledge your complaint within fourteen (14) business days. The Company will only accept a complaint from the data subject’s representative if the representative provides the data subject’s written consent authorising the personal representative to act on the data subject’s behalf in relation to the complaint.
    3. Once all the identification requirements have been verified, the investigation will be carried out within 30 working days. If further clarification is required from the complainant or more time is required for the response to be completed, the Company will inform the complainant prior to the initial The Complaint outcome will be communicated to the complainant in writing by email.
    4. If the complainant does not agree with or is dissatisfied with the outcome, they can request a review of the decision. If the complainant is aggrieved by the Company’s decision after such review, the complainant may lodge a compliant with the Office of the

  1. General

    1. This Policy shall be governed in all respects by the laws of the Republic of Kenya.
    2. This Website and our platforms are controlled, operated and administered by the Company from its offices within the Republic of Kenya. The Company makes no representation that the content of the Website . Users may not use this Website or our platforms in violation of Kenyan laws and regulations. If the user accesses this Website or our platforms from locations outside of Kenya, that user is responsible for compliance with all local laws.
    3. Whilst reasonable care is taken to ensure that the information contained on the Website or our platforms is accurate, we cannot guarantee the accuracy thereof. The Company provides the Website and platforms on an “as is” and “as available” basis and makes no representations or warranties of any kind (express or implied) with respect to the Website or the Website Content (including, but not limited to any pictures, photographs of products, merchandise, text, graphics, advertisements, files, links, financial calculators, currency conversion or other items on the Website or platforms) and disclaims all representations and warranties.
    4. Refence to the term information in this policy shall be construed to mean, without limitation, information which (i) is processed by means of an equipment operating automatically in response to instructions given for that purpose; (ii) is recorded with intention that it should be Processed by means of such equipment; (iii) is recorded as part of a relevant filing system; (iv) forms part of an accessible record; or (v) any recorded information which is otherwise held by a public entity.
    5. This policy does not apply to the personal information of our employees, staff, agents or service providers in their capacity as such.