What Gloodoh does with your information

Who we are and how to reach us

Gloodoh is operated by iTsitso Space LTD, a company incorporated in the Republic of Kenya. We decide what personal data Gloodoh collects and what it is used for, which makes us a data controller under the Data Protection Act, No. 24 of 2019 (Cap. 411C). In this policy, "we", "us" and "Gloodoh" mean iTsitso Space LTD; "the Act" means that Act; and "the Regulations" means the Data Protection (General) Regulations 2021 (Legal Notice 263 of 2021).

One policy covers all of Gloodoh:

• Gloodoh Supplier — the app shopkeepers and their staff use to sell (space.itsitso.gloodoh)
• Gloodoh Consumer — the app buyers use to shop (space.itsitso.gloodohconsumer)
• Gloodoh Uploader — the app used to load a catalogue in bulk (space.itsitso.gloodohuploader)
• The supplier console at supplier.gloodoh.com, and the staff console at manage.gloodoh.com, which only Gloodoh staff can sign in to
• This website, gloodoh.com

Every Gloodoh app links to this page from More information → Privacy Policy. This is the only privacy policy for Gloodoh. Any older copy at another web address is out of date and does not apply.

Where to write

Email is how you reach us, and it is watched.

• privacy@gloodoh.com — our privacy point of contact. Anything about your personal data: a copy of it, a correction, deletion, an objection, a complaint, or a breach you think has happened.
• support@gloodoh.com — an order, a payment, or something that is not working.
• legal@gloodoh.com — legal notices.
• info@gloodoh.com — everything else.

Write in English or Kiswahili, whichever is easier. Tell us enough to find you — the email address or phone number on the account is usually enough.

If email does not suit you

Ask legal@gloodoh.com and we will give you our company registration particulars and a postal address for service, so you can write to us on paper about your personal data or serve a notice under this policy. The Companies Act, No. 17 of 2015, s.67 requires us to give those particulars to anyone who asks, and we will.

What this policy covers, and what it does not

This policy explains what Gloodoh does with your information. It does not explain what a shop you buy from does with it afterwards, because that is not ours to decide.

It covers

• The three Gloodoh apps, the supplier console and this website.
• The notifications, emails and text messages Gloodoh sends you.
• The records Gloodoh keeps of orders, payments and payouts.

It does not cover

• What a supplier does with your details in its own books — its own notebook, its own phone, its own till, its own WhatsApp.
• What the payment providers do. SasaPay (operated by Viewtech Limited) and Safaricom are licensed in their own right and run under their own privacy policies.
• Other apps and websites we link to.
• Your phone maker, app store or mobile network.

Two controllers, not one

The Act defines a data controller as whoever decides the purpose and means of processing — "alone or jointly with others" (s.2). On a marketplace that means two parties hold your information, and each answers for its own use of it: Gloodoh, and the business at the other end of the order.

If you sell on Gloodoh, the law calls you a controller too

This section is only for businesses. In one sentence: the customer data you collect through Gloodoh is yours to protect, and Gloodoh's registration and Gloodoh's policy do not cover you.

You may need to register with the ODPC

You are exempt from mandatory registration only if both apply: annual turnover or annual revenue below KES 5 million and fewer than ten employees (Data Protection (Registration of Data Controllers and Data Processors) Regulations 2021, Legal Notice 265 of 2021, reg 13(2)). Miss either limb and you must register.

The Third Schedule to those Regulations then removes the exemption altogether, whatever your size, from twelve kinds of processing: canvassing political support among the electorate; crime prevention and the prosecution of offenders, including operating security CCTV; gambling; operating an educational institution; health administration and the provision of patient care; hospitality firms, excluding tour guides; property management, including the selling of land; the provision of financial services; telecommunications network or service providers; businesses wholly or mainly in direct marketing; transport services firms, including online passenger-hailing applications; and businesses that process genetic data (reg 13(4) and the Third Schedule).

Several of those catch ordinary Gloodoh suppliers — a guest house, a chemist, a school shop, an agent selling land — so read the list against what you actually do rather than against how big you are. And being exempt from registering never exempts you from the substantive duties: Part IV of the Act (principles, rights, retention, security, breach) and Part VI (transfers out of Kenya) apply to you either way (reg 13(3)).

