Effective date: 15 September 2026

Privacy Policy

Comrade Kejani ("Comrade Kejani", "we", "us", or "our") respects your privacy and is committed to handling personal data responsibly.

This Privacy Policy explains what personal data we collect, why we collect it, how we use and share it, how we protect it, and the choices and rights available to you when you use Comrade Kejani.

Comrade Kejani is a student housing platform that helps people discover accommodation and connect with landlords. Because housing decisions can involve personal information and direct communication between users, we collect only the information we reasonably need to operate the platform and support the housing journey.

This policy is intended to apply to users of Comrade Kejani in Kenya and is designed with the Kenya Data Protection Act, 2019 and applicable regulations in mind.

1. Who is responsible for your data?

Comrade Kejani is responsible for determining how and why personal data is processed through the platform, except where a third-party service acts as an independent controller for its own processing.

For privacy questions or requests, contact us at: privacy@comradekejani.co.ke

Where another service processes personal data on our behalf, we may use that service as a data processor.

2. Personal data we collect

The information we collect depends on how you use Comrade Kejani.

Information you provide directly

  • Name
  • Email address
  • Phone number
  • Account and profile information
  • Property or accommodation details submitted by landlords
  • Messages and other communications sent through the platform
  • Reviews, photos, descriptions, and other content you choose to submit
  • Information provided when contacting support

Information related to housing

When you search for or enquire about accommodation, we may process information such as:

  • Areas or campuses you are interested in
  • Housing preferences and search criteria
  • Preferred move-in dates
  • Enquiries and interactions with landlords
  • Application-related information where the platform supports applications

Information collected automatically

When you use the website or platform, we may collect technical and usage information such as:

  • IP address
  • Browser and device information
  • Pages or listings viewed
  • Search and interaction activity
  • Approximate location information where enabled and necessary
  • Cookies and similar technologies
  • Security and diagnostic information

We use this information to operate, secure, understand, and improve the platform.

3. Why we use personal data

We use personal data for purposes including:

Providing the platform

To create and manage accounts, display accommodation, enable enquiries and communication, provide support, and operate Comrade Kejani.

Helping users make housing decisions

To remember relevant preferences, improve search and discovery, and provide information that helps users compare accommodation.

Supporting landlords

To help landlords create, manage, and maintain property listings and communicate with prospective tenants.

Safety and fraud prevention

To identify suspicious activity, investigate reported concerns, protect accounts, and help maintain a safer platform.

Communications

To send service-related messages, respond to enquiries, provide support, and communicate important changes affecting your use of the platform.

Where marketing communications are sent, we will provide appropriate choices and respect applicable opt-out requirements.

Improving Comrade Kejani

To understand how the platform is used, identify problems, improve features, conduct product analysis, and develop better housing experiences.

Legal and regulatory obligations

To comply with applicable laws, regulations, lawful requests, and legal processes.

4. Our lawful basis for processing

Depending on the circumstances, we may process personal data where:

  • It is necessary to provide a service you have requested or to take steps at your request before providing that service.
  • We are required to do so by law.
  • Processing is necessary for a legitimate interest that is not overridden by your rights and freedoms.
  • You have provided valid consent for a particular purpose.

Where we rely on consent, you may withdraw that consent where applicable. Withdrawal does not affect processing that occurred lawfully before the withdrawal.

5. Information shared with other users

Some information must be shared to make Comrade Kejani work.

For example, when a student contacts a landlord about a listing, information necessary for that communication may be shared with the landlord.

Similarly, information submitted by a landlord about a property may be displayed to people viewing the listing.

We encourage users to avoid publishing unnecessary personal information in public listing descriptions, messages, reviews, or other content.

6. Service providers and third parties

We may use trusted third-party service providers to help us operate Comrade Kejani.

These may include providers supporting:

  • Hosting and cloud infrastructure
  • Email and communications
  • Analytics
  • Security and fraud prevention
  • Authentication and account services
  • Customer support
  • Other technical services required to operate the platform

Where a provider processes personal data on our behalf, we require appropriate contractual and security measures.

We do not sell your personal data as a product.

7. Legal and safety disclosures

We may disclose personal data where reasonably necessary to:

  • Comply with applicable law or a lawful request
  • Protect the rights, property, or safety of Comrade Kejani, our users, or others
  • Investigate suspected fraud, abuse, or security incidents
  • Establish, exercise, or defend legal claims
  • Respond to regulators, courts, law enforcement, or other authorized bodies

We disclose only information that is reasonably relevant to the purpose where practicable.

8. Cookies and similar technologies

We may use cookies and similar technologies to keep the platform functioning, remember preferences, understand usage, improve performance, and support analytics.

