Privacy Policy

PlugConnect KE is a digital marketplace designed to connect customers with providers of:

• Residential properties
• Rental properties
• Accommodation and stays
• Vehicles
• Commercial spaces
• Professional and other services

PlugConnect KE provides the technology and marketplace through which Users and Service Providers can discover, communicate, enquire, book, rent, hire and connect.

Data Controller: PlugConnect KE

Email

plugconnect.ke@gmail.com

Support

plugconnect.ke@gmail.com

Phone

0787 970 352

Address

plugconnect.ke@gmail.com

This Privacy Policy applies when you:

• Create a PlugConnect KE account.
• Browse the Platform.
• Search for listings.
• Create or manage listings.
• Make enquiries.
• Make bookings.
• Make or receive payments through supported systems.
• Upload photographs or videos.
• Communicate with other users.
• Submit reviews.
• Contact customer support.
• Use the PlugConnect KE AI assistant.
• Interact with advertisements.
• Use our website or mobile application.

Depending on how you use PlugConnect KE, we may collect different categories of information.

A. Account Information

When you register, we may collect:

• Full name
• Email address
• Phone number
• Password or authentication credentials
• Account type
• Profile photograph
• Account preferences

B. Service Provider Information

If you register as a Service Provider, we may collect:

• Individual or business name
• Phone number
• Email address
• Business information
• Business location
• Profile information
• Verification information
• Identification information where required
• Business registration information where applicable
• Provider category
• Payment-related information

C. Property and Listing Information

When a Provider creates a listing, we may collect:

• Property name/title
• Property type
• Location
• Description
• Number of rooms
• Number of bedrooms
• Number of bathrooms
• Size
• Amenities
• Price
• Availability
• Rules and conditions
• Images
• Videos
• Documents where applicable

D. Vehicle Information

For vehicle listings, we may collect:

• Vehicle make
• Model
• Year
• Vehicle type
• Seating capacity
• Transmission
• Fuel type
• Hire price
• Availability
• Vehicle images
• Vehicle videos
• Other information necessary to operate the listing

E. Commercial Space Information

For commercial listings, we may collect:

• Property type
• Location
• Size
• Intended use
• Facilities
• Availability
• Price
• Images
• Videos
• Description
• Other listing information

F. Service Information

For service listings, we may collect:

• Service category
• Service description
• Service area
• Pricing
• Availability
• Provider qualifications where applicable
• Business information
• Images and videos

PlugConnect KE may allow Users and Service Providers to upload photographs and videos.

These may include:

• Property photographs
• Vehicle photographs
• Accommodation photographs
• Commercial-space photographs
• Service-related images
• Profile photographs
• Listing videos

You should not upload photographs or videos containing another person's personal information unless you have the necessary permission or lawful basis.

Uploaded content may be displayed publicly where it forms part of a listing or profile.

PlugConnect KE may collect or use location information to provide location-based functionality.

This may include:

• General location
• Property location
• Business location
• Service coverage area
• Approximate device location where permission is granted

Location information may be used to help users:

• Find nearby listings.
• Search by location.
• Determine service availability.
• Display properties or businesses on maps.
• Improve search results.

Where device location is requested, you may be able to control location permissions through your device settings.

When you use PlugConnect KE, we may automatically collect technical information such as:

• IP address
• Browser type
• Device type
• Operating system
• Application version
• Screen information
• Language settings
• Time zone
• Approximate location
• Log information
• Pages or screens accessed
• Usage information
• Error information

This information helps us maintain security, troubleshoot problems and improve the Platform.

Where booking functionality is available, we may collect:

• Booking details
• Listing selected
• Booking dates
• Number of guests/users where applicable
• Booking status
• Customer information
• Provider information
• Cancellation information
• Transaction references

This information is necessary to facilitate and manage bookings.

When you make a payment through PlugConnect KE, we may process information such as:

• Amount
• Transaction reference
• Payment status
• Date and time
• Payment method
• Related booking
• Provider/customer information

Where third-party payment providers are used, sensitive payment credentials may be processed directly by the relevant payment provider.

