Privacy Policy

This Privacy Notice for Qwangu (“we”, “us”, or “our”), describes how and why we might access, collect, store, use, and/or share (“process”) your personal information when you use our services (“Services”), including when you:

• Visit our website at https://qwangu.co.ke, or any website of ours that links to this Privacy Notice
• Download and use our mobile application (Qwangu), or any other application of ours that links to this Privacy Notice
• Use Qwangu. Qwangu is a Kenyan online property platform where owners and agents list vacant houses to let or for sale, and seekers browse listings, compare true costs, and contact owners directly.
• Engage with us in other related ways, including any marketing or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at [email protected].

Summary of Key Points

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by using the table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? Yes, but only if you choose optional agent ID verification. In that case we process your government ID document and a selfie, and compare the two faces to help an administrator confirm they match. We do not create or store a faceprint, and the comparison never decides the outcome by itself. Nothing here applies if you do not submit those documents.

Do we collect any information from third parties? We do not collect any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process your information only when we have a valid legal reason to do so.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific categories of third parties.

How do we keep your information safe? We have adequate organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? The easiest way to exercise your rights is by visiting https://qwangu.co.ke/contact, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Table of Contents

1. What Information Do We Collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names
• phone numbers
• email addresses
• usernames
• passwords
• contact or authentication data

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

• national identity or other government identifiers (for optional agent ID verification)
• biometric data, in the limited form described under “Face comparison” below (for optional agent ID verification only)

Face comparison. If you choose to submit an ID document and a selfie for optional agent verification, our system compares the face on the document with the face in the selfie to help an administrator judge whether they are the same person. This comparison runs on our server only while an administrator is reviewing your submission. We do not create or store a facial template, faceprint or other biometric identifier, and the comparison result is shown only to the reviewing administrator — it is never saved to our database and never decides the outcome on its own. A human administrator makes every verification decision. Your ID document and selfie themselves are stored in a private area readable only by administrators, and are covered by the retention rules in “How long do we keep your information?”. Agent verification is entirely optional: you can use Qwangu without submitting either.

Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Google account. If you choose to register in this way, we will collect certain profile information about you from the social media provider, as described in the section called “How do we handle your social logins?” below.

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

• Geolocation Information. We may request access or permission to track location-based information from your mobile device to provide certain location-based services. You may change our access or permissions in your device’s settings.
• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your camera and storage, and other features. You may change our access or permissions in your device’s settings.
• Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model, Internet service provider and/or mobile carrier, and Internet Protocol (IP) address.
• Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). You may opt out in your device’s settings.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, and information about how and when you use our Services. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Notice: https://qwangu.co.ke/cookies.

The information we collect includes:

• Log and Usage Data. Service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services. This may include your IP address, device information, browser type and settings, and information about your activity in the Services.
• Device Data. Information about your computer, phone, tablet, or other device you use to access the Services, such as IP address, device identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, and operating system.
• Location Data. Information about your device’s location, which can be either precise or imprecise. You can opt out of allowing us to collect this information by disabling your Location setting on your device, though you may then be unable to use certain aspects of the Services.

2. How Do We Process Your Information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts.
• To deliver and facilitate delivery of services to the user.
• To respond to user inquiries and offer support to users.
• To enable user-to-user communications, such as connecting a seeker with a property owner or agent.
• To request feedback and to contact you about your use of our Services.
• To protect our Services, including fraud monitoring and prevention and to keep our Services safe and secure.
• To identify usage trends and to improve our Services.
• To comply with our legal obligations.

3. When and With Whom Do We Share Your Personal Information?

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. We have data processing agreements in place with these providers, who fall into the following categories:

• Cloud Computing Services
• Data Storage Service Providers
• User Account Registration & Authentication Services
• Website Hosting Service Providers
• Communication & Collaboration Tools
• Performance Monitoring Tools
• Social Networks
• Security & Fraud Prevention Services

We also may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Other Users. When you share personal information or otherwise interact with public areas of the Services, such information may be viewed by all users. For example, when a seeker contacts a property owner or agent through the Services, the parties can see each other’s contact details (such as name and phone number) in order to communicate about a listing.

4. Do We Use Cookies and Other Tracking Technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and keep you signed in.

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice: https://qwangu.co.ke/cookies.

5. How Do We Handle Your Social Logins?

In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account details (like your Google login). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, and profile picture, as well as other information you choose to make public on such a social media platform.

We will use the information we receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider.

6. How Long Do We Keep Your Information?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, and in any case for no longer than the period of time in which users have an account with us. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible, then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. How Do We Keep Your Information Safe?

In Short: We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. You should only access the Services within a secure environment.

8. Do We Collect Information From Minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at [email protected].

9. What Are Your Privacy Rights?

In Short: Depending on your state of residence or country, you may have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA, UK, and Kenya), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. To make such a request, please use the contact details provided below.

Withdrawing your consent. If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. However, this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Account Information. If you would at any time like to review or change the information in your account or terminate your account, you can log in to your account settings and update your user account, or contact us using the contact information provided. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms, and/or comply with applicable legal requirements.

If you have questions or comments about your privacy rights, you may email us at [email protected].

10. Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

11. Do We Make Updates to This Notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated “Last updated” date at the top of this Privacy Notice. If we make material changes, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

12. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may email us at [email protected], or contact us through our contact page. We are based in Kenya.

13. How Can You Review, Update, or Delete the Data We Collect From You?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. To request to review, update, or delete your personal information, please visit https://qwangu.co.ke/contact.