1. Who We Are
HAgent ('we', 'us', 'our') operates the HAgent property listing and short-stay booking platform. We are the data controller of the personal information you provide to us.
Contact: privacy@hagent.app | Nairobi, Kenya
2. Information We Collect
2.1 Information You Provide
When you register or use HAgent, we may collect:
- Account details: full name, email address, phone number, profile photo.
- Agent details: professional/business name, licence or registration number (where applicable).
- Property listings: building name, address, GPS coordinates, property description, asking price or rental rate.
- Media content: photographs and videos of properties you upload.
- Contact information: names and phone numbers of property contacts you add.
- Payment information: billing address, bank account or mobile money details for payouts; card details collected by our payment processor (not stored by HAgent).
- Communications: messages sent via the in-app chat or support system.
2.2 Information We Collect Automatically
When you use the platform, we automatically collect:
- Device information: device type, operating system, browser type, unique device identifiers.
- Usage data: pages viewed, features used, search queries, listing interactions, and time spent on the app.
- Location data: approximate or precise location if you grant permission (used to show nearby properties).
- Log data: IP address, access times, referring URLs, error logs.
- Cookies and similar technologies: see Section 8.
2.3 Information from Third Parties
We may receive information from payment processors, identity verification providers, social login services (if you sign in via Google, Apple, etc.), and fraud prevention partners.
3. How We Use Your Information
We use your personal data for the following purposes:
- Account creation and authentication.
- Publishing and managing property listings on your behalf.
- Processing bookings and payments through the BnB Feature.
- Communicating with you about your account, bookings, and updates.
- Personalising your experience and surfacing relevant listings.
- Preventing fraud, enforcing our Terms of Service, and ensuring platform security.
- Complying with our legal obligations.
- Analytics and product improvement (using aggregated or anonymised data where possible).
- Sending marketing communications where you have consented (you may opt out at any time).
4. Legal Bases for Processing (GDPR / Kenya DPA)
Where applicable data protection law requires a legal basis for processing, we rely on:
- Contract performance: processing necessary to provide the HAgent service you signed up for.
- Legitimate interests: fraud prevention, security, product improvement, and direct marketing of our own services.
- Legal obligation: complying with tax, anti-money laundering, and other applicable laws.
- Consent: for marketing emails, push notifications, and precise location tracking.
5. Sharing Your Information
We do not sell your personal data. We may share your information with:
- Payment processors to facilitate bookings and payouts (e.g., Stripe, Flutterwave, M-Pesa APIs).
- Cloud hosting providers for data storage and app infrastructure.
- Analytics providers to help us understand platform usage (data is anonymised where possible).
- Identity verification services to confirm Agent credentials.
- Law enforcement or regulators where required by applicable law or court order.
- Business transfers: in the event of a merger, acquisition, or sale of assets, your data may be transferred (you will be notified).
All third-party partners are required to handle your data in accordance with this Privacy Policy and applicable data protection laws.
6. Data Retention
We retain your personal data for as long as your account is active or as needed to provide our services. Specifically:
- Account data is retained while your account is open and for up to 3 years after closure for legal and audit purposes.
- Transaction and payment records are retained for 7 years to meet financial and tax obligations.
- Property listing data (including photos and videos) is deleted within 90 days of removal of the listing, unless required for dispute resolution.
- Log data is retained for up to 12 months.
7. Data Security
We implement industry-standard technical and organisational measures to protect your data, including:
- TLS/HTTPS encryption for all data in transit.
- Encryption of sensitive data at rest.
- Role-based access controls limiting who can access personal data.
- Regular security assessments and penetration testing.
- Incident response procedures in the event of a data breach.
No method of internet transmission is 100% secure. While we strive to protect your data, we cannot guarantee absolute security. In the event of a breach affecting your rights, we will notify you as required by law.
8. Cookies & Tracking Technologies
HAgent uses cookies, pixels, and similar technologies to:
- Keep you logged in across sessions.
- Remember your preferences and settings.
- Analyse traffic and usage patterns.
- Serve relevant content.
You can manage cookie preferences in your browser settings or in the HAgent app settings. Disabling certain cookies may affect functionality.
9. Your Rights
Depending on your location, you may have the following rights regarding your personal data:
- Access: request a copy of the data we hold about you.
- Correction: request correction of inaccurate or incomplete data.
- Deletion: request deletion of your data ('right to be forgotten'), subject to legal obligations.
- Portability: receive your data in a structured, machine-readable format.
- Restriction: request that we limit processing of your data in certain circumstances.
- Objection: object to processing based on legitimate interests or for direct marketing.
- Withdraw consent: where processing is based on consent, you may withdraw it at any time.
To exercise any of these rights, contact us at privacy@hagent.app. We will respond within 30 days. You also have the right to lodge a complaint with the Office of the Data Protection Commissioner of Kenya.
10. Children's Privacy
HAgent is not directed at children under the age of 18. We do not knowingly collect personal data from minors. If you believe a minor has provided us with personal data, please contact us immediately and we will delete it.
11. International Data Transfers
HAgent operates primarily in Kenya. If your data is transferred to servers or processors outside Kenya, we ensure appropriate safeguards are in place (such as standard contractual clauses) to protect your information consistent with applicable law.
12. Third-Party Links
The platform may contain links to third-party websites or services. We are not responsible for their privacy practices and encourage you to review their policies independently.
13. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of material changes by posting a notice in the app or sending an email. The 'Effective Date' at the top indicates when the current version was last revised.
14. Contact Us
For any privacy-related questions, requests, or concerns, please contact our Data Protection Officer:
- Email: privacy@hagent.app
- Address: HAgent Data Protection Officer, Nairobi, Kenya
- In-App: Settings → Help & Support → Privacy Request