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16. Amendments to this Statement

WMWM reserves the right to amend or modify this privacy statement from time to time. Your continued use of our products and services constitutes your agreement to be bound by the terms of any such amendment or variation. You can access the most current version of the privacy statement from and any amendment or modification to this statement will take effect from the date of notification on the WMWM website.

15. Contact Us

Please contact our Data Protection Officer if you:

  • Have any questions or concerns about how WMWM processes your personal data or

  • Want to exercise any of any of your rights in relation to your personal data, on +254 759 704523 or by writing to us on email:

14. Disclaimer

Our site may, from time to time, contain links to and from the website of our partner networks, advertisers, and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibilities or liability for these policies. Please check these policies before yu submit any personal data to these websites.

13. The use of Cookies

We may store some information (using "cookies") on your computer when you visit our websites. This enables us to recognize you during subsequent visits. The type of information gathered is non-personal(such as the Internet Protocol (IP)) address of your computer, the date and time of your visit, which pages you browsed, and whether the pages have been delivered successfully. We use cookies for storing anf honoring your preferences and settings, enabling you to sigh in, providing interest-based advertising combatting fraud, analyzing how our products perform, and fulfilling other legitimate purposes.


We may also use this data in aggregated form to develop customized services-tailored to your individual interests and needs. Should you choose to do so, it is possible (depending on the browser you are using), to be prompted before accepting any cookies or to prevent your browser from accepting any cookies at all. This may, however, cause certain features of the website not to be accessible.

12. Your Rights

You have the right (in the circumstances and under the conditions, and subject to the expectations set out in applicable law to:

  • Be informed that we are collecting personal data about you;

  • Request access to your personal information that we have on record. This right entitles you to know whether WMWM holds personal data of you and, if so, obtain information on and a copy of those personal data.

  • Request WMWM to rectify any of your personal data that is incorrect or incomplete.

  • Object to and withdraw your consent to processing of your personal data. The right entitles you to request that WMWM no longer processes your personal data. The withdrawal of your consent shall not affect the lawfulness of processing based on prior consent before its withdrawal. We may also continue to process your personal information if we have a legitimate of legal reason to do so.

  • Request the erasure of your personal data. This right entitles you to request the erasure of your personal data, including where such personal data would no longer be necessary to achieve the purposes.

  • Request the restriction of the processing of your personal data: This right entitles you to request that WMWM only processes your personal data in limited circumstances, including with your consent.

  • request portability of your personal data. This right entitles you to receive a copy (in a structured, commonly used, and machine-readable format) of personal data that you have provided to WMWM, or request WMWM to transmit such personal data to another data controller in an electronic format.

11. Retention of Personal Data

WMWM will only retain your personal data for as long as necessary to fulfill the purpose for which it was collected. We have specific records management and retention policies and procedures in place to ensure that personal data is deleted after a reasonable period.

The retention period for your personal data may be up to seven (7) years, or as required by applicable law. We may retain your personal data for the following reasons:

  • If we have an ongoing relationship with you.

  • To comply with a legal obligation.

  • To safeguard or improve our legal position.

10. Direct Marketing

WMWM may use your personal information to contact you for market research purposes or to provide information about other services that may be of interest to you. Depending on the products you use, you may be required to opt-in or provide explicit consent before receiving marketing messages from us.

We respect your right to control your personal data, and we want to ensure that you have the ability to manage your preferences. Therefore, we will always provide you with the opportunity to opt-out of receiving direct marketing or market research communications. You can exercise your right to opt-out at any time.

9. Legal Basis for Processing Personal Data

WMWM will process your personal information as permitted by the applicable Data Protection Law and its internal policies:

  • For the performance of a product/service contract to which you are party to.

  • Where the processing is necessary for the purpose of legitimate business interests pursued by WMWM or by a third party within the confines of the law.

  • For the establishment, exercise, or defense of a legal claim.