PlugConnect KE will not ask you to provide your M-Pesa PIN, card PIN or similar confidential payment credentials through ordinary customer-support communication.

If PlugConnect KE provides messaging or enquiry functionality, we may process:

• Messages
• Enquiries
• Responses
• Attachments
• Dates and times
• Related listing information

This allows us to facilitate communication between Users and Providers.

Where necessary for security, fraud prevention, dispute handling or legal compliance, communications may be reviewed in accordance with applicable law and our policies.

If you submit a review or rating, we may collect:

• Review content
• Rating
• Related listing
• Account information
• Submission date

Reviews may be publicly displayed on the Platform.

Do not include unnecessary personal information about another person in a review.

When you contact PlugConnect KE, we may collect information necessary to resolve your issue, including:

• Name
• Contact details
• Account information
• Booking information
• Complaint details
• Supporting documents
• Communications with support

PlugConnect KE may provide an AI-powered assistant.

You may use the AI assistant to:

• Search listings.
• Find properties.
• Find stays.
• Find vehicles.
• Find commercial spaces.
• Find services.
• Ask questions about the Platform.
• Receive general recommendations.

Information submitted to the AI assistant may be processed by the AI technology provider used by PlugConnect KE.

We will take reasonable measures to ensure that third-party AI processing is appropriately governed.

Users should avoid entering unnecessary sensitive personal information into the AI assistant.

AI responses may not always be accurate and should not be treated as professional legal, financial or other professional advice.

PlugConnect KE may use personal data to:

Provide Platform Services

Including:

• Creating accounts
• Managing profiles
• Publishing listings
• Searching listings
• Processing enquiries
• Facilitating bookings
• Processing transactions
• Providing customer support

Improve the Platform

We may use information to:

• Improve features
• Improve search
• Understand Platform usage
• Fix technical problems
• Develop new functionality

Maintain Security

We may process information to:

• Detect fraud
• Prevent abuse
• Detect unauthorized access
• Protect accounts
• Investigate suspicious activity
• Protect the Platform

Communicate With You

We may send:

• Account notifications
• Booking confirmations
• Payment notifications
• Security alerts
• Service updates
• Customer-support communications
• Important policy updates

Depending on the circumstances, PlugConnect KE may process personal data based on:

• Your consent.
• Performance of a contract or steps taken at your request before entering a contract.
• Compliance with a legal obligation.
• Legitimate interests, where permitted by law.
• Protection of rights and security.
• Other lawful grounds recognized under applicable law.

We will seek consent where consent is required.

Where processing is based on consent, you may withdraw your consent subject to applicable legal and contractual limitations.

Withdrawal of consent does not affect processing that occurred lawfully before withdrawal.

Some information may still need to be retained where we have another lawful basis or legal obligation to retain it.

When you make an enquiry or booking, certain information may be shared with the relevant Service Provider.

This may include:

• Name
• Contact details
• Booking information
• Relevant enquiry information
• Information necessary to fulfil the requested service

We only intend to share information reasonably necessary for the relevant transaction or service.

PlugConnect KE may use third-party payment providers to process transactions.

These providers may process information necessary to:

• Initiate payments.
• Confirm payments.
• Process refunds.
• Prevent fraud.
• Reconcile transactions.

Their processing may also be governed by their own privacy policies and terms.

PlugConnect KE may use third-party technology providers for:

• Hosting
• Cloud storage
• Database infrastructure
• Authentication
• Email
• SMS
• Push notifications
• Analytics
• Maps
• AI services
• Security
• Payment processing

These providers may process personal data on our behalf where necessary to provide their services.

We will take reasonable measures to ensure appropriate contractual and security safeguards are in place.

Where PlugConnect KE uses external AI technology, relevant information may be transmitted to the AI provider to process a user's request.

We will seek to minimize unnecessary personal data sent to AI services.

The AI provider may process information according to the applicable contractual arrangements and privacy requirements.

Some third-party technology providers may operate outside Kenya.

