Privacy notice

1. Who we are

Kibanda is a point-of-sale service for shops, provided by [company legal name], a company registered in Kenya under number [registration number], of [registered address] ("Kibanda", "we", "us"). We are registered with the Office of the Data Protection Commissioner as a [data controller / data processor] under registration number [ODPC registration number].

This notice explains how we handle personal data under the Data Protection Act, 2019 and its regulations.

2. Our role and the shop's role

Each shop that uses Kibanda decides what it records about its own customers and staff. For that data the shop is the data controller and Kibanda is its data processor: we store and process it only on the shop's instructions and to run the service. If you are a customer of a shop, contact that shop first about your data; we will help the shop answer you.

For the details of the people who sign up for and manage a shop's account, and for visitors to this website, Kibanda is the data controller.

3. What we collect

Shop owners and staff

• Name, email address and role in the shop.
• Sign-in records: when you signed in, from which device and network address (stored as a one-way hash for security monitoring).
• What you do in the till: sales, refunds, cash counts, approvals and changes to settings, recorded in an audit log.

A shop's customers

• Name and phone number, and an email address if the shop records one.
• Purchases, credit balances, repayments and receipts.
• For M-Pesa payments: the payer's masked phone number, name as reported by Safaricom, M-Pesa receipt number, amount and time.

Visitors to this website

Standard server logs (address, browser and pages requested). This site sets no tracking or advertising cookies.

4. How we use it, and on what basis

• To provide the service to the shop under our contract with it: recording sales, payments, stock and credit.
• To keep it secure (our legitimate interest and legal obligations): sign-in protection, rate limits, audit logs and backups.
• To meet legal obligations, such as tax and accounting record-keeping the shop is subject to.
• [Any other purpose, e.g. service emails or product updates, with its lawful basis]

We do not sell personal data, and we do not use a shop's customer data for our own marketing.

5. Who we share it with

• Safaricom, when a shop takes M-Pesa payments through its own Daraja account: the customer's phone number and the amount are sent to Safaricom to request and confirm the payment.
• Anthropic, only when a shop's owner switches on invoice reading: a photo or PDF of a supplier's invoice is sent to Anthropic's Claude API to be read into the shop's stock records. The app doesn't keep the file. [Anthropic's location and the transfer safeguard relied on.]
• Our hosting and backup providers: [list providers and what they do, e.g. server hosting, offsite backup storage, email delivery].
• Authorities, where the law requires it.

6. Where it is stored

Each shop's data is kept in its own database, on servers located in [country / region]. Encrypted backups are kept in [country / region]. [If any data leaves Kenya: the safeguards relied on under sections 48–50 of the Act.]

7. How long we keep it

We keep a shop's data for as long as its account is active. When a shop leaves, its data is deleted [number] days after the account closes; backups containing it expire within [number] days. Sales and payment records may be kept longer where tax law requires. [Confirm periods with counsel.]

8. How we protect it

Every shop's data is held in a separate database. Connections are encrypted, passwords and payment credentials are stored encrypted or as one-way hashes, staff see only what their role allows, and backups are encrypted. If a breach puts your data at risk, we will notify the shop, the Data Protection Commissioner and, where required, you, within the times the law sets.

9. Your rights

Under the Data Protection Act you have the right to:

• be told how your data is used (this notice);
• access the personal data held about you;
• have inaccurate data corrected;
• have data deleted where it is no longer needed;
• object to processing and to automated decisions;
• receive your data in a portable format.

To use these rights, contact the shop you deal with, or us (see below). You may also complain to the Office of the Data Protection Commissioner.

10. Cookies

The till uses one essential cookie to keep you signed in. It is removed when you sign out or the session expires. We use no analytics or advertising cookies.

11. Children

Kibanda is a business tool and is not meant for children. Shops should not record children's data unless the law allows it.

12. Changes to this notice

We will post any change here and update the date above. If a change materially affects how we use personal data, we will tell shop owners by email before it takes effect.

13. Contact us

Data protection officer: [name], at our contact address, or by post at [postal address].