What you must do with a customer's details

• Use them for the order, and for your own books. Not for anything the customer would not expect.
• Do not send marketing without express consent. Using personal data for commercial purposes without consent is an offence, punishable by a fine of up to KES 20,000 or six months' imprisonment (Regulations, reg 15(4)).
• Do not sell or pass on a customer list. Offering personal data for sale is an offence under s.72 of the Act.
• Give your staff only the access their job needs. Gloodoh lets you set a role per member — use it.
• Keep customer details only as long as you need them, and answer a customer's request about their data within the deadlines in Your rights.
• If customer data leaks on your side, you must notify the Data Commissioner within 72 hours of becoming aware where there is a real risk of harm (s.43). Tell us too.

Where Gloodoh is working for you

For most of what happens on the platform we are a controller in our own right. Where we only hold and move your customers' data on your instruction — storing it, sending an order SMS on your behalf — we act as your data processor, and if we discover a breach affecting it we will tell you without delay and, where reasonably practicable, within 48 hours (s.43(3)).

The information we collect

Everything Gloodoh holds about a person falls into one of the groups below. If a kind of information is not in this table, we do not ask for it and Gloodoh has no field for it.

What you have to give us, and what happens if you do not

No law compels you to hand any of this over, and nothing on this page is collected under a statutory power. Giving it to us is voluntary — but some of it is the price of the thing you asked for, so here is exactly what withholding it costs.

• A name, an email address or phone number, and a sign-in method — without these there is no account, so you cannot buy, sell or be paid through Gloodoh.
• Order and payment details — without these an order cannot be placed, filled or proved, and a payment cannot be matched to it.
• A business's name, published contacts and payout number — without these a shopfront cannot be published and the business cannot be settled.
• A device identifier and push token — Gloodoh still works without them, but you will get no notifications and we cannot show you which devices are signed in to your account.
• Everything else here — budgets, alerts, follows, the assistant, your location for Deals Near Me, a shop's map pin — is optional. Withholding it costs you that one feature and nothing more: no account is closed, no price changes, nothing else is withdrawn.

Sensitive personal data

The Act treats some things as sensitive: health, race, ethnic or social origin, conscience and belief, genetic and biometric data, sex or sexual orientation, and — unusually — property details, marital status, and family details including the names of a person's children, parents or spouse (s.2). We do not ask you for any of it, and Gloodoh has no field for it.

The one way it can reach us is if you type it into free text — a chat message, an order note, a support email. Please do not. Anything you type is stored with the rest of the record, and we have no way to spot it and take it out.

Permissions the apps ask for

• Camera — to scan a Gloodoh card, a QR code or a barcode, and to take product photos. Asked for the first time you use a scanner or the camera, not at startup. The supplier console asks your browser for the same thing.
• Notifications — order, payment and booking alerts. On Android the Supplier and Consumer apps ask for this when you first open the app, and ask again on a later launch if you said no; booking reminders ask separately when you switch one on. Saying no leaves the rest of the app working. Gloodoh Uploader never asks.
• Exact alarms and restart-after-reboot — so a booking reminder fires at the right minute and survives your phone restarting. If you do not grant exact alarms, reminders still fire, just less precisely.
• Location — Consumer app: to show Deals Near Me. The permission itself is your phone's own dialog. The app may suggest turning it on when you open Browse or tap the search field — at most once in any 24 hours, and Not now is always an answer. Otherwise a line on the home screen says location is off, and does something only when you tap it. It is used only while the app is open, and Deals Near Me needs precise location, because an approximate one can be kilometres out. Supplier app: only if you tap Use my location while placing your shop's pin, and then only to move the map to where you are standing — nothing is saved until you save the pin. Saying no leaves the rest of either app working. Your phone's own location service works out the position; on Android that service may be provided by Google, and on iPhone by Apple, under their own terms.
• Photos and files — to attach an image or a document to an order, and on older Android versions to save an image back to your gallery.
• Gloodoh Uploader asks for less — no notification permission and no alarm permission at all; only internet, camera, and reading and saving images on older Android versions. It can also receive images shared to it from another app on your phone, which is how a catalogue gets loaded in bulk.