Where personal data is transferred outside Kenya, PlugConnect KE will take reasonable steps to ensure that the transfer is conducted in accordance with applicable Kenyan data-protection requirements.

This may include appropriate contractual, technical or organizational safeguards.

PlugConnect KE may provide advertising services to businesses and Providers.

We may process information necessary to:

• Display advertisements.
• Manage advertising accounts.
• Measure advertising performance.
• Manage promotional campaigns.

Where marketing communications require consent, we will provide an appropriate mechanism for managing or withdrawing that consent.

PlugConnect KE may use cookies and similar technologies to:

• Keep users signed in.
• Remember preferences.
• Improve performance.
• Understand usage.
• Improve security.
• Measure Platform performance.

You may be able to manage cookies through your browser settings.

Some cookies may be necessary for Platform functionality.

PlugConnect KE may use analytics tools to understand:

• How users navigate the Platform.
• Which features are used.
• Which pages are accessed.
• Technical problems.
• General usage patterns.

Analytics information may be aggregated or otherwise processed to improve the Platform.

PlugConnect KE will implement reasonable technical and organizational measures designed to protect personal data against:

• Unauthorized access
• Loss
• Misuse
• Alteration
• Disclosure
• Destruction

Security measures may include:

• Access controls
• Authentication
• Encryption where appropriate
• Secure connections
• Database protections
• Monitoring
• Backups
• Administrative controls

However, no internet-based system can be guaranteed to be completely secure.

If PlugConnect KE becomes aware of a personal-data breach, we will assess the incident and take appropriate steps in accordance with applicable law.

This may include:

• Containing the incident.
• Investigating the cause.
• Restoring affected systems.
• Assessing affected data.
• Taking corrective measures.
• Notifying relevant authorities where legally required.
• Notifying affected individuals where legally required.

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

Retention periods may depend on:

• Account status
• Booking history
• Financial records
• Legal requirements
• Dispute resolution
• Fraud prevention
• Security
• Business requirements

When information is no longer required, it may be securely deleted, anonymized or otherwise disposed of.

Users may request deletion of their PlugConnect KE account.

Account deletion may not immediately remove every record where PlugConnect KE is legally required or permitted to retain certain information.

For example, transaction records may need to be retained for:

• Legal compliance
• Accounting
• Fraud prevention
• Dispute resolution
• Security

Subject to applicable law, you may have the right to:

• Be informed about how your data is used.
• Request access to your personal data.
• Request correction of inaccurate information.
• Request deletion of personal data.
• Object to certain processing.
• Request restriction of processing.
• Request portability of applicable personal data.
• Withdraw consent where processing relies on consent.
• Lodge a complaint concerning the processing of your personal data.

Kenya's Data Protection Act recognizes data-subject rights including being informed, access, objection, correction, deletion and portability.

If you wish to know what personal information PlugConnect KE holds about you, you may submit a data-access request.

We may need to verify your identity before responding to protect your information from unauthorized disclosure.

If information held by PlugConnect KE is inaccurate or incomplete, you may request that it be corrected.

Users should also keep their account information up to date through their account settings where available.

You may request deletion of your personal data where applicable.

Deletion may be subject to legal or legitimate retention requirements.

Where deletion cannot be completed immediately, we may explain the applicable reason.

You may have the right to object to certain forms of processing, subject to applicable law.

Where appropriate, PlugConnect KE will assess the objection and determine whether the processing may continue lawfully.

Where permitted by law, you may request restriction of processing in circumstances such as:

• Contesting the accuracy of data.
• Challenging the lawfulness of processing.
• Where information is required for a legal claim.

Where applicable, you may request personal data in a structured, commonly used and machine-readable format.

This right may be subject to limitations under applicable law.

PlugConnect KE may use automated systems to assist with:

• Search ranking
• Recommendations
• Fraud detection
• Content moderation
• Personalization

Where automated decision-making produces a legally significant effect or otherwise triggers rights under applicable law, PlugConnect KE will provide appropriate safeguards and information.

PlugConnect KE is not intended to be used independently by children where applicable legal age restrictions apply.

We do not knowingly seek to collect personal data from children in circumstances where such collection is prohibited.

