Privacy Policy

SOKOSKULI MARKETPLACE

PRIVACY POLICY

Version 1.0

Document Owner: Manen Systems Limited

Platform: Sokoskuli Marketplace

Document Classification: Public

Effective Date: 11^th July 2026

Review Cycle: Annual

DOCUMENT CONTROL

TABLE OF CONTENTS

1. Introduction
2. Purpose
3. Scope
4. Definitions
5. Our Privacy Commitment
6. Information We Collect
7. How We Collect Information
8. Legal Basis for Processing
9. How We Use Your Information
10. Children's Privacy
11. Sharing of Personal Information
12. International Data Transfers
13. Data Security
14. Cookies & Tracking Technologies
15. Data Retention
16. Your Privacy Rights
17. Marketing Communications
18. Automated Decision-Making & Artificial Intelligence
19. Third-Party Services
20. Data Breach Response
21. Policy Updates
22. Contact Information

1. INTRODUCTION

This Privacy Policy explains how Manen Systems Limited, the owner and operator of the Sokoskuli Marketplace, collects, uses, stores, shares, protects and manages personal information obtained through the Sokoskuli platform.

This Privacy Policy forms an integral part of the Sokoskuli Marketplace Terms & Conditions and applies to every visitor, buyer, vendor, transporter, hostel provider, advertiser, educational institution, partner, employee, contractor and any other user interacting with the Sokoskuli platform.

By using Sokoskuli, you acknowledge that you have read and understood this Privacy Policy.

2. PURPOSE

The purpose of this Policy is to:

• protect the privacy of all Marketplace users;
• ensure lawful processing of personal information;
• promote transparency and accountability;
• explain users' privacy rights;
• comply with the Kenya Data Protection Act, 2019 and other applicable laws;
• build trust within the Sokoskuli ecosystem.

3. SCOPE

This Policy applies to all Sokoskuli services including:

• Marketplace Shopping
• Vendor Services
• Buyer Accounts
• School Transport
• Hostel Booking
• ECDE Marketplace
• Educational Services
• Donations
• Eco Points Programme
• Recycling Programme
• Customer Support
• Website
• Mobile Applications
• APIs
• Administrative Portals
• Marketing Platforms
• Social Media Channels

4. DEFINITIONS

Personal Data means information relating to an identified or identifiable natural person.

Processing means any operation performed on personal data, including collection, storage, use, disclosure, deletion or destruction.

Data Subject means the individual whose personal information is processed.

Data Controller means Manen Systems Limited in relation to the Sokoskuli Marketplace.

Data Processor means any person or organisation processing personal data on behalf of Manen Systems Limited.

5. OUR PRIVACY COMMITMENT

Sokoskuli is committed to:

• protecting user privacy;
• collecting only necessary information;
• processing data fairly and lawfully;
• maintaining strong security controls;
• respecting user rights;
• ensuring responsible use of technology and Artificial Intelligence.

Privacy is incorporated into the design of our systems through a "Privacy by Design and Default" approach.

6. INFORMATION WE COLLECT

Depending on how you use Sokoskuli, we may collect:

Identity Information

• Full Name
• National ID or Passport (where required)
• Student Identification
• Business Registration Details
• KRA PIN (where applicable)

Contact Information

• Mobile Number
• Email Address
• Postal Address
• Physical Address

Account Information

• Username
• Password (encrypted)
• Profile Photo
• Account Preferences
• Notification Settings

Transaction Information

• Orders
• Payments
• Refunds
• Delivery Information
• Vendor Transactions
• Booking Details

Device Information

• Device Type
• Browser
• Operating System
• IP Address
• Device Identifiers
• Log Files

Usage Information

• Pages Visited
• Search History
• Products Viewed
• Time Spent
• Click Behaviour
• Wishlist
• Eco Points Activity

Customer Support Information

• Complaints
• Support Requests
• Feedback
• Chat Records
• Call Records (where applicable)

7. HOW WE COLLECT INFORMATION

Information may be collected when you:

• create an account;
• complete your profile;
• purchase products;
• register as a vendor;
• make payments;
• contact customer support;
• upload documents;
• participate in promotions;
• complete surveys;
• browse the Marketplace;
• use our mobile application;
• interact with our advertisements;
• communicate with other users through authorised Marketplace features.

Some information may also be collected automatically through cookies and similar technologies, as described in our Cookie Policy.

8. LEGAL BASIS FOR PROCESSING

We process personal information where it is necessary:

• to perform a contract with you;
• to comply with legal obligations;
• to protect vital interests;
• for our legitimate business interests, provided these do not override your rights;
• based on your consent, where consent is required.

You may withdraw consent at any time where processing relies on consent, without affecting the lawfulness of processing carried out before withdrawal.

9. HOW WE USE YOUR INFORMATION

We may use personal information to:

• create and manage user accounts;
• process orders and bookings;
• facilitate payments and refunds;
• coordinate deliveries;
• verify identities;
• provide customer support;
• improve Marketplace functionality;
• personalise user experiences;
• prevent fraud and abuse;
• comply with legal obligations;
• maintain security;
• send important service notifications;
• communicate policy updates;
• conduct analytics and reporting;
• develop new Marketplace features.