Where the information comes from

The Act says personal data should be collected directly from the person it is about (s.28(1)). Almost all of ours is.

• From you — what you type when you sign up, build a shopfront, place an order, set a budget, send a message or write to support.
• From Google or Apple, if you sign in that way — the email address on that account and an identifier that lets us match it to your Gloodoh profile.
• From your device, when the app registers for notifications — the device identifier, the device name, the platform and a push token. And, only if you have allowed it, your position at the moment Deals Near Me looks for deals — used for that search and not kept.
• From the payment provider, after a payment — the phone number that paid, the receipt and transaction references, and the result of the attempt.
• From a supplier who records a counter sale — see below.

When a shop records a sale for you

A supplier can record a walk-in sale for a customer who is not signed in. If the shop types a name and a phone number, both are kept on that order, and we turn the last nine digits of the number into a scrambled identifier so that repeat visits by the same customer add up in the shop's own records.

That is indirect collection under s.28(2) of the Act. It is permitted because collecting it that way does not prejudice you and the sale cannot be recorded without it. Where we collect your details from someone other than you and we have a way to reach you, the Regulations give us 14 days to tell you (reg 6(3)), and we will.

We do not buy personal data. We do not take it from data brokers, we do not scrape it, and we do not build profiles from anything outside Gloodoh.

Why we are allowed to use it

Section 30(1) of the Act says we may not process personal data at all unless one of a fixed list of reasons applies — and s.30(3) makes processing without one an offence. Where we are not relying on your consent, the Regulations let us rely on only one reason for a given purpose, and we must have picked it before we started (reg 5). Here is the one we picked, for each thing we do.

On money, plainly: the sale is between you and the business, and so is the payment obligation. Gloodoh is not a bank, not a financial institution, and is not licensed or authorised as a payment service provider. Payments are collected by SasaPay — operated by Viewtech Limited, authorised by the Central Bank of Kenya since 15 September 2021 — into Gloodoh's merchant account with SasaPay, and SasaPay then settles the supplier's share out of that account to the payout number the business gave us. Our part is to initiate the instruction, keep our service fee, and reconcile the records. We say it that way because it is what happens: a policy that told you the money never touches our side would be easier to write and would not be true.

If we ever want to use it for something else

A new use has to be compatible with the reason the data was collected for. Where it is not, the Regulations require us to come back and ask for fresh consent (reg 6(4) and (5)). We will, and we will say plainly what we are asking for.

We do not make automated decisions about you

Section 35 of the Act gives you the right not to be subject to a decision made solely by a computer that has legal effects or otherwise significantly affects you. Gloodoh makes no such decisions. The smart budget limit is arithmetic on your own orders that you asked for and can switch off; the shopping assistant suggests products and nothing more. Nothing in Gloodoh scores you, ranks you, or decides automatically whether you may buy, sell or be paid.

Messages we send, and how to stop each one

Section 37 of the Act says personal data may not be used for commercial purposes without express consent, and the Regulations make marketing without it an offence (reg 15(4)). So: we do not sell your data, and we do not send you promotions you did not ask for.

Turning something off costs nothing and is meant to be easy

The Regulations require an opt-out that is visible, quick, free, and reachable by people with a disability (reg 16). If any of the routes above is hard to find or does not work, email privacy@gloodoh.com and we will do it for you. You can also ask us to stop all marketing in one go, and we act within 7 days — in any event within the 14 days reg 8(2) allows.

We never profile a child for direct marketing. That is flatly prohibited (reg 13(2)(b)), and it is also not something we would do.

The shopping assistant

The assistant answers a buyer's questions about what to buy, and drafts a campaign for a supplier from that supplier's own slow-moving stock. To do either it sends what you typed to an AI provider outside Kenya. This section says exactly what leaves and what does not.

What is sent

• The words you type.
• The last four turns of the conversation, so the answer follows on.
• Your budget figure and its currency, the category and how urgent you said it was.
• A short summary of the products and campaigns we already picked out as candidates — on the supplier side, the stock lines the campaign would be about.

