Draft. This is written to be accurate about what the software actually does, which is the hard part. It is not legal advice and has not been reviewed by an advocate. Every highlighted field needs filling in, and the whole document needs a Kenyan advocate's eye before launch — particularly the ODPC registration position and the cross-border transfer section.

Privacy notice

Last updated DATE · Governed by the Data Protection Act, 2019 (Kenya)

Funguo connects people looking for a home with the people who own one. This notice says what we hold about you, why, who else sees it, and how to make us delete it. It is deliberately short, because we deliberately collect little.

Who is responsible

The data controller is REGISTERED COMPANY NAME, of POSTAL ADDRESS, Nairobi, Kenya. Our data protection contact is privacy@yourdomain. Registration with the Office of the Data Protection Commissioner: ODPC REGISTRATION NUMBER, or "application pending".

What we collect, and why

What	Why	How long
Your phone number	It is your account. We text a one-time code to it; there is no password.	Until you ask us to delete the account
Your email address	Asked for once, at first sign-in, so we can reach you about your account or a listing.	Until you ask us to delete the account
Your name, as you type it	Shown to seekers on your listings, so they know who they are calling.	Until you ask us to delete the account
A photo of your national ID or passport, if you choose to upload one	So a moderator can check by hand that you are who you say you are, and turn on the "ID checked" badge.	RETENTION PERIOD after the check, then deleted
Your listings: address area, price, photos, description, contact number	They are the product. Everything in a listing is meant to be seen.	Until you delete the listing
A record that someone asked for a listing's contact number	To stop anyone harvesting every landlord's number in bulk.	RETENTION PERIOD, e.g. 12 months
M-Pesa payment records for agent plans and boosts	To grant what you paid for, and because tax law requires it.	As required by Kenyan tax law

What stays on your own device

If you are looking for a home rather than listing one, most of what you do never reaches us at all. Saved homes, the private notes you write on them, and side-by-side comparisons live in your browser's own storage. They are not uploaded, not backed up, and not visible to us. Clearing your browser data deletes them permanently, and we cannot get them back for you.

We run no analytics, no advertising pixels and no third-party scripts. There is no cookie banner because there are no tracking cookies to ask you about.

Who else sees it

Other users. Your listing, your display name and whether your ID has been checked are public to signed-in seekers. Your phone number is not in the listing data — a seeker has to press a button to ask for it, one listing at a time, and we count those requests.
Africa's Talking (or SMS PROVIDER) receives your phone number in order to deliver the sign-in code.
Safaricom, through the M-Pesa Daraja API, when you pay for an agent plan or a boost.
DigitalOcean, which hosts the database and the photo storage.
Anyone we are legally required to disclose to, on a lawful order.

We do not sell your data. We do not share it with landlords in bulk, with marketers, or with anyone building a list.

Where it is stored

Our database and photo storage run in DigitalOcean's Frankfurt region, so your personal data leaves Kenya. We chose Frankfurt because it is roughly 90ms from Nairobi against 250ms from the United States, and the app feels different at that distance. The Data Protection Act, 2019 permits transfer outside Kenya where appropriate safeguards exist; DESCRIBE THE SAFEGUARD RELIED ON — this is the sentence to get an advocate to write.

Your rights

Under the Data Protection Act, 2019 you may ask us to show you what we hold about you, correct anything wrong, delete it, or stop using it in a particular way. Write to privacy@yourdomain from the email on your account, or from the phone number you sign in with, and we will answer within RESPONSE TIME, e.g. 14 days.

Deleting your account deletes your profile, your listings and their photos, and any ID document we still hold. Payment records survive deletion where tax law requires us to keep them.

If you think we have handled your data badly, you can complain to us first — we would rather fix it — and you can complain to the Office of the Data Protection Commissioner either way.

How we protect it

Sign-in is a one-time code to your phone. There is no password to steal, and codes are stored only as a hash.
What each signed-in account may read or change is decided by the database itself, not by the website. An account cannot grant itself a verified badge, a bigger listing limit or an agent plan.
ID documents are stored privately, are never served publicly, and are readable only by the person who uploaded them and by a moderator.
Owner phone numbers are not present in the data the app downloads to browse listings.

Children

Funguo is for adults renting and buying property. We do not knowingly hold data about anyone under 18. If you believe we do, tell us and we will delete it.

Changes

If we change this notice we will say so on this page and update the date at the top. If a change materially affects you, we will text or email you.