Privacy Policy

This Privacy Policy explains how FOBO Technologies Ltd ("FOBO", "we", "us") collects, uses, shares, and protects personal data when you visit fobotechnologies.co.ke (the "Site"). It is written to comply with the Data Protection Act, 2019 (Kenya) ("DPA") and its subsidiary regulations, as enforced by the Office of the Data Protection Commissioner ("ODPC").

This policy covers the marketing Site only. Data processed within FOBO Control - including transaction data, member records, and account information - is governed by the separate FOBO Control Privacy Policy .

1. What We Collect

• Contact and enquiry data: name, organization, email address, phone number, and message content submitted through contact forms or demo requests.

We do not knowingly collect financial account data, transaction data, or national ID numbers through this Site.

2. Legal Basis for Processing

Under the DPA, we process personal data on the following bases:

• Legitimate interest: for responding to enquiries, operating the Site securely, and understanding aggregate Site usage;
• Contractual necessity: where processing is required to take steps you request, such as scheduling a demo.

3. How We Use Your Data

We use personal data collected through the Site to:

• Respond to enquiries and demo requests;
• Improve Site content, performance, and security;
• Send product updates or marketing communications, where you have opted in;
• Comply with legal obligations, including responding to lawful requests from Kenyan authorities.

4. Sharing of Data

We do not sell personal data. We may share data with:

• Professional advisers (legal, audit) where necessary;
• Regulators or law enforcement, where required by Kenyan law;
• Service providers who host the Site, provide analytics, or support our CRM and email tools, under contractual confidentiality obligations.

5. International Transfers

Where any of our service providers store or process data outside Kenya, we ensure such transfer complies with Section 48 of the DPA; including verifying that the destination country has adequate data protection safeguards, or relying on contractual clauses that impose DPA-equivalent protections on the recipient.

6. Cookies

The Site DOES NOT use cookies.

7. Data Retention

We retain enquiry and contact data for as long as necessary to respond to your enquiry and for a reasonable period afterward for record-keeping, unless you request earlier deletion.

8. Your Rights Under the DPA

As a data subject, you have the right to:

• Data portability, where technically feasible;
• Be informed of the use of your personal data;
• Access your personal data in our possession;
• Request correction of inaccurate or outdated data;
• Request deletion of your data, subject to legal retention requirements;
• Object to processing based on legitimate interest or direct marketing;
• Lodge a complaint with the ODPC odpc.go.ke if you believe your rights have been violated.

To exercise these rights, contact us using the details in Section 10. We will respond within the timeframes prescribed by the DPA.

9. Security

We apply reasonable technical and organizational measures - including encryption in transit, access controls, and regular review of third-party processors - to protect personal data against unauthorized access, alteration, disclosure, or destruction. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

10. Contact and Data Protection Officer

For privacy questions, rights requests, or complaints, contact our Data Protection Officer at dpo@fobotechnologies.co.ke. If unsatisfied with our response, you may lodge a complaint with the Office of the Data Protection Commissioner, Kenya, complaints@odpc.go.ke.

11. Changes to This Policy

We may update this Privacy Policy periodically. Material changes will be reflected in the "Last updated" date above and, where required by law, notified to you directly.