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Guarding Your Data: Our Commitment to Privacy Transparency

This website is provided by Waugh McDonald Wealth Management Limited (WMWM).

WMWM is committed to protecting the privacy of the people that we receive information about. This means that we take steps to lawfully, fairly and transparently process any personal data that is made available to us.

1. Introduction

Waugh McDonald Wealth Management Limited (WMWM) is committed to protecting the privacy and personal data of its customers. This privacy statement outlines the methods by which WMWM processes personal data and provides transparency on the reasons for data collection, usage, and how individuals can exercise their data rights.

2. Definitions

  • WMWM: Waugh McDonald Wealth Management Limited, including its successors, assigns, affiliates, and subsidiaries.

  • Personal Data: Information that uniquely identifies an individual such as name combined with address or identity number.

  • Processing: The range of actions performed on personal data, from collection to destruction.

  • Sensitive Personal Information: Data related to race, health, ethnicity, beliefs, genetics, family, or sexual orientation.

  • You: Refers to WMWM customers, visitors, suppliers, and anyone interacting with our services.

3. Collection of Personal Data

WMWM collects personal data to fulfill the commitments outlined in this privacy statement. Data is collected with consent, except when legally justified. This information can be provided:

  • When applying for or using WMWM products or services.

  • When communicating with WMWM.

  • Visiting WMWM premises or events.

  • Engaging online or subscribing to our digital platforms.

  • Responding to WMWM surveys or offers.

  • When applying to or engaging with WMWM Foundation programs.

4. What information is collected?

From our customers and their representatives, we might collect:

  • Identity and contact details, employment, and income information.

  • Details about interactions with WMWM including transactions, biometric data, or visits to our branches.

  • Compliance information, such as for 'Know Your Client' or anti-money laundering regulations.

  • Surveillance recordings for security purposes.

  • Visitor data, including vehicle and device details.

  • Internet usage details when using WMWM's Wi-Fi or visiting our website.

  • Information on minors, processed with parental or guardian consent


For Related Legal Entities: Although corporate entities are not data subjects, personal information about individuals might be collected, including:

  • Personal identification details.

  • Contact information.

  • Occupation details.

  • Details about ownership or control of a company.

5. Mailing Lists

To enhance our customer relationship and tailor marketing efforts, we may collect the following:

  • Your name and contact details.

  • Job title and employer details.

  • Specific interests related to our products or services.

  • Event attendance and other voluntarily provided details.

6. Purpose of Personal Data Processing

We prioritize clarity and transparency in our processing of your personal data. When the data relates to minors, we only process with parental or guardian consent, ensuring the child's best interests are always upheld.

Your data may be used for:

  • Identity verification for compliance with KYC norms.

  • Evaluating the nature of your business relationship with us.

  • Communicating and delivering services.

  • Monitoring potential fraud and financial crimes.

  • Improving our products and services.

  • Complying with legal mandates.

  • Marketing, unless you opt-out.

  • Employee and supplier relationship management.

  • Event documentation and promotion.

7. Sensitive Data Collection

We may gather personal data of a sensitive nature based on legal provisions outlined later. Such data includes details like race, health status, biometric data, family details, and more.

8. Personal Data Transfer

We may share your data for service delivery, legal reasons, and to protect our interests. This can include sharing with:

  • Regulatory bodies.

  • Support vendors, who are bound by confidentiality.

  • Foreign entities, ensuring adequate data safeguards.


We promise confidentiality when sharing with external parties for legal, fraud prevention, or other authorized reasons.

9. Grounds for Data Processing

WMWM processes your data based on:

  • Contractual obligations.

  • Legitimate business interests.

  • Legal claims.

  • Mandatory legal duties.

  • Protecting vital interests.

10. Direct Marketing

We might contact you for market research or to introduce other services. Based on your product usage, you might need to provide consent for marketing messages. However, you always have the right to opt-out.

11. Retention of Personal Data

WMWM retains your personal data only as long as needed to serve its collection purpose. Typically, this period spans up to seven years or as mandated by law. We may keep your data longer if:

  • We maintain an active relationship with you.

  • Legal obligations demand it.

  • It bolsters our legal standing.

12. Your Rights

Under applicable law, you have the right to:

  • Be informed about our data collection.

  • Access and obtain a copy of your data.

  • Request correction of inaccurate or incomplete data.

  • Withdraw consent for data processing, noting that prior consents remain unaffected. If we have a legal or legitimate reason, we might continue processing.

  • Request deletion of your data.

  • Limit data processing under certain conditions.

  • Have data portability, allowing you to receive or transfer your data in a commonly used electronic format.

13. Cookies

Our website uses cookies to enhance user experience. These capture non-personal details like your IP address, visit date and time, and page interactions. Cookies support preferences, sign-ins, targeted advertising, fraud prevention, and more. For customized services, we might aggregate this data. You can set your browser to decline cookies, but some website features may not function as intended.

14. Disclaimer

Our site may link to external websites. Their privacy policies might differ from ours. We advise you to review such policies before submitting your data, as we aren't responsible for them.

15. Contact Us

For inquiries or concerns about your data or rights, contact our Data Protection Officer at +254 759 704523 or email

16. Statement Updates

We may revise this privacy statement periodically. Continued engagement with our services implies your acceptance of any changes. Access the latest version at Changes become effective upon their website posting.

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