This privacy policy template is drafted to complyt with theKenyan Data Protection Act (2019). Review it against you specific operation and consult a lawyer for anything contested.

Privay policy - Fodabe Solutions

Date update :

2026 - 06 - 07

Fodabe Solutions ("we", "us", "our") operates a paid hotspot in Kenya. This policy explains what personal data we colllect when you connect to our network, why we collect it and what rights you have over it. We comply with theKenyan Data Protection Act, (2019) and are registered with the Office of the Data Protection Commisioner ("ODPC") as a Data Controller.

1. Who we are

Bussiness Name: Fodabe solutions

KRA PIN : Kra pin

Physical Address : Bussiness Address

Contact For Protection Enquiry : support@fodabe.co.ke

ODPC Registartion : REg No

2 When a usser connects to a hotspot powered by Fodabe Solutions, we may collect :

Phone Number

Network Identifiers

Location of Your sessions (Location of our routers you connect to )

Session Logs

Transaction Details

We do not collect : your ID, biometric data, banking Credentials, the content of websites you visit or your browsing history.

3. Purpose of the data we collect

Data	Why we colllect	Lawful basic under the Act
Phone Number	To send STK prompt for payment and issueing of subscription receipt	