We do not sell users' personal information.

10. CHILDREN'S PRIVACY

Sokoskuli primarily serves the education sector, including learners.

Where personal information relating to children is processed:

• appropriate safeguards shall be applied;
• collection shall be limited to what is necessary;
• parental, guardian or institutional authorisation may be required where applicable;
• information shall never be knowingly used for inappropriate marketing or profiling.

Users must not misuse the platform to obtain personal information from children.

11. SHARING OF PERSONAL INFORMATION

We may share information only where necessary with:

• Vendors fulfilling orders;
• Delivery Partners;
• Transport Providers;
• Hostel Providers;
• Payment Service Providers;
• Cloud Infrastructure Providers;
• Customer Support Providers;
• Government Authorities where legally required;
• Professional Advisers;
• Auditors;
• Law Enforcement Agencies where authorised by law.

Recipients are expected to protect personal information in accordance with applicable legal and contractual obligations.

12. INTERNATIONAL DATA TRANSFERS

Where personal information is transferred outside Kenya, Sokoskuli shall take reasonable steps to ensure that appropriate safeguards are in place and that such transfers comply with the Kenya Data Protection Act, 2019 and other applicable laws.

13. DATA SECURITY

We implement appropriate technical and organisational measures to protect personal information, including:

• encryption of sensitive data;
• secure network architecture;
• role-based access controls;
• multi-factor authentication for privileged accounts;
• regular security monitoring;
• vulnerability assessments;
• audit logging;
• secure backup procedures;
• disaster recovery planning.

While we strive to protect personal information, no system can guarantee absolute security.

14. COOKIES & TRACKING TECHNOLOGIES

Sokoskuli uses cookies and similar technologies to:

• remember user preferences;
• maintain secure sessions;
• improve website performance;
• understand user interactions;
• provide analytics;
• support essential Marketplace functionality.

Further information is available in the Sokoskuli Cookie Policy.

15. DATA RETENTION

Personal information is retained only for as long as necessary to:

• provide Marketplace services;
• comply with legal obligations;
• resolve disputes;
• enforce agreements;
• maintain business records.

When information is no longer required, it will be securely deleted, anonymised or archived in accordance with our Data Retention Policy.

16. YOUR PRIVACY RIGHTS

Subject to applicable law, you may have the right to:

• access your personal information;
• request correction of inaccurate information;
• request deletion where appropriate;
• object to certain processing activities;
• request restriction of processing;
• request portability of your personal data where applicable;
• withdraw consent where processing is based on consent;
• lodge a complaint with the Office of the Data Protection Commissioner (ODPC) or another competent authority.

Requests will be handled within the timelines required by applicable law.

17. MARKETING COMMUNICATIONS

Where permitted by law, Sokoskuli may send information about:

• Marketplace updates;
• educational opportunities;
• promotions;
• product recommendations;
• newsletters;
• service announcements.

You may opt out of promotional communications at any time. Essential service notifications will continue where necessary for account administration or legal compliance.

18. AUTOMATED DECISION-MAKING & ARTIFICIAL INTELLIGENCE

Sokoskuli may use automated systems and AI-assisted tools to support:

• fraud detection;
• spam prevention;
• content moderation;
• personalised recommendations;
• analytics;
• customer support.

Important decisions that significantly affect users will not be based solely on automated processing where prohibited by applicable law. Human oversight will be applied where appropriate.

19. THIRD-PARTY SERVICES

The Marketplace may integrate with third-party services, including:

• payment gateways;
• mapping services;
• analytics providers;
• cloud hosting services;
• communication platforms.

These providers operate under their own privacy obligations and are expected to process data in accordance with applicable laws and contractual commitments.

20. DATA BREACH RESPONSE

If Sokoskuli becomes aware of a personal data breach that poses a risk to individuals, we will:

• investigate the incident promptly;
• contain and mitigate the breach;
• notify affected individuals where required by law;
• notify the relevant regulatory authorities where legally required;
• implement corrective measures to reduce future risk.

21. POLICY UPDATES

This Privacy Policy may be updated periodically to reflect:

• legal developments;
• changes in Marketplace services;
• technological improvements;
• security enhancements.

Material changes will be communicated through the Marketplace. Continued use of Sokoskuli after such updates may require acknowledgement of the revised Policy.

22. CONTACT INFORMATION

Sokoskuli Marketplace
A Product of Manen Systems Limited

Registered Office
Hussein Building, 3rd Floor, Suite 12
Haile Selassie Road
P.O. Box 99282–80107
Mombasa, Kenya

Website: https://www.sokoskuli.co.ke

General Enquiries: info@sokoskuli.co.ke

Customer Support: support@sokoskuli.co.ke

Privacy Office: privacy@sokoskuli.co.ke

Data Protection Officer (DPO): dpo@sokoskuli.co.ke

Legal & Compliance: legal@sokoskuli.co.ke

Telephone: +254 116 363 483