  • Compliance with a mandatory legal obligation.

  • To protect your vital interest or the vital interest of any person.

8. Transfer of Personal Data 

WMWM may transfer your personal information for the purpose of effecting, implementing, administering, and securing any product or service that you have applied for, as well as for other purposes outlined in this privacy statement. We may also share data with WMWM-controlled affiliates and subsidiaries, vendors working on our behalf, when required by law or to respond to legal process, to protect our customers and lives, to maintain the security of our products, to comply with regulatory requirements, and to protect the rights and property of WMWM and its customers.


We may transfer or disclose the personal data we collect to regulatory, fiscal, or supervisory authorities, correspondent banks for transaction enquiries, third-party contractors, subcontractors, and their subsidiaries and affiliates who provide support to WMWM in delivering its services. These third-party providers may engage their own third-party subcontractors with access to personal data (sub-processors). It is our policy to engage only third-party providers that are bound to maintain appropriate levels of security and confidentiality, process personal information as instructed by WMWM, and extend the same obligations to their sub-processors.


On occasion, we may need to transfer your personal information to countries outside the country where you are located, including countries outside the European Economic Area and Kenya, which may not have specific data protection laws. When we send your information to a foreign country, we will ensure that there are adequate data protection safeguards in place in the recipient country or obtain your consent for the transfer of your personal information.


We may also disclose your personal information where required by law, to enforce other agreements, or to protect the rights, property, or safety of our business, clients, customers, employees, or others.


WMWM may disclose, respond, advise, exchange, and communicate personal data and/or information held by WMWM relating to you to external parties, even after you cease to be a customer, during the WMWM-customer relationship, or prior to the relationship, provided that such personal information is treated confidentially by the recipient. This may include:

  • Fraud prevention, detection, and investigation purposes.

  • Sharing with WMWM's external lawyers, auditors, subcontractors, software developers, or other authorized agents.

  • Disclosure to any person who may assume WMWM's rights within the confines of the law.

  • Providing income tax-related information to tax authorities.

  • Sharing with regulatory, fiscal, or supervisory authorities, local or international law enforcement agencies, governmental agencies to assist in the prevention, detection, investigation, or prosecution of criminal activities, courts, or arbitration tribunals where the demand for personal data and/or information is within the law.

  • Where WMWM has a right or duty to disclose or is permitted or compelled to do so by law.

7. Sensitive (Special Category) Data 

We may collect Special Categories of Personal Data about you, which includes details about your race, health status, ethnic origin, social origin, conscience, belief, genetic data, biometric data, property details, marital status, family details (including details of your children, parents, spouse or spouses), sex or sexual orientation, and biometric data. The collection of such data will be based on one or more legal bases provided in clause 9 below.

6. Use of Personal Data

This privacy statement aims to provide you with complete and transparent information on how WMWM processes your personal data. We are committed to ensuring that your personal information is processed in a manner that is compatible with the specified, explicit, and legitimate purpose of collection.

When personal data relates to a child, we will process the personal data only with parental or legal guardian consent. The processing of such data will be done in a manner that protects and advances the rights and best interests of the child.

We may use the personal data provided to us for any of the following purposes, but not limited to:

  • Verifying your identity information through publicly available and/or restricted government databases to comply with applicable Know Your Customer (KYC) requirements.

  • Assessing the purpose and nature of your business or principal activity, your financial status, and the capacity in which you are entering into the business relationship with us.

  • Creating a record of you on our system to verify your identity and provide you with the products and/or services you have applied for.

  • Communicate with you and keep you informed about the products and/or services you have applied for.

  • Verification of age and consent where the personal data relates to a child.

  • Identifying you and verifying your physical address.

  • Identifying your source of income and similar information.

  • Assessing your personal financial circumstances and needs before providing advice to you.

  • Responding to any queries or concerns, we may record or monitor telephone calls between us so that we can check instructions and make sure that we are meeting our service standards. 