If you believe a child has provided personal data improperly, contact us so that we can investigate and take appropriate action.

When you upload information, photographs, videos, reviews or other content, you remain responsible for ensuring that you have the right to provide that information.

Do not upload:

• Another person's confidential information.
• Identification documents unnecessarily.
• Private information belonging to another person.
• Content that violates another person's rights.

Public listing information may be visible to other Platform users.

Information included in a public listing may be visible to:

• Platform visitors
• Registered Users
• Potential customers
• Search engines where indexing is enabled

Providers should avoid publishing unnecessary personal information in public listing descriptions.

PlugConnect KE may contain links to external websites.

We are not responsible for the privacy practices of third-party websites.

You should review the privacy policy of any external service you access.

We may process personal information to identify and prevent:

• Fake accounts
• Fake listings
• Payment fraud
• Identity fraud
• Scams
• Abuse
• Unauthorized access
• Other suspicious activity

Where necessary, information may be shared with relevant authorities or service providers in accordance with applicable law.

PlugConnect KE may disclose information where reasonably necessary to:

• Comply with applicable law.
• Respond to lawful requests.
• Protect users.
• Protect PlugConnect KE.
• Investigate suspected unlawful activity.
• Enforce our Terms and policies.
• Establish or defend legal claims.

If PlugConnect KE is involved in a:

• Merger
• Acquisition
• Restructuring
• Sale of assets
• Business transfer

personal data may be transferred as part of the relevant transaction, subject to applicable law and appropriate safeguards.

PlugConnect KE aims to collect and process information that is reasonably necessary for legitimate Platform purposes.

We do not intend to collect unnecessary personal information simply because it is technically possible to do so.

Users are responsible for providing accurate information.

You should update your:

• Name
• Phone number
• Email
• Provider information
• Listing information

when changes occur.

Providers are particularly responsible for keeping listing information accurate and current.

Privacy and security considerations will be incorporated into the development and operation of PlugConnect KE where reasonably appropriate.

This may include:

• Access controls
• Data minimization
• Secure authentication
• Permission management
• Secure storage
• Appropriate retention controls

Service Providers may receive personal information from Users in connection with enquiries and bookings.

Providers must:

• Use the information only for legitimate purposes.
• Protect customer information.
• Avoid unauthorized disclosure.
• Not sell customer information.
• Not use customer information for unrelated purposes without an appropriate lawful basis.

Providers may have their own legal obligations as data controllers or processors depending on their activities.

Where permitted and where required, PlugConnect KE may send promotional communications about:

• New listings
• Offers
• Platform features
• Promotions
• Provider services
• Other relevant marketplace information

Users may opt out of marketing communications using the available unsubscribe or account-preference mechanisms.

Transactional and security communications may still be sent where necessary.

PlugConnect KE may update this Privacy Policy when necessary due to:

• New Platform features
• Changes in technology
• Changes in our business operations
• Changes in data-processing practices
• Changes in applicable law

The Last Updated date will be changed whenever the policy is materially updated.

Where legally required, we may provide additional notice.

If you have concerns about how PlugConnect KE handles your personal data, you should first contact us using the details below.

We will review and respond to privacy-related complaints in accordance with applicable requirements.

Where applicable, you may also lodge a complaint with Kenya's Office of the Data Protection Commissioner (ODPC) if you believe your personal-data rights have been violated.

The ODPC is Kenya's data-protection regulatory authority.

For privacy questions, data-access requests, correction requests, deletion requests, objections or other data-protection matters, contact:

PlugConnect KE

Privacy/Data Protection Email

plugconnect.ke@gmail.com

General Email

plugconnect.ke@gmail.com

Phone

0787 970 352

Business Address

plugconnect.ke@gmail.com

When submitting a request, please provide enough information for us to identify your account and understand your request.

We may request reasonable proof of identity before processing certain requests.

By using PlugConnect KE, you acknowledge that you have read and understood this Privacy Policy.

Where consent is legally required for a particular processing activity, PlugConnect KE will request that consent separately.