MBOKAMAN is committed to protecting the privacy and personal data of everyone who uses our Services, including Recruiters, Contractors, Employers, Workers, and Candidates.

This Privacy Policy explains what personal data we collect, why we collect it, how we use, share, retain, and protect it, and the rights available to data subjects under applicable Kenyan data protection laws, including the Data Protection Act, 2019 and its subsidiary regulations.

By using the Platform, you acknowledge the processing of your personal data as described in this Privacy Policy, subject to the applicable legal basis for each processing activity.

1. Data Controller

MBOKAMAN is the Data Controller responsible for personal data processed through the Platform, subject to applicable data protection laws and regulations.

2. Information We Collect

Information Workers and Candidates Provide

Depending on how you use the Platform, we may collect:

1. Full name, national ID/passport number, date of birth, gender, and contact details;
2. CV/resume, employment history, education, qualifications, and certifications;
3. Profile photo, where uploaded;
4. References and, where applicable, background-check information; and
5. Communications with Recruiters, Contractors, and Employers through the Platform.

Information Recruiters, Contractors and Employers Provide

1. Company or business name and registration details;
2. Contact person's name, role, email address, and telephone number;
3. Job listings and related recruitment content; and
4. Payment and billing information, where applicable.

Information Collected Automatically

1. IP address, browser type, and device information;
2. Log data, cookies, and usage analytics; and
3. Location data, where enabled and permitted.

3. How We Use Your Information

We may process personal data for the following purposes:

1. To create and manage user accounts and profiles;
2. To match Workers with relevant job opportunities and Recruiters with suitable Candidates;
3. To facilitate communication between Recruiters and Workers;
4. To verify identity and help prevent fraud or misuse of the Platform;
5. To process payments, where applicable;
6. To send notifications, service updates, and marketing communications where permitted and, where required, with your consent;
7. To comply with legal, regulatory, and lawful law-enforcement obligations; and
8. To improve, secure, maintain, and develop the functionality of the Platform.

4. Legal Basis for Processing

In accordance with applicable data protection law, including the Data Protection Act, 2019, we process personal data based on one or more applicable legal grounds, including:

1. Consent – where you have provided clear consent for us to process your personal data for a specific purpose;
2. Contractual necessity – where processing is necessary to provide the Services you have requested or to perform a contract with you;
3. Legal obligation – where processing is required to comply with applicable Kenyan law or another legal obligation; and
4. Legitimate interests – where processing is necessary for legitimate business interests and those interests do not override your rights and freedoms.

5. Sharing of Information

Between Users

Worker profiles, CVs, and application materials may be shared with Recruiters for legitimate recruitment purposes. Recruiter job listings and relevant company information may be made available to Workers.

Third-Party Service Providers

We may share personal data with trusted service providers, including payment processors, cloud hosting providers, analytics providers, communication providers, and background-check providers, where applicable and where necessary for operating and providing the Platform.

Legal Requirements

We may disclose personal data where required or permitted by applicable law, court order, regulatory requirement, or lawful request, or where necessary to protect the rights, property, or safety of the Platform, our Users, or the public.

No Sale of Personal Data

MBOKAMAN does not sell personal data to third parties.

6. Data Retention

We retain personal data only for as long as reasonably necessary to fulfil the purposes described in this Privacy Policy or as required or permitted by applicable law, including tax, employment, regulatory, dispute-resolution, and other legitimate record-keeping requirements.

Where personal data is no longer required, we may delete, anonymize, or securely dispose of it, subject to applicable legal retention obligations.

7. Data Security

We implement reasonable technical and organizational measures designed to protect personal data against unauthorized access, loss, misuse, alteration, disclosure, or destruction.

Such measures may include encryption, access controls, secure server infrastructure, and appropriate operational safeguards.

However, no method of transmission or storage is completely secure. Accordingly, while we take reasonable steps to protect personal data, we cannot guarantee absolute security.

8. Your Rights as a Data Subject

Subject to applicable law and any lawful limitations, you may have the right to:

1. Be informed of the use to which your personal data is to be put;
2. Access your personal data held by us;
3. Request correction or rectification of inaccurate, incomplete, or outdated data;
4. Request deletion of your personal data, subject to applicable legal retention requirements;
5. Object to or request restriction of certain processing of your personal data;
6. Withdraw consent at any time where processing is based on consent;
7. Request data portability, where applicable; and
8. Lodge a complaint with the Office of the Data Protection Commissioner (ODPC) where you believe your data protection rights have been violated.

Requests concerning your personal data should be made through the contact channels provided by MBOKAMAN.

9. Children's Privacy

The Platform is not intended for individuals under 18 years of age. We do not knowingly collect personal data from minors.

If we become aware that we have inadvertently collected personal data belonging to a minor, we will take reasonable steps to delete such information in accordance with applicable law.

10. Third-Party Links

The Platform may contain links to third-party websites, applications, or services. MBOKAMAN is not responsible for the privacy practices, security, or content of such third parties.

We encourage Users to review the privacy policies and terms of any third-party services they access through links provided on the Platform.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our services, technology, business practices, or applicable legal requirements.

Where appropriate, material changes may be communicated through the Platform or by email. Continued use of the Platform after changes take effect constitutes acceptance of the revised Privacy Policy to the extent permitted by applicable law.