  • To perform our obligations under a contractual arrangement with you.

  • Fraud prevention, detection, and investigation.

  • Any purpose related to prevention of financial crime, including sanctions screening, monitoring of anti-money laundering, and any financing of terrorist activities.

  • Further processing for historical, statistical or research, survey, and other scientific or business purposes where the outcomes will not be published in an identifiable format.

  • Provide aggregated data (which do not contain any information which may identify you as an individual) to third parties for research and scientific purposes.

  • In business practices, including quality control, training, and ensuring effective systems operations.

  • To understand how you use our products and services for purposes of developing or improving products and services.

  • Administering any of our online platforms/websites.

  • To comply with any legal, governmental, or regulatory requirement or for use by our lawyers in connection with legal proceedings.

  • For purposes relating to the assignment, sale, or transfer of any of our businesses, legal entities or assets, in whole or in part, as part of corporate transactions.

  • Keeping you informed generally about new products and services and contacting you with offers or promotions based on how you use our or third-party products and services, unless you opt out of receiving such marketing messages (you may contact WMWM at any time to opt out of receiving marketing messages).

  • Where you have applied for employment at WMWM, we perform application screening and background checks.

  • Where you are a WMWM employee (including contractors), we create an employment record of you on our system to facilitate continuous monitoring during your employment with us.

  • Where you are a WMWM director, we create a record of you as a director on our system. 

  • Where you are a supplier to WMWM, we process your personal information for due diligence, risk assessment, administrative and payment purposes. 

  • For security purposes when accessing any of WMWM buildings/premises.

  • Where you attend an event sponsored by WMWM, we will be taking photos or videos of the event. These images and videos will be used by us to share news about the event, and may be used in press releases, printed publicly, and published on our website.

5. Mailing Lists

We also collect information to enhance the customer experience and market our products and/or services that may be of interest to you. For this purpose, we collect:

  • Name and contact details.

  • Other business information, such as job title and the company you work for.

  • Products and/or services that interest you.

  • Additional information may be collected, such as events you attend, if you provide it to us.

4. What information is collected?

From individuals who are our customers and prospective customers or are representatives of customers and prospective customers, we may collect personal information that includes but is not limited to the following:

  • Your identity information, including your title, name, photograph, marital status, nationality, occupation, residence, address, location, phone number, identity document type and number, date of birth, age, gender, your email, Facebook, and Twitter address.

  • Name of your employer, terms of employment, and if on contract, expiry of the contract.

  • Your estimated monthly income levels.

  • If you are a student, your college or university and graduation date.

  • Your signature specimen.

  • Your credit or debit-card information, information about your bank account numbers and/or other banking information.

  • Your transaction information when you use our electronic and digital platforms.

  • Your preferences for particular products and services, based on information provided by you or from your use of our network or third-party products and services.

  • Name, family details, age, profiling information such as the level of education, bank account status, income brackets, etc., collected as part of surveys conducted by our agents and us on behalf of WMWM.

  • Your contact with us, such as when you: call us or interact with us through social media or email (we may record your conversations, social media or other interactions with us), register your biometric information such as your voice, fingerprints, etc., or visit our branches.

  • Relevant information as required by regulatory Know Your Client and/or Anti Money Laundering regulations and as part of our client intake procedures. This may possibly include evidence of the source of funds, at the outset of and possibly from time to time throughout our relationship with clients, which we may request and/or obtain from third-party sources. The sources for such verification may include documentation, which we request from you or through the use of online or public sources or both.

  • We use Closed Circuit Television (CCTV) surveillance recordings. CCTV Devices are installed at strategic locations to provide a safe and secure environment in all our premises as a part of our commitment to security and crime prevention.

  • We maintain a register of visitors in which we collect and keep your personal data such as names, company/institution details, telephone number, vehicle registration details, National ID number, and device serial number and model (where you visit our premises with your personal devices, e.g., laptops). This information is collected for health, safety, and security purposes.

