Jama Kazoku Ltd ("we," "our," or "us") operates the Kazoku Properties platform. This Privacy Policy explains how we collect, use, disclose, and safeguard your information in compliance with the Data Protection Act (2019) of Kenya.
1. Legal Basis and Scope
1.1 Compliance Statement
We process personal data in accordance with the Data Protection Act (2019) of Kenya and the regulations made under it.
1.2 Role Identification
For the purposes of this policy:
- Data Controllers: Landlords and Agencies are the Data Controllers for tenancy data, as they determine why and how tenant data is processed within the scope of their tenancy relationships.
- Data Processor: Jama Kazoku Ltd acts as the Data Processor for that tenancy data, providing the technical infrastructure to process it on behalf of property owners.
- Our own data: Jama Kazoku Ltd is the Data Controller for the account data we collect for ourselves: sign-up and login details, platform fee records, and marketing preferences.
2. Minimal Data Collection (Privacy by Design)
2.1 The Principle
We collect only the minimal information necessary to facilitate tenancy agreements, send invoices, and receive payments. This principle of data minimization is central to our platform design.
2.2 Data Points Collected
- Identification: Full names, National ID/Passport numbers, and KRA PINs (required for legal due diligence and MRI tax filing).
- Contact Details: Phone numbers and email addresses for notices, reminders and digital receipts, and an emergency contact you choose to give us.
- Verification Documents: Copies of ID, KRA PIN certificates, title deeds or proof of income that you upload for verification.
- Tenancy Records: Leases and the signatures on them, unit numbers, rent amounts, invoices, payment history, meter readings, maintenance tickets, and move-out inspections, including photos.
- Payout Details: (For landlords) The bank or mobile money account your rent is settled to.
- Consent Records: When you accepted our terms and this policy, and your marketing preferences.
We do not store card numbers or M-Pesa PINs. Those are handled by our payment processor, Paystack.
3. Purpose of Processing
We process your personal data for the following purposes:
3.1 Financial Transactions
Processing rent and other payments through Paystack (M-Pesa and card), matching each confirmed payment to the right invoice automatically, settling rent to the landlord, and deducting our platform fee.
3.2 Statutory Compliance
Generating KRA-ready reports for the 7.5% Monthly Rental Income (MRI) tax for landlords earning between KSh 288,000 and KSh 15 million annually in residential rental income.
3.3 Operational Efficiency
- Managing maintenance tickets and repair requests
- Providing a digital audit trail for disputes in the Small Claims Court
- Sending automated rent reminders and payment confirmations
- Generating legally compliant rent receipts as required by the Landlord and Tenant Act
4. Confidentiality and Sharing
4.1 Non-Disclosure
Landlords and agents have a legal responsibility to keep tenant information confidential and must not use it for purposes other than the tenancy without explicit consent.
4.2 Third-Party Integration
Data is shared with the following service providers only to the extent required to complete the service:
- Paystack: For payment processing (M-Pesa and card). Paystack is authorised by the Central Bank of Kenya as a payment service provider.
- Google Cloud / Firebase: For secure data storage, sign-in, and processing
- Email delivery provider: For sending notices, invitations, and receipts
- Typesense: For searching public property listings (listing details only, no tenant data)
- Kenya Revenue Authority (KRA): For KRA PIN verification and tax filing, only where the law requires it
4.3 International Transfers
Our service providers store and process data outside Kenya. Our database is hosted in South Africa, our application servers run in the United States, and our listing search index is hosted in Belgium. We transfer data only under the safeguards required by Part VI of the Data Protection Act, including our providers' contractual data protection commitments.
5. Data Security Measures
We implement the following technical safeguards to protect your sensitive financial data:
5.1 Encryption
- Data at Rest: AES-256 encryption for all stored personal and financial data
- Data in Transit: TLS/SSL encryption for all data transmission
5.2 Access Control
Role-Based Access Control (RBAC) ensures appropriate data access levels:
- Caretakers can view maintenance issues but cannot access owner payouts or sensitive tenant ID documents
- Tenants can only view their own lease and payment information
- Landlords can view data only for their own properties and tenants
5.3 Audit Logs
We keep a record of key actions such as payments, lease changes, and move-out decisions, for accountability and dispute resolution.
5.4 Breach Notification
If a personal data breach puts your rights at risk, we will notify the Office of the Data Protection Commissioner within 72 hours of becoming aware of it, and notify affected users without undue delay.
6. User Rights
Under the Data Protection Act (2019), you have the following rights:
6.1 Access and Correction
You may view and update your personal profiles and payment history at any time through your account dashboard.
6.2 Data Portability
You can download your rent statements and receipts in PDF format for your records or to share with third parties.
6.3 Right to Erasure (Off-boarding)
You may ask us to permanently delete your records when you leave the platform. We will do so except for records the law requires us to keep, such as tax records, which must be kept for at least five years.
6.4 Right to Object
You may object to processing based on legitimate interests or withdraw consent for marketing communications at any time.
To exercise any of these rights, please contact our Data Protection Officer at info@kazokuproperties.com. We respond within the timelines set by the Data Protection (General) Regulations, 2021.
7. Data Retention
We retain your personal data for as long as necessary to:
- Fulfill the purposes for which it was collected
- Comply with legal obligations (tax records must be kept for at least five years)
- Resolve disputes and enforce our agreements
When data is no longer required, we will securely delete or anonymize it.
8. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date. For material changes, we will provide additional notice through email or in-app notification.
9. Contact Us
If you have any questions about this Privacy Policy or our data practices, please contact:
- Data Protection Officer: Jama Kazoku Ltd
- Email:info@kazokuproperties.com
- Address: Nairobi, Kenya
You also have the right to lodge a complaint with the Office of the Data Protection Commissioner of Kenya if you believe your data protection rights have been violated.