What is not sent

No name. No email address. No phone number. No user id. We know which account made the request — we count it against a limit of 30 questions a day — but that identity is never put into the message we send onward. There is one exception: on the supplier side, the request carries your business's identifier alongside the stock lines the campaign is about.

Who receives it

Groq handles it first. If Groq fails, the same request goes to DeepInfra instead. Both process it outside Kenya.

What we keep

Gloodoh stores no transcript. There is no table of assistant conversations. All we keep is a counter of how many questions you asked today, so the daily limit works.

Before the assistant sends anything for the first time, we show you the substance of this section and ask you to agree — one explicit yes, recorded with the date and what it covered, because s.32(1) of the Act puts the burden of proving your consent on us and not on you. That consent covers one thing only: sending the words you type, with the context listed above, to Groq or DeepInfra outside Kenya, with the risks set out in Sending information outside Kenya. You can withdraw it at any time in the app (s.32(2)) and the assistant simply stops. Not using it, or withdrawing later, costs you nothing else in Gloodoh — no feature is withheld, no price changes, and nothing about your account is treated differently.

If you connect Gloodoh Budget

Gloodoh Budget is a separate budgeting app made by iTsitso Space LTD. If you choose to connect it, Gloodoh sends it a record of each payment, refund and manual purchase you make, so your budget there stays up to date. Nothing is sent unless you connect it, and you can disconnect at any time.

How you connect

You start in Gloodoh Budget, which asks for its own passphrase and shows you a six-character pairing code. Gloodoh then asks you to confirm and to type that code. Gloodoh tells you each time a connection is created, and lists it in Settings → Connected apps.

What is sent

For each payment, refund or manual purchase from the moment you connect: the amount, its currency, the date, the shop's name (for a manual purchase, the name you typed), the order reference, a shopping category and whether it went through or was cancelled. If you ask for it when connecting, the same for the previous 90 days.

What is not sent

No phone number, email address, M-PESA or SasaPay receipt number, item list or note, and nothing about anyone else.

Who can read it

Each record is encrypted on our servers so that only your own Gloodoh Budget app, once you unlock it, can read it. Gloodoh Budget's servers store it only in that encrypted form, and Gloodoh keeps no way to read it back.

What we learn from Gloodoh Budget

One thing: the currency your Gloodoh Budget budget is in, so that we can show it to you. We use it only for that. It never changes a price, a payment or what we send.

Stopping

Disconnect in Gloodoh Settings → Connected apps, or in Gloodoh Budget. We stop sending immediately and delete the connection key we held. What Gloodoh Budget already received stays in your budget there, under Gloodoh Budget's own privacy policy.

Advertising in the apps

We would rather tell you this plainly than have you find it in a store listing.

Google's Mobile Ads SDK is built into all three Android apps — Supplier, Consumer and Uploader — and starts with the app. It contacts Google, and it is capable of collecting a device advertising identifier and technical information about the device, under Google's own terms. It is an advertising SDK and we disclose it as one. On iPhone it is narrower: the Supplier app ships the same SDK, together with Google's consent SDK (the User Messaging Platform), inside the binary but never starts them, and the Consumer app does not include the advertising SDK at all — so no ad is requested on either.

What is actually happening today

Every ad slot in Gloodoh currently uses Google's public test identifiers. That means any ad you see is a Google test placeholder marked as such. Gloodoh earns nothing from it, no advertiser has bought anything, and no advertising profile of you is built for us or handed to us.

We ask you once, plainly, before the SDK sends anything that identifies your device, and you can change that answer at any time in the app's settings. Saying no costs you nothing: every part of Gloodoh keeps working exactly as it did.

What we do not do

• We do not sell your personal data to advertisers.
• We do not give any advertiser your name, phone number, email address, orders or messages.
• We do not track you across other companies' apps and websites. On iPhone we do not ask for App Tracking Transparency permission, because we are not doing the thing that permission is for.

Our own promotions

Gloodoh shows its own promo cards inside the consumer app. We count how many times a card was shown and how many times it was tapped — totals on the card itself, not a record of who saw what. There is no per-person impression log.