Some cookies may be essential to the operation of the website. Others may depend on your choices and applicable consent requirements.

You can manage certain cookie and browser settings through your browser or any controls we provide on the platform.

9. Analytics

We may use analytics tools to understand how visitors use Comrade Kejani, such as which pages are visited, how users navigate the website, and how the platform performs.

Analytics data is used to improve the service and understand product usage.

Where an analytics provider receives personal data, its own privacy practices may also apply.

10. Location information

Location can be useful when searching for accommodation because proximity to campus and nearby services can affect a housing decision.

Where location information is collected, we aim to use only the level of location information necessary for the relevant feature or purpose.

You may also control certain location permissions through your device or browser settings.

11. Sensitive personal data

We do not generally need sensitive personal data to provide ordinary housing discovery services.

Where sensitive personal data is necessary for a specific purpose, we will process it only where there is an applicable lawful basis and appropriate safeguards.

Do not submit sensitive personal information unless the platform specifically requests it for a legitimate purpose.

12. Identity and verification information

If Comrade Kejani introduces verification processes that require identity information, we may collect information reasonably necessary for that verification.

Where verification documents are collected, access should be limited to authorized purposes, and the information should be retained only for as long as reasonably necessary or as required by law.

13. Communications and user-generated content

Messages, reviews, photographs, property descriptions, support requests, and other content you submit may contain personal data.

We process this information to provide the relevant feature, maintain the platform, respond to issues, investigate reports, and protect the community.

Do not share another person's personal information without an appropriate reason or authorization.

14. Children's privacy

Comrade Kejani is intended primarily for adults using the platform for housing and rental purposes.

Under Kenya's data protection framework, additional requirements apply when processing a child's personal data, including parental or guardian consent and appropriate protection of the child's best interests.

If we become aware that personal data relating to a child has been collected in circumstances where the required safeguards were not met, we will take appropriate steps in accordance with applicable law.

15. International transfers

Some of our technology and service providers may process personal data outside Kenya.

Where personal data is transferred outside Kenya, we will do so in accordance with applicable Kenyan data protection requirements and use appropriate safeguards where required. Kenyan law places conditions on transfers of personal data outside Kenya, including appropriate safeguards and other permitted grounds.

16. How long we keep personal data

We keep personal data only for as long as it is reasonably necessary for the purpose for which it was collected, unless a longer period is required or permitted by law.

Our retention approach takes into account:

  • The purpose for which the information was collected
  • Whether an account or housing relationship remains active
  • Legal, accounting, or regulatory requirements
  • Dispute resolution and enforcement needs
  • Security and fraud-prevention needs

When personal data is no longer required, we take appropriate steps to delete, anonymize, or otherwise dispose of it in accordance with our retention practices and applicable law. Kenya's regulations require controllers and processors to establish retention schedules and review retained data periodically.

17. Account deletion

If you request deletion of your account, we will process the request in accordance with applicable law.

Deletion may not result in the immediate removal of every record where we are required or permitted to retain certain information for legal, security, dispute-resolution, or other legitimate purposes.

Where information is retained, we will limit its use to the purposes for which retention is necessary.

18. Security

We use reasonable administrative, technical, and organizational measures designed to protect personal data from unauthorized access, disclosure, alteration, loss, or misuse.

No online system can be guaranteed to be completely secure. For this reason, users should also protect their account credentials and avoid sharing sensitive information unnecessarily.

19. Your data protection rights

Subject to applicable law and relevant conditions, you may have rights including:

  • The right to be informed about how your personal data is used
  • The right to access personal data we hold about you
  • The right to request correction of inaccurate or misleading data
  • The right to request deletion or erasure where permitted
  • The right to object to certain processing
  • The right to request restriction of processing in applicable circumstances
  • The right to data portability where applicable

These rights are recognized within Kenya's data protection framework.

20. How to make a privacy request

To ask a privacy question or exercise a data protection right, contact:

privacy@comradekejani.co.ke

Please provide enough information for us to understand your request and, where reasonably necessary, verify your identity.

We will handle requests in accordance with applicable law.

21. Complaints

If you believe your personal data has been handled in a way that violates applicable data protection law, please contact us first so that we can investigate and respond.

You may also have the right to lodge a complaint with the Office of the Data Protection Commissioner (ODPC) in Kenya. The ODPC is the statutory authority responsible for oversight and enforcement of Kenya's data protection framework.

22. Changes to this Privacy Policy

We may update this Privacy Policy when our services, technology, legal obligations, or data practices change.

When we make material changes, we will update the effective date and provide additional notice where required.

23. Contact us

For privacy questions, requests, or concerns:

Comrade Kejani

Email: privacy@comradekejani.co.ke

For general support, please use the support options available on the Comrade Kejani platform.