  • When you use WMWM WIFI for guests and visitors, we collect email IDs and will provide a username and password. We record the device address and also log traffic information in the form of sites visited, duration, and date sent/received.

  • Information you provide to us for the purposes of attending meetings and events.

  • When you visit our website, we collect your ID-type information: cookie ID, mobile ID, IP address which is used for real-time processing in order to generate a visitor ID.

  • We may collect details of a minor which include name, date of birth, birth certificate number, relationship with the applicant, and any other information relevant to the provision of our products and services. We will only process such data where parental or legal guardian consent has been given. We will also ensure that the processing of such data will be done in a manner that protects and advances the rights and best interests of the child.

Related Legal Entities

Even though corporate entities and clients that form part of our client base are not data subjects as part of our engagement with these clients, we may receive personal information about individuals, which may include but is not limited to:

  • Full names.

  • Birth certificate number, national identity card number, or passport number; personal identification number (PIN).

  • Date of birth.

  • Postal and business address.

  • Residential address, telephone number, and email address.

  • Occupation or profession.

  • Nature of ownership or control of the company.

  • Number of shares in the company.

3. Collection of Personal Data

WMWM will only collect personal data about you insofar as is necessary to achieve the purposes set out in this privacy statement. We collect your personal information with your knowledge and consent, except in cases where prior consent cannot be obtained for legitimate reasons and the data processing is permitted by law.


Personal information may be given to or collected by WMWM in writing as part of a written application form, electronically (email), telephonically, online, or through an Application.


WMWM will collect your personal information when you do any of the following (but not limited to):

  • Make an application, buy, or use any of our products and/or services.

  • Ask WMWM for more information about a product or service or contact WMWM with a query or a complaint.

  • When you visit or access any of WMWM buildings/premises.

  • When you've been identified as next of kin by our customer or employee.

  • When you have applied for employment at WMWM.

  • Attend an event sponsored by WMWM.

  • Make an application to WMWM or interact with us as a supplier, agent, or dealer.

  • Visit, access, or use any of our online platforms/websites.

  • Subscribe to any of our online services, Short Message Service (SMS), email, or social media platforms.

  • Respond to or participate in a survey, marketing promotion, prize competition, or special offer.

  • We may also collect your information from other organizations, including credit reference bureaus, fraud prevention agencies, government agencies, and business directories.

  • When you make an application or engaging with WMWM Foundation as a beneficiary in any of our programs.

2. Definitions

“WMWM” “We,” “our,” “ours,” and “us,” means Waugh McDonald Wealth Management Limited and includes its successors in title and assigns, its affiliates, and/or its subsidiaries as may from time to time be specified by us to you.

“Personal data” or “personal information” means Information about you or information that identifies you as a unique individual, such as your name/s and surname combined with your physical address, contact details, and/or passport/identity number.

“Processing” collectively means handling, collecting, using, altering, merging, linking, organizing, disseminating, storing, protecting, retrieving, disclosing, erasing, archiving, destroying, or disposing of your personal information.

“Sensitive personal information” includes data revealing your race, health status, ethnic, social origin, conscience, belief, genetic data, biometric data, property details, marital status, family details, including details of your children, parents, spouse or spouses, sex or sexual orientation.


"You" means:

  • Customers, which includes personal representatives, assigns, legal entities operating an Account held with us and includes (where appropriate) any person you authorize to give us instructions, the person who uses any of our products and services or accesses our website.

  • Any Visitor that is a person (including contractors/subcontractors or any third parties) who gains access to any of our premises.

  • Any suppliers/service provider whom WMWM has contracted.

Data Privacy Statement

1. Introduction

​This privacy statement describes how Waugh McDonald Wealth Management Limited (WMWM) protects the personal data it processes, why and how we collect and use your personal data, and how you can exercise your rights in relation to the processing of your personal data.

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.

Privacy Policy 

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