Who else sees your information

The table below is the full list of companies and businesses we routinely give your information to. Four things sit outside it, and they are set out straight after the table: a currency-rate service that receives no personal data at all, our own staff, disclosures the law compels us to make, and what would happen if Gloodoh were sold. Nobody else receives your personal data from us.

We also fetch currency rates from Open Exchange Rates. That request carries no personal data at all — it asks for exchange rates and nothing else.

When you tap See on map or Directions, Gloodoh hands the shop's pin and name to the maps app on your phone — usually Google Maps on Android and Apple Maps on iPhone. Your own position is not part of what Gloodoh hands over. What that app then does, including working out a route from where you are, is governed by its maker's terms, not ours.

Gloodoh's own staff

A small number of Gloodoh staff can reach the staff console to investigate a payment, a dispute or an abuse report. Email addresses and phone numbers are masked in every list they see; revealing one, or opening a conversation, is a separate act that is written to an append-only audit log with who did it, when and why. Staff sessions last at most 12 hours and end after 30 minutes of inactivity.

When the law requires it

We will disclose personal data where we are legally obliged to — a court order, a lawful request from the Data Commissioner or another regulator, or a lawful police investigation. We give only what is required, and we record what we gave.

If Gloodoh is ever sold, merged or reorganised, records may pass to the new owner. We would tell you, and the new owner would be bound by this policy until it lawfully published a different one.

Sending information outside Kenya

Some of Gloodoh runs on services based outside Kenya, so some of your information leaves the country. Section 25(h) of the Act allows that only where there are adequate safeguards or your consent, and ss.48 and 49 set the conditions.

What leaves, and to whom

Supabase (the database, sign-in, file storage and realtime), Google (notification delivery, the ads SDK, sign-in, and the connectivity check on iPhone and desktop), Apple (sign-in, and the iPhone connectivity check), Resend (email), Groq and DeepInfra (the shopping assistant), Gloodoh Budget (the encrypted payment records of consumers who connect it, processed on Cloudflare), the OpenStreetMap Foundation (the map pictures in the supplier's pin map) and Vercel (this website and the supplier console) all process outside Kenya.

SasaPay, Safaricom and Africa's Talking operate in Kenya, so payments and SMS are handled here.

The safeguard we rely on

The Data Commissioner has not published a list of countries with an adequacy decision, so we do not claim one. We rely on appropriate safeguards — the basis in reg 41 of the Regulations, and the one s.48(a) and (b) of the Act require us to be able to prove to the Data Commissioner. Before we send a provider anything, we accept the data-protection terms that form part of its service agreement with us — terms that bind it to protection essentially equivalent to the Act, to act only on our instructions, and not to pass the data on without our authorisation (reg 47). We keep those terms and a record of each transfer in a documented transfer file, we will produce it to the Data Commissioner on request as reg 41(2) requires, and we will put it before the Commissioner proactively where s.48 calls for it.

For the parts you directly asked for — your account, your orders, the notification that tells you a payment landed — the transfer is in addition necessary to perform our contract with you (s.48(c)(i)). The service cannot exist without it.

Sensitive personal data

Transferring sensitive personal data out of Kenya needs both your consent and confirmed safeguards (s.49). We do not ask for sensitive personal data and Gloodoh has no field for it — but anything you type into a message or a note travels with the rest of the record. Please keep it out of free text.

How long we keep it

The Act says we may keep personal data only as long as is reasonably necessary for the purpose, and that we must delete, anonymise or pseudonymise the rest (s.39). Below is what actually happens — and, in the last column, whether the system does it on its own or a person does it.

Two honest notes about deletion

Deleting a chat message clears the words, but not every trace of it. When you delete a message we blank the text itself straight away. Three things stay behind until the account goes: an empty stub in the conversation showing who sent it and when, with the name and photo attached to it at the time; any file you had attached to it; and — if it was the newest message in that conversation — up to its first 120 characters, which sit in the conversation's preview line until somebody sends a newer message. Treat a sent message as sent.

Files you upload stay reachable by their web address. See Keeping it safe — it matters more than it sounds.

Deleting your account and your data

You can ask us to delete your Gloodoh account and the personal data attached to it, at any time, for any reason, from anywhere. It costs nothing.

