Data Policy

Smart. Safe. Seamless.

At Safiri by Citrus, we're committed to transparency and compliance with data protection laws. This policy outlines how we collect, process, store, and protect data for Platform Administrator account users.

Effective Date:
January 11th, 2025
Last Updated:
March 17th, 2025
Contact Email:
legal@citruslabs.co.ke
Mailing Address:
P.O. Box 23983 - 00100
Phone:
+254 112 400 000
1
Introduction & Scope
2
Definitions
3
Types of Data Collected
4
Legal Basis for Data Processing
5
Purpose of Data Collection
6
Data Storage & Security
7
Data Sharing
8
User Rights & Access
9
Data Retention & Deletion
10
Data Breach Notification
11
Cookies & Tracking
12
Policy Updates
13
Contact Information
1

Introduction & Scope

This Data Policy explains how Safiri by Citrus ("the Platform") collects, processes, stores, and protects data provided by Platform Administrator account users. The purpose of this Policy is to ensure transparency and compliance with Kenyan Data Protection laws, including the Data Protection Act (2025), as well as any other applicable regulations. This Policy applies solely to Platform Administrator account users who manage and oversee the entire school transport system through our centralized dashboard.

Transparency & compliance with Kenyan Data Protection laws
Applies to Platform Administrators managing school transport system
2

Definitions

For the purposes of this Policy, the following definitions apply:

Personal Data

Any information relating to an identified or identifiable natural person, including names, contact details, and other identifiers.

Processing

Any operation performed on personal data, including collection, storage, retrieval, use, disclosure, or deletion.

Data Subject

Any Platform Administrator account user whose personal data is processed by the Platform.

Data Controller

Citrus Labs Limited, which determines the purposes and means of processing personal data.

Data Processor

Any third party engaged by Citrus Labs Limited to process personal data on its behalf.

Sensitive Data

Personal data that is subject to special protection under Kenyan law, including any data considered sensitive under applicable regulations.

3

Types of Data Collected

Safiri by Citrus collects the following data from Platform Administrator account users:

Personal Information

Includes full name, contact details (email address, phone number), job title, and any other identifying information provided during registration.

Usage Data

Information regarding user interactions with the Platform, such as login timestamps, session durations, and activity logs.

Device Information

Data on the device used to access the Platform, including IP address, device type, operating system, and browser type.

Cookies and Tracking Data

Data collected via cookies and similar technologies to enhance the user experience and improve service performance.

Sensitive Data

If provided, any sensitive personal data will be processed with additional safeguards in accordance with Kenyan law.

5

Purpose of Data Collection and Processing

Data collected from Platform Administrator account users is used for:

Service Delivery

Enabling administrators to manage school registrations, user accounts, system performance, revenue settings, and security protocols.

System Administration

Monitoring and optimizing the operation of the Platform to ensure reliability and compliance.

Customer Support

Facilitating efficient support and troubleshooting for Platform-related issues.

Security and Compliance

Implementing security measures, conducting audits, and ensuring adherence to legal and regulatory obligations.

Marketing and Communication

Communicating updates, new features, and relevant promotional information, provided users have consented to such communications.

6

Data Storage and Security Measures

Data Storage

Personal data is stored securely on cloud-based servers and may be processed by third-party service providers who meet industry-standard security requirements. Data is retained only for as long as necessary to fulfill the purposes outlined in this Policy or as required by law.

Security Protocols

The Platform employs robust security measures including:

  • Encryption of data in transit and at rest
  • Strict access controls and multi-factor authentication
  • Regular security audits and vulnerability assessments
  • Firewalls, intrusion detection systems, and secure data backup procedures
7

Data Sharing and Third-Party Disclosures

8

User Rights and Access

Platform Administrator account users have the following rights regarding their personal data:

Right to Access

The right to request access to the personal data held by Citrus Labs Limited.

Right to Rectification

The right to have inaccurate or incomplete data corrected.

Right to Erasure

The right to request deletion of personal data, subject to legal obligations.

Right to Restrict Processing

The right to request limitations on the processing of personal data.

Right to Data Portability

The right to obtain personal data in a structured, commonly used, and machine-readable format.

Right to Object

The right to object to data processing based on legitimate interests or direct marketing.

Requests to exercise these rights should be submitted via the contact information provided in Section 13.

9

Data Retention and Deletion

Retention

Personal data will be retained for the period necessary to fulfill the purposes outlined in this Policy or as required by law. Specific retention periods will be determined based on the nature of the data and regulatory requirements.

Deletion

Once data is no longer required, it will be securely deleted or anonymized in accordance with Citrus Labs Limited's data retention policies.

10

Data Breach Notification and Response

1

Breach Detection

Citrus Labs Limited implements systems to detect potential data breaches promptly.

2

Notification Procedures

In the event of a data breach, affected users will be notified within a reasonable timeframe, and relevant regulatory authorities will be informed in accordance with Kenyan law.

3

Response Plan

A data breach response plan is in place, including measures for remediation, investigation, and prevention of future incidents.

11

Cookies and Tracking Technologies

Usage

The Platform may use cookies and similar tracking technologies to improve user experience and analyze usage patterns.

Management

Users can manage or disable cookies via their browser settings, although this may affect the functionality of the Platform.

12

Policy Updates and Amendments

Updates

Citrus Labs Limited reserves the right to update this Data Policy periodically. Material changes will be communicated to Platform Administrator account users via email or a notice on the Platform.

User Acceptance

Continued use of the Platform after such updates constitutes acceptance of the amended Data Policy.

13

Contact Information and Complaints

For any questions, clarifications, or complaints regarding this Data Policy, please contact:

Email

legal@citruslabs.co.ke

Mailing Address

P.O. Box 23983 - 00100

Phone

+254 112 400 000

If you believe your data has been mishandled or you are unsatisfied with our response, you may escalate your complaint to the relevant data protection authority in Kenya.

By using the Safiri by Citrus Platform Administrator account, you acknowledge that you have read, understood, and consent to the collection, processing, storage, and sharing of your personal data as described in this Data Policy.

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