Keeyo Digital Solutions Ltd (“the Company”, “we”, “us”, or “our”) is committed to protecting your personal data and respecting your privacy. This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you use the MyShugli platform.
Under the Kenya Data Protection Act, 2019 (“DPA”), the Company acts as the Data Controller for all personal data you provide to us. This Policy is consistent with the DPA and reflects alignment with international standards including the UK General Data Protection Regulation (UK GDPR).
By creating an account or using the MyShugli platform, you acknowledge that you have read and understood this Privacy Policy.
Your full name, email address, diaspora or international telephone number, and encrypted account credentials. Collected at registration and required to operate your account.
Transaction reference numbers, payment amounts, and billing history. We do not store raw credit or debit card numbers or M-Pesa PINs. All payment processing is handled by IntaSend under its own security framework.
The details of your task request, including descriptions, special instructions, location, and any specific conditions. Used solely to execute the instructed task.
Names, local Kenyan telephone numbers, and physical addresses or GPS locations of individuals or places you instruct us to visit.
GPS-tagged photographs, operator location logs, receipts, and written reports generated during task execution. Uploaded to your private Client Portal as evidence of completion.
We use Mixpanel, a third-party analytics service, to collect anonymised data about platform usage, including page views, feature usage, and session duration. Phone numbers and personally identifying information are masked before transmission to Mixpanel. You may opt out by contacting us at hello@myshugli.com.
The MyShugli platform uses session cookies strictly necessary for maintaining your login state. We do not use advertising, behavioural, or cross-site tracking cookies.
Under Section 30 of the Kenya Data Protection Act, 2019, we only process personal data where a lawful basis exists:
We do not sell, rent, or trade your personal data. We share information only on a strict need-to-know basis with:
MyShugli specifically serves the international Kenyan diaspora. Personal data necessarily flows between your location (which may include the United Kingdom, Europe, North America, or other jurisdictions) and our operational base in Kenya.
In compliance with Section 48 of the Kenya Data Protection Act, 2019, and in alignment with the UK GDPR, any transfer of personal data is protected by appropriate safeguards and limited to what is strictly necessary for service delivery.
We have implemented appropriate technical and organisational measures including encrypted data transmission (HTTPS/TLS), authenticated platform access with IP-bound session controls, role-based access restrictions, and append-only audit logging.
In the event of a personal data breach likely to result in risk to your rights, the Company will notify the Office of the Data Protection Commissioner (ODPC) within 72 hours. Where the risk is high, we will also notify affected Clients without undue delay.
The MyShugli platform is intended exclusively for individuals aged 18 and over. We do not knowingly collect personal data from individuals under 18. If you believe a minor has provided data to us, please contact hello@myshugli.com immediately.
The Company does not make any decisions about you based solely on automated processing. All task assessments, quotations, and decisions involve human review by a Company operator.
To exercise any of the following rights, contact us at hello@myshugli.com. We will respond within 21 days of a valid request.
If you are unsatisfied with our response, you have the right to lodge a complaint with the Office of the Data Protection Commissioner (ODPC) at www.odpc.go.ke.
The MyShugli platform may contain links to third-party websites. This Privacy Policy applies solely to the MyShugli platform. We are not responsible for the privacy practices of any third-party sites.
We may update this Policy at any time. The current version is published on the MyShugli platform with an updated effective date. Continued use of the platform after any amendment constitutes acceptance of the revised Policy.
Supervisory Authority: Office of the Data Protection Commissioner (ODPC), Republic of Kenya — www.odpc.go.ke