Privacy Policy

1. Information We Collect

Personal Data: Name, email, phone number, physical address, identity documents, payment information, and communication history.

Usage Data: IP addresses, browser type, pages visited, time spent on pages, and device information.

2. How We Use Your Information

We use your data to provide our Service, process payments, verify identity, prevent fraud, send notifications, and improve our platform.

Who controls my personal information?

When this policy mentions "Comrade Kejani," "we," "us," or "our," it refers to the entity responsible for your personal information under this Privacy Policy (the Controller). We also use separate controllers for payment and insurance services where required by law.

• The Controller is the Comrade Kejani entity responsible for the platform.
• Payments Controller applies to payment services and related transaction data.
• Insurance Controller applies to insurance-related data when you use those services.

Personal information we collect

We collect information needed to provide bookings, support, and a safe travel experience, as well as information you choose to share.

• Contact, account, and profile information like name, email, phone, and profile photo.
• Identity data such as government IDs, tax identifiers, and verification documents.
• Payment transaction information including payment account details, transaction dates, and amounts.
• Guest insurance and host insurance information when you choose those services.
• License, permit, and professional information for hosts when required by law.
• Communications data such as messages, call logs, and support transcripts.
• Content you provide like reviews, photos, descriptions, and other user-generated materials.
• Automatically collected data such as usage, device, location, cookies, and similar technologies.
• Data from third parties including connected services, public sources, referrals, and partners.

Definitions and examples

Examples: “Personal information” includes your name and contact details; “Usage data” includes pages you view, searches you make, and device identifiers; “Sensitive data” includes government IDs and certain verification documents.

Lawful bases for processing

Where applicable, we process personal information on several lawful bases: to perform a contract (for bookings and payments), to comply with legal obligations, to protect vital interests, and, where permitted, on our legitimate interests (for fraud prevention, analytics, and improving our services) or with your consent (for marketing communications and some tracking technologies).

Cross-border transfers

We may transfer personal information to Affiliates and service providers located outside your country. Where required by law, we use contractual safeguards and other measures to protect your information when it is transferred internationally.

Sensitive information

We generally do not seek sensitive personal information. If you provide sensitive data such as government ID documents for verification, we process it only as necessary for verification and legal compliance and with appropriate safeguards.

Children’s privacy

Our services are not directed to children under 13. We do not knowingly collect personal information from children. If we learn that we have collected such data, we will delete it in accordance with applicable law.

How long we keep personal information

Retention depends on the purpose and legal requirements. We keep booking and transaction records for tax and accounting obligations, customer support records to resolve disputes and safety events, and analytics data for service improvement. When data is no longer needed, we delete or anonymize it.

How to exercise your rights

If you want to exercise any privacy rights we describe (access, correction, deletion, portability, objection), you can:

• Visit your account settings and privacy dashboard (if available).
• Submit a request via our privacy request form or the support portal.
• Contact privacy@ComradeKejani.example or the support team for assistance.

Complaints and supervisory authorities

If you are not satisfied with our response to a privacy request, you may lodge a complaint with your local data protection authority. We will work with authorities as required to resolve issues.

How we use personal information

We use personal information to operate the platform, provide services, improve our products, and keep the community safe.

• To provide, personalize, and maintain the platform and its features.
• To communicate with you, respond to requests, and deliver support.
• To process bookings, payments, cancellations, and refunds.
• To prevent fraud, abuse, and safety risks and to protect our community.
• To develop and improve our services, including product research and analytics.
• To comply with legal obligations and respond to lawful requests.

Who we disclose personal information to

We may disclose personal information to other members, partners, service providers, authorities, and our affiliates where necessary to provide our services or comply with law.

Why we disclose personal information

Disclosure helps us deliver bookings, support operations, marketing, customer care, payment processing, insurance, safety, and legal compliance.

Third-party partners and integrations

We work with third-party partners for payments, verification, analytics, marketing, and other services. These partners are contractually required to protect your data.

Changing your country or state of residence

Your country or state of residence may affect which privacy rules and controllers apply to your data. We update those details when you change your residency information.

Your rights

Depending on where you live, you may have rights to access, correct, delete, or restrict how we use your personal information.

• Access and review the personal information we hold about you.
• Update or correct inaccurate details.
• Request deletion where permitted by law.
• Control certain uses of your data, such as marketing preferences.

Retention

We keep personal information only as long as needed for the purposes described in this policy and as required by law.

Security

We use administrative, technical, and physical measures to help protect personal information against unauthorized access, loss, or alteration.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will update the effective date and notify you when required.

Soft-Delete Data Retention

When you delete your account, your personal data undergoes a "soft delete" process. This means your data is marked as deleted but retained for important purposes:

• Legal Compliance: To comply with tax, financial, and legal obligations
• Dispute Resolution: To resolve disputes and enforce agreements
• Platform Improvement: To analyze trends and improve our services using anonymized and aggregated data
• Security: To prevent fraud and maintain platform security
• Historical Records: To maintain accurate booking and transaction history

Soft-deleted data is not visible to you and is not used for marketing purposes. We retain such data for a maximum of 24 months after deletion, after which it is permanently destroyed. During retention, only authorized personnel can access this data for the purposes listed above.

Contact information

If you have questions about this policy or how we handle personal information, contact our support team at privacy@comradekejani.co.ke.