What we will do

• Check it is really you. We may ask you to confirm from the email address or phone number already on the account — acting on a fake deletion request would itself be a breach.
• Acknowledge it within 7 days so you know it arrived.
• Answer within 14 days, which is the period reg 12 of the Regulations allows for an erasure request, and tell you what was removed and what had to stay.
• Finish the deletion within 30 days of your request at the latest. These are the same deadlines as on our deletion page.
• Delete the account record and the personal data attached to it. We do not "freeze" or deactivate an account and call it deleted.

What goes

Your profile — name, username, photo, phone numbers, Gloodoh card; your linked Google or Apple sign-in; your budgets and category limits; the businesses you follow and your alert settings; your registered devices and their push tokens; and the manual purchases you recorded for yourself.

What stays, and why

• Orders, payments and payout records, including the snapshot taken at the moment of the order — the name, the Gloodoh card id, the account identifier and the address of the profile photo of the buyer, the business and the staff member who served. They are financial records of a deal with another party, needed for accounting and tax and for defending or bringing a claim. The photo file itself is deleted with your account, so the stored address stops working.
• Messages already delivered into someone else's conversation. They are part of that person's record too.
• Anything we are required to keep by law or need as evidence in a live dispute. Where that applies, the Act requires us to restrict the data rather than erase it — it is locked away and not used for anything else (s.40(3)).

Withdrawing consent, without deleting anything

Where we rely on your consent — marketing, the advertising SDK, the smart budget limit, the shopping assistant, location for Deals Near Me, a shop's map pin — you can withdraw it at any time (s.32(2)) and we stop that use. For location, switch it off for Gloodoh in your phone's settings; for a pin, tap Remove pin in the business editor. Withdrawing consent does not undo what was lawfully done before you withdrew it (s.32(3)), and where you withdraw consent for only part of something, we restrict that part (reg 4(5)). You do not have to delete your account to withdraw a consent, and we will not make you.

Keeping it safe

Section 41 of the Act requires us to build protection into the system rather than bolt it on. What that means here, concretely:

• Everything travels encrypted. Every connection between the apps, the website and our servers uses HTTPS.
• We never see your password. Sign-in is handled by Supabase Auth using the PKCE flow; we hold no readable copy of any password.
• The database enforces who may read what. Row-level rules mean one business cannot read another's orders, and one person cannot read another's conversations, even if a request asks for them.
• Staff see masked details. Email addresses and phone numbers are masked in the staff console's lists; unmasking one, or opening a conversation, is logged to an append-only audit trail.
• Short sessions where the risk is highest. Staff sessions last 12 hours and end after 30 minutes idle; staff sign-in codes expire in 10 minutes and are stored only as a hash.
• We do not store your IP address against your account, so there is nothing there to leak.
• You can see and end your own sessions on the web. Sessions & devices in the supplier console at supplier.gloodoh.com lists every device signed in to your account and signs the others out. The phone apps do not have that screen yet — signing out ends that device, and we will end any other one for you if you ask at privacy@gloodoh.com.

If something goes wrong

If personal data is accessed or taken by someone who should not have it, and there is a real risk of harm to you, we must and will:

• Notify the Data Commissioner within 72 hours of becoming aware of it — and if we are late, say why (Act s.43(1) and (2)).
• Tell you in writing, with what happened, what we are doing about it and what you should do to protect yourself (s.43(5)).
• Where we hold the data on another controller's behalf, tell them within 48 hours (s.43(3)).

A breach touching payment details, amounts paid, or money owed is treated as notifiable automatically under reg 37 and the Second Schedule of the Regulations. Almost every record in an order is in that list — so we would not be weighing whether to tell anyone.

No system is perfectly safe, and we will not claim ours is. Keep your password to yourself, do not share a sign-in code with anyone, and tell us about any device signed in to your account that you do not recognise.

Your rights, and what we must do about them

These rights are real, they are free, and the deadlines below are the ones Kenyan law actually sets — not the 30 days most policies copy from elsewhere. Understating your rights would itself be a misrepresentation offence under the Competition Act (Cap. 504) s.55(b)(v), so here they are in full.

