Privacy notice
Last updated [date]
Draft. This text hasn't been reviewed by a lawyer yet. Text in [square brackets] still needs to be filled in before launch.
Who is responsible
[Company name], [registered address], is the data controller for featherinink. [Registration with the Office of the Data Protection Commissioner: number.] Contact us about your data at help@featherinink.com.
What we collect
When you buy
- Your name, email, M-Pesa phone number, delivery address and any directions for the rider.
- Payment records from M-Pesa: the amount, the phone number that paid, and the M-Pesa receipt. We never see or store your M-Pesa PIN.
- Your orders and their delivery progress.
When you ask for a book
- Your email, the book you want and the most you'd pay. Sellers only see the book, how many people asked and the prices; never who asked. Requests close after six months or when you cancel them.
- The words you type when looking a book up are sent to Google Books to suggest titles. We send only those words, not who you are.
When you create an account
- Your email and a password, stored only as a secure hash. Your saved phone number and delivery address, if you add them.
When you sell
- Your name, store name, location, email and the M-Pesa number for payouts, plus your listings, sales and payouts.
- Book photos you upload. We remove all hidden information from photos, including the GPS location phones add, before anyone can see them.
Automatically
- A sign-in cookie that keeps you signed in, and a cookie that lets your browser follow a payment you started. Your cart is kept in your browser until you sign in. We don't use advertising or tracking cookies.
- Your IP address, used briefly to protect sign-in and checkout from abuse.
- Technical error reports when something breaks, which may include the page you were on and your browser type.
Why we use it
- To take payment, deliver your order, and send receipts and delivery updates (to carry out our contract with you).
- To pay sellers and process refunds.
- To keep accounts secure and prevent fraud (our legitimate interest).
- To keep financial records we are required to keep by law.
We don't sell your data, and we don't send marketing emails [unless you opt in].
Who sees it
- The seller of your books sees your name, phone number, delivery address and rider directions for that order only.
- The rider gets what they need to deliver: your name, phone number and address.
- Safaricom processes M-Pesa payments, refunds and payouts.
- Service providers who run featherinink for us: hosting and storage (Amazon Web Services), email delivery ([provider]), error reporting (Sentry) and book look-ups (Google Books, which receives only the words typed). [Confirm which of these store data outside Kenya, and the safeguards in place.]
- Our team, who can see orders and accounts to help you. Every change they make is logged.
- Authorities, where the law requires it.
How long we keep it
We keep order and payment records for [period required for tax and accounting]. Account details are kept while your account is open and for [period] after you ask us to close it. [Retention periods for backups and error reports.]
Your rights
Under the Data Protection Act, 2019, you can ask us to:
- tell you what data we hold about you and give you a copy;
- correct data that's wrong (you can also change your name, phone and address yourself under Profile);
- delete your data, unless we must keep it by law;
- stop or limit how we use it, or object to a use.
Contact us at help@featherinink.com and we'll reply within [number] days. If you're unhappy with our answer, you can complain to the Office of the Data Protection Commissioner (odpc.go.ke).
Security
Data travels over encrypted connections. Passwords are hashed, payment callbacks are checked, and only our team can open the admin area, with access depending on their role. If a breach puts your data at risk, we'll tell you and the Data Commissioner as the law requires.
Changes
We'll update this notice when how we use data changes, and show the date at the top.