Privacy Policy

SOQONI APP PRIVACY POLICY

Last Updated: 18 May 2026

Effective Date: 18 June 2026

1. INTRODUCTION AND SCOPE

1.1. Sokoni Applications Ltd (hereinafter referred to as “Soal,” “we,” “us,” “our,” “Company”), the owner and operator of the SoQoni mobile application (“App”), is committed to protecting the privacy and security of your personal data. This Privacy Policy (“Policy”) outlines our practices concerning the collection, use, processing, storage, disclosure, and protection of the personal information of all users of our Services, including Customers, Sellers, Service Providers, and Riders (collectively, “you” or “your”).

1.2. This Policy is formulated in strict adherence to the provisions of the Data Protection Act, No. 24 of 2019 of the Laws of Kenya, and all subsequent regulations and guidelines issued thereunder (the “Act”). By accessing, downloading, registering for, or using the SoQoni App and its associated services (the “Services”), you explicitly acknowledge that you have read, understood, and hereby provide your informed and unequivocal consent to the practices described in this Policy. If you do not agree with any term of this Policy, you must immediately cease all use of the App and Services.

2. DEFINITIONS

2.1. For the purposes of this Policy, the following terms shall have the meanings ascribed to them:

(a) “Personal Data” shall have the meaning given in the Data Protection Act and includes any information relating to an identified or identifiable natural person.

(b) “Data Subject” means an individual who is the subject of Personal Data.

(c) “Processing” encompasses any operation or set of operations which is performed on Personal Data, such as collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination, alignment, combination, restriction, erasure, or destruction.

(d) “Data Controller” refers to Sokoni Applications Ltd (Soal), which determines the purpose and means of the Processing of Personal Data.

(e) “Data Processor” means a natural or legal person, public authority, agency, or other body which processes Personal Data on behalf of the Data Controller.

(f) “Customer” shall mean any natural or legal person who accesses the Services for the purpose of procuring goods or services from Sellers or Service Providers via the App.

(g) “Seller” shall denote any registered business, merchant, or individual that has been granted permission by Soal to list, advertise, offer, and sell goods to Customers through the App.

(h) “Service Provider” shall mean any registered business or individual offering services through the App, including but not limited to professional services, repair services, or other non-goods offerings.

(i) “Rider” shall refer to an independent, third-party delivery contractor who is verified by Soal to provide logistics and delivery services for transactions conducted on the App.

  1. THE CATEGORIES OF PERSONAL DATA WE COLLECT

3.1. In the course of providing our Services, we may collect, use, store, and transfer different kinds of Personal Data about you, which we have grouped as follows:

  1. Identity and Contact Data:This includes, but is not limited to, your full name, username or similar identifier, title, residential and/or business address, email address, and telephone numbers.
  2. Profile and Transaction Data:This encompasses your order history, preferences, feedback and survey responses, details of products and services you have purchased or sold through the App, and information about the delivery of such products and services.
  3. Financial and Payment Data:This includes bank account details, M-Pesa numbers, Till Numbers, and other necessary payment instrument details required to process transactions, facilitate payouts, and administer refunds. Please note that while we facilitate payment processing, we utilize third-party payment processors, and we do not store your full payment card details on our servers.
  4. Technical and Usage Data:This includes your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to access the App. It also includes information about how you use our App and Services.
  5. Location Data:We collect and process real-time, precise geolocation data from your mobile device. For Riders, this is essential for the real-time tracking of deliveries and for the functioning of the Proximity Matching Algorithm. For Customers, this is used to determine your market segment and delivery address. For Sellers, this is used to verify your business location for the Proximity Matching Algorithm. You may disable location services through your device settings, but this will impair core functionalities of the App.
  6. Marketing and Communications Data:This includes your preferences in receiving marketing and promotional materials from us and our third-party partners, as well as your communication preferences. It also includes records of your correspondence with us, including calls to our support line (0748237799) and messages through the App.
  7. Special Category Data (Riders):In order to verify the eligibility and legitimacy of our Rider partners, we require and process copies of government-issued identification documents, such as your National Identity Card, and your valid motorcycle riding license. This data is processed in accordance with Section 30 of the Data Protection Act, 2019, as it is necessary for the purpose of carrying out the obligations and exercising specific rights of the Data Controller or the Data Subject in the field of employment and social security law.
  8. THE PURPOSES FOR WHICH WE USE YOUR PERSONAL DATA

4.1. We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

(a) Performance of a Contract: Where we need to perform the contract we are about to enter into or have entered into with you. This includes:

(i) Registering you as a new user and creating your account.

(ii) Processing and delivering your orders, including managing payments, fees, and charges.

(iii) Facilitating the matching of Customers with Sellers, Service Providers, and Riders.

(iv) Communicating with you regarding your orders, account, or our Services.

(b) Legitimate Interests: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. This includes:

(i) Administering and protecting our business and the App (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data).

(ii) Using data analytics to improve our App, Services, marketing, customer relationships, and experiences.

(iii) Detecting and preventing fraud, financial crime, and unauthorized activities.

(c) Legal Obligation: Where we need to comply with a legal or regulatory obligation, such as retaining business records for tax purposes or providing information to law enforcement agencies upon a valid request.

