1. Introduction

Jumbo Greens ("we," "our," or "us") is committed to protecting your personal data and privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information in compliance with the Data Protection Act, 2019 of Kenya and other applicable data protection laws.

By using our services, you consent to the collection and use of your personal data as described in this Privacy Policy.

2. Data Controller Information

Business Name: Jumbo Greens
Data Controller: Noreen Anditi
Contact Phone: +254 721 612407
Operating Location: Nairobi, Kenya

If you have any questions about this Privacy Policy or our data practices, please contact us using the information above.

3. Legal Basis for Processing

We process your personal data based on the following legal grounds under the Data Protection Act, 2019:

• Consent: You have given clear consent for us to process your personal data for specific purposes
• Contract: Processing is necessary for the performance of a contract with you (e.g., processing orders)
• Legal Obligation: Processing is necessary to comply with legal obligations
• Legitimate Interests: Processing is necessary for our legitimate business interests, provided these do not override your rights

4. Information We Collect

4.1 Personal Information You Provide

• Account Information: Name, email address, phone number, password
• Delivery Information: Delivery address, apartment/house details, location zone
• Payment Information: M-Pesa transaction codes, payment method preferences (we do not store complete card details)
• Order Information: Products ordered, order history, preferences
• Communication: Messages, feedback, and correspondence with us

4.2 Information Automatically Collected

• Device Information: IP address, browser type, operating system
• Usage Information: Pages visited, time spent on pages, links clicked
• Location Data: General location information based on IP address (not precise GPS coordinates)
• Cookies and Similar Technologies: Information collected through cookies and tracking technologies

5. How We Use Your Information

We use your personal data for the following purposes:

• Order Processing: To process and deliver your orders
• Account Management: To create and manage your account
• Payment Processing: To process payments and verify transactions
• Customer Service: To respond to your inquiries and provide support
• Communication: To send order confirmations, delivery updates, and service notifications
• Marketing: To send promotional offers and updates (with your consent)
• Improvement: To improve our services, website, and user experience
• Legal Compliance: To comply with legal obligations and protect our rights
• Security: To prevent fraud and ensure platform security

6. Data Sharing and Disclosure

We do not sell your personal data. We may share your information with:

6.1 Service Providers

• Delivery partners for order fulfillment
• Payment processors for transaction processing (M-Pesa, payment gateways)
• Cloud hosting providers for data storage
• Analytics providers for service improvement

6.2 Legal Requirements

We may disclose your information when required by law or to:

• Comply with legal processes or government requests
• Enforce our Terms and Conditions
• Protect our rights, property, or safety, or that of others
• Prevent fraud or criminal activity

6.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections.

7. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction, including:

• Encryption of data in transit and at rest
• Secure authentication and access controls
• Regular security assessments and updates
• Employee training on data protection
• Restricted access to personal data on a need-to-know basis

However, no method of transmission over the internet is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

8. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

• Account Data: Retained while your account is active and for a reasonable period after closure
• Order Data: Retained for 7 years for accounting and tax purposes as required by Kenyan law
• Marketing Data: Retained until you withdraw consent or opt-out

After the retention period, we will securely delete or anonymize your personal data.

9. Your Data Protection Rights

Under the Data Protection Act, 2019 of Kenya, you have the following rights:

• Right to Access: Request copies of your personal data
• Right to Rectification: Request correction of inaccurate or incomplete data
• Right to Erasure: Request deletion of your personal data (subject to legal obligations)
• Right to Restrict Processing: Request limitation of how we use your data
• Right to Data Portability: Request transfer of your data to another service provider
• Right to Object: Object to processing of your data for certain purposes
• Right to Withdraw Consent: Withdraw consent where processing is based on consent
• Right to Lodge a Complaint: Complain to the Office of the Data Protection Commissioner

To exercise any of these rights, please contact us at +254 721 612407. We will respond to your request within 30 days as required by law.

10. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience on our website.

Types of Cookies We Use:

• Essential Cookies: Necessary for the website to function properly (e.g., shopping cart, authentication)
• Performance Cookies: Help us understand how visitors interact with our website
• Functional Cookies: Remember your preferences and settings
• Marketing Cookies: Track your browsing to provide relevant advertisements

You can manage cookie preferences through your browser settings. However, disabling certain cookies may affect website functionality.

11. Marketing Communications

With your consent, we may send you promotional emails, SMS, or other communications about our products and special offers. You can opt-out at any time by:

• Clicking the "unsubscribe" link in our emails
• Replying "STOP" to SMS messages
• Contacting us at +254 721 612407
• Updating your communication preferences in your account settings

12. Children's Privacy

Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal data from children. If you believe we have collected information from a child, please contact us immediately so we can delete it.

13. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies before providing any personal information.

14. International Data Transfers

Your data is primarily processed and stored within Kenya. If we transfer data outside Kenya, we will ensure appropriate safeguards are in place as required by the Data Protection Act, 2019.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of significant changes by:

• Posting the updated policy on our website with a new "Last updated" date
• Sending an email notification for material changes
• Displaying a notice on our website

Your continued use of our services after changes are posted constitutes acceptance of the updated Privacy Policy.

16. Data Protection Commissioner

If you have concerns about how we handle your personal data, you have the right to lodge a complaint with the Office of the Data Protection Commissioner of Kenya:

Office of the Data Protection Commissioner
Nairobi, Kenya
Website: www.odpc.go.ke

17. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us:

Jumbo Greens
Data Controller: Noreen Anditi
Phone: +254 721 612407
Contact Form: Visit our Contact Page