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
This platform complies with the Data Protection Act (2019) of Kenya and is registered with Kenya's Office of the Data Protection Commissioner (ODPC).
1.2 Role Identification
For the purposes of this policy:
- Data Processor: Jama Kazoku Ltd acts as the Data Processor, providing the technical infrastructure to process personal data on behalf of property owners.
- Data Controllers: Landlords and Agencies are the Data Controllers, as they determine why and how tenant data is processed within the scope of their tenancy relationships.
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 for M-Pesa STK Push notifications and email addresses for digital receipts.
- Property Data: Unit numbers, rent amounts, and maintenance logs.
- Employment Information: (For tenants, optional) Employer name, employment status for tenant verification purposes.
3. Purpose of Processing
We process your personal data for the following purposes:
3.1 Financial Transactions
Matching M-Pesa transaction codes to tenant ledgers to provide instant payment confirmation and prevent "screenshot fatigue" — eliminating the need for manual verification of payment screenshots.
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:
- Safaricom (M-Pesa): For payment processing via STK Push and Paybill
- Africa's Talking: For SMS and USSD notification services
- Firebase/Google Cloud: For secure data storage and processing
- Kenya Revenue Authority (KRA): For MRI tax filing as required by law
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 Multi-Factor Authentication (MFA)
Required for administrative roles (Agents and Owners) to prevent unauthorized access to financial dashboards and sensitive data.
5.4 Audit Logs
We maintain tamper-proof audit logs recording who accessed what data, essential for legal accountability and dispute resolution.
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)
We provide a clear process for the permanent deletion of records when a client or tenant leaves the platform, subject to statutory tax record-keeping requirements (tax records must be retained for 7 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.
7. Physical Privacy (The "Notice" Clause)
While not strictly "digital data," we reinforce the tenant's right to privacy within their physical unit. The platform will log and enforce the requirement for landlords to provide at least 24-hour notice before entry, except in emergencies.
This notice requirement is tracked within our system to ensure compliance and provide evidence in case of disputes.
8. 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 retained for 7 years)
- Resolve disputes and enforce our agreements
When data is no longer required, we will securely delete or anonymize it in accordance with our data retention policy.
9. 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.
10. 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.