Privacy Policy

Slotly Ltd. (“Slotly,” “we,” “us,” or “our”) respects your privacy and is committed to protecting your personal data. This Privacy Policy describes how we collect, use, disclose, transfer, store, and protect your personal information when you use our mobile application, website, and related services (collectively, the “Platform”).

This Policy is issued in line with the Kenya Data Protection Act, 2019, the Kenya Information and Communications Act (KICA), and international best practices, and it is legally binding on Slotly Ltd., its employees, contractors, and service providers.

1. Scope of this Privacy Policy

This Privacy Policy applies to:

• All users of the Slotly mobile app and website (customers and vendors).

• Vendors who sign up their businesses on Slotly.

• All individuals whose personal data we collect in connection with providing our services.

By using Slotly, you consent to the collection and processing of your personal data as described in this Privacy Policy.

2. Data We Collect

We may collect and process the following categories of personal data:

(a) Personal Identification Information

• Full name, ID/passport number, date of birth, gender.

• National ID or passport copy (for verification).

• KRA PIN or business registration certificate (vendors).

(b) Contact Information

• Phone number, email address, physical and postal addresses.

(c) Account & Profile Information

• Username, password (encrypted), profile picture, business profile, preferences, saved services.

(d) Financial & Transaction Data

• M-Pesa/payments reference numbers.

• Credit/debit card details (processed securely by third-party providers).

• Billing address, invoices, receipts, transaction history.

(e) Usage & Technical Data

• IP address, device type, OS version, app version.

• Log-in data, activity logs, clickstream data.

• Location data (if enabled).

(f) Marketing & Communication Data

• Communication preferences.

• Reviews, surveys, support requests, feedback.

(g) Sensitive Personal Data

• Health information only where voluntarily shared (e.g., for beauty or wellness services requiring disclosure).

• Only collected with explicit consent under Section 25 of the DPA.

3. How We Collect Your Data

We collect data in the following ways:

• Directly from you: When you sign up, make a booking, upload documents, or contact us.

• Automatically: Through cookies, analytics, and mobile device data.

• From vendors: If you book services, vendors may share updates on your appointments.

• From third parties: Payment processors, identity verification providers, or government registries (e.g., KRA).

4. How We Use Your Data

We use personal data strictly for legitimate purposes:

• To create and manage your Slotly account.

• To verify vendor identity and prevent fraud.

• To process payments securely.

• To send confirmations, receipts, and service updates.

• To personalize your user experience.

• To enable communication between customers and vendors.

• To enforce our Terms & Conditions and prevent misuse.

• To comply with legal and regulatory obligations (KRA, CBK, NSSF, NHIF).

• To conduct research, data analysis, and service improvements.

• For targeted marketing (only with your consent).

5. Legal Basis for Processing

Under the Kenya Data Protection Act (2019), we process your data on the following bases:

• Consent: When you voluntarily provide data for specific purposes.

• Contractual necessity: To provide services under our Terms & Conditions.

• Legal obligation: To meet tax, anti-fraud, or regulatory requirements.

• Legitimate interest: Improving services, maintaining security, preventing fraud.

6. Sharing & Disclosure of Data

We may share your personal data with:

• Vendors/Service Providers: To fulfill bookings.

• Payment Providers: For secure payment processing.

• Regulators & Law Enforcement: To comply with lawful requests.

• Third-party Service Providers: Hosting, analytics, SMS/email services.

• Business Partners: For marketing (only with your consent).

• Group Companies or Successors: In mergers, acquisitions, or restructuring.

We do not sell personal data under any circumstances.

7. Data Retention

We retain your data for as long as:

• You maintain an active account.

• Necessary to meet legal and financial obligations (minimum 7 years for tax records).

• Required to resolve disputes or enforce agreements.

After retention periods expire, we securely delete or anonymize your data.

8. Data Security

Slotly takes reasonable steps to secure your data through:

• End-to-end encryption for payments and communications.

• Secure cloud storage hosted in Kenya or in countries with adequate safeguards.

• Regular system audits and penetration testing.

• Access restricted to authorized staff under confidentiality agreements.

9. Your Data Rights

Under Sections 26–40 of the Kenya Data Protection Act, you have rights to:

• Access: Request copies of your personal data.

• Rectification: Correct inaccurate or incomplete data.

• Erasure: Request deletion of your data.

• Restriction: Limit how we process your data.

• Portability: Obtain your data in a machine-readable format.

• Objection: Opt out of marketing or automated decision-making.

Requests should be sent to privacy@slotly.com and will be addressed within 30 days as per the law.

10. Children’s Privacy

Slotly is not intended for users under 18 years without parental/guardian consent. If we discover that we have collected children’s data without consent, we will delete it immediately.

11. Cookies & Tracking

We use cookies and similar technologies to:

• Improve user experience.

• Analyze traffic.

• Deliver targeted ads (with consent).

Users may disable cookies in browser/app settings.

12. Cross-Border Transfers

If personal data is transferred outside Kenya, we ensure:

• The recipient country has adequate data protection laws; OR

• We have data processing agreements in place to safeguard your data.

13. Third-Party Links

Our app/website may contain links to third-party sites. We are not responsible for the privacy practices of these external services.

14. Changes to this Policy

We may update this Privacy Policy at any time. Updates will be communicated via email, app notifications, or on our website.

15. Contact Us

If you have questions, complaints, or data requests, please contact:

Data Protection Officer

Slotly Ltd.

Edipark Plaza, Nairobi, Kenya

Email: keslotly@gmail.com

Phone: +254 768088198