(d) Consent: Where you have provided your explicit, informed, and unambiguous consent for a specific purpose, such as receiving direct marketing communications via email or SMS. You have the right to withdraw this consent at any time by contacting us or adjusting your preferences in the App settings.

  1. DISCLOSURE OF YOUR PERSONAL DATA

5.1. We may share your Personal Data with the following categories of recipients for the purposes set out in this Policy:

  1. Other Users of the Service:As an integral part of the Service, it is necessary to share limited Personal Data between Users to facilitate a transaction.

(i) To Sellers: Upon order placement, a Seller will receive information necessary to fulfill the order, which includes the specific items purchased and the Customer’s delivery address.

(ii) To Service Providers: Upon a Customer expressing interest in a service listing, the Service Provider will receive the Customer’s contact information solely for the purpose of facilitating the service engagement. Soal does not participate in, monitor, or have access to any communications or negotiations between Customers and Service Providers. The terms of service, including pricing, timing, and location, are agreed upon entirely between the Customer and the Service Provider without any involvement from Soal.

(iii) To Riders: To facilitate delivery, a Rider will be provided with the Customer’s delivery address and contact phone number. This access is strictly limited to the duration of the active delivery assignment and is revoked upon completion or cancellation of the delivery.

(iv) To Customers: During an active delivery, a Customer will be provided with the Rider’s first name and contact phone number for the sole purpose of coordinating the delivery.

  1. Third-Party Service Providers (Data Processors):We engage carefully selected third-party companies and individuals to perform functions on our behalf. These entities are contractually obligated to process your data only in accordance with our instructions and for the specified purposes, and to maintain appropriate security measures. These include:

(i) Payment Processors: (e.g., M-Pesa) to securely facilitate financial transactions.

(ii) Cloud Storage and IT Service Providers: (e.g., Amazon Web Services, Google Cloud Platform) for data hosting and infrastructure.

(iii) Analytics Providers: (e.g., Google Analytics, Firebase) to help us understand how our App is used.

(iv) Communication Services: (e.g., Africa’s Talking, Twilio) to manage SMS and in-app notifications.

(v) Mapping Services: (e.g., Google Maps Platform) to provide location-based services, including calculating delivery fees and enabling real-time tracking.

  1. Legal and Regulatory Authorities:We may disclose your Personal Data to comply with a legal obligation, to protect and defend our rights or property, to prevent or investigate possible wrongdoing in connection with the Service, to protect the personal safety of users of the Service or the public, or to protect against legal liability, in accordance with the law.
  2. INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA

6.1. We primarily store and process your Personal Data on servers located within the Republic of Kenya. However, some of our third-party service providers may be located in, or have operations in, countries outside of Kenya. In such cases, we will ensure that appropriate safeguards, as required by the Data Protection Act, are in place to protect your Personal Data. This may include the use of standard contractual clauses approved by the relevant authorities.

  1. DATA SECURITY AND RETENTION

7.1. Data Security: We have implemented and will maintain appropriate technical and organizational security measures designed to protect your Personal Data against accidental, unauthorized, or unlawful loss, access, destruction, alteration, disclosure, or use. These measures include encryption of data in transit and at rest, strict access controls, and secure server infrastructure.

7.2. Data Retention: We will only retain your Personal Data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it, and whether we can achieve those purposes through other means. Upon the expiry of the retention period, or upon your valid request where applicable, your Personal Data will be securely deleted or anonymized.

  1. YOUR LEGAL RIGHTS UNDER THE DATA PROTECTION ACT, 2019

8.1. As a Data Subject, you have the following rights regarding your Personal Data:

(a) The right to access: You have the right to request copies of the Personal Data we hold about you.

(b) The right to correction: You have the right to request that we correct any information you believe is inaccurate or complete any information you believe is incomplete.

(c) The right to erasure (“the right to be forgotten”): You have the right to request that we erase your Personal Data, under certain conditions stipulated by the Act.

(d) The right to restrict processing: You have the right to request that we restrict the processing of your Personal Data, under certain conditions.

(e) The right to object to processing: You have the right to object to our processing of your Personal Data, under certain conditions.

(f) The right to data portability: You have the right to request that we transfer the data that we have collected to another organization, or directly to you, in a structured, machine-readable format.

8.2. To exercise any of these rights, please contact us using the details provided in Section 10 below. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.

  1. CHANGES TO THIS PRIVACY POLICY

9.1. We may update this Policy from time to time to reflect changes in our practices, technology, legal requirements, or other reasons. The “Last Updated” date at the top of this Policy will indicate when the latest revisions were made. We will notify you of any material changes through a prominent notice on the App or via email prior to the change becoming effective. Your continued use of the Services after such notification constitutes your acknowledgment and acceptance of the revised Policy.

  1. CONTACT US AND DATA PROTECTION OFFICER

10.1. If you have any questions, concerns, or requests regarding this Privacy Policy or our data protection practices, or if you wish to exercise any of your legal rights, please contact us at:

Sokoni Applications Ltd (Soal)

Kitengela, Red Heron Mall, Room 19D

Email: info@soqoni.co.ke; applications.sokoni@gmail.com
Phone: 0748237799
Website: www.soqoni.co.ke

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy.

 

SoQoni – Bringing All Your Markets to You.

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