How to use one

Email privacy@gloodoh.com. Say which right you are using and give us enough to find the record — the email address or phone number on the account is usually enough. The Regulations publish forms for these requests (DPG 1 to DPG 5) and you are welcome to use them, but you do not have to: a plain email works and we will act on it.

We may ask you to confirm your identity first, and the clock starts once we can be sure it is you. This is not a delaying tactic — handing your data to someone pretending to be you would be a breach in itself.

Someone acting for you

A right can be exercised on your behalf by a parent or guardian if you are under 18, by a guardian or administrator if you have a disability that requires one, or by anyone you have authorised (s.27). We will ask for proof of the relationship or the authority before we act, and we act in the data subject's best interests.

If we say no

We will tell you in writing, within the deadline, why — and we will tell you that you may complain to the Data Commissioner. We will not simply go quiet.

Children

Gloodoh is not for children. In Kenya a child is anyone under 18 (Constitution of Kenya 2010, Article 260). You must be 18 or over to hold a Gloodoh account — see the Terms of Service.

Our criterion, as reg 23(2)(g) of the Regulations asks us to state, is simple: we do not set out to collect a child's personal data at all. No part of Gloodoh is aimed at children, none of the content is designed for them, and we do not advertise to them.

Section 33 of the Act allows a child's data to be processed only with a parent's or guardian's consent and in a way that protects and advances the child's best interests. We have no product that could meet both limbs, so we do not try.

If a child's data reaches us anyway

If you are a parent or guardian and you believe a child has given us personal data, write to privacy@gloodoh.com. We will delete it, and suspend any account opened by a child — unless you tell us you want it kept and you consent to that as the child's parent or guardian.

We do not profile a child for direct marketing under any circumstances. It is prohibited outright by reg 13(2)(b), and we do not do it.

Complaints

If you think we have mishandled your personal data, you can complain to us, to the regulator, or both. You do not have to come to us first.

To us

Write to privacy@gloodoh.com and say what happened and what you want done. We acknowledge a complaint within 7 days and give you an answer within 30 days — or, if it will take longer, tell you why and when to expect it. We keep a log of complaints and what we did about each one.

That 30 days never delays a request about your own data. If your message also asks for a copy of your data, a correction, deletion, restriction, or objects to something we are doing, the deadlines in Your rights govern that part — 7 days for access, 14 days for the rest, 7 days for anything about marketing — and they run whether or not you called it a complaint, and whether or not the complaint itself is still open.

To the Office of the Data Protection Commissioner

Anyone aggrieved by a decision under the Act may complain to the Data Commissioner (s.56(1)). A complaint may be made orally or in writing, by you, by someone acting for you, or anonymously, and it is free (Data Protection (Complaints Handling Procedure and Enforcement) Regulations 2021, Legal Notice 264 of 2021, reg 4). The ODPC acknowledges receipt within 7 days (reg 4) and must investigate and conclude a complaint within 90 days (s.56(5)).

• Complaints portal: cie.odpc.go.ke
• Website: www.odpc.go.ke
• Email: info@odpc.go.ke
• Telephone: 020 780 1800
• Office of the Data Protection Commissioner, Britam Tower, Hospital Road, Upper Hill, Nairobi
• P.O. Box 30920-00100 G.P.O. Nairobi

To the courts

Section 65 of the Act entitles a person who suffers damage through a contravention to compensation — and "damage" expressly includes distress, not only financial loss. Nothing in this policy or in our Terms takes that away.

Changes to this policy

Regulation 23(1) of the Regulations requires us to develop, publish and regularly update a policy that reflects what we actually do with personal data. That is this page, and keeping it true is part of the work, not an afterthought.

• When what we do changes, we change this page and update the Last updated date at the top.
• Where a change materially affects you, we tell you in the app or by email before it takes effect.
• Where we want to use your information for a new purpose that is not compatible with the one it was collected for, we ask for fresh consent rather than assume it (reg 6(4) and (5)).
• We will never quietly widen what we collect and call it a clarification.

If you want the version of this policy that applied on a particular date — because of a dispute, or simply to check — ask privacy@gloodoh.com and we will send it to you.

Related pages: Terms of Service · Delete your account and data · Cookies and local storage · Cancellations and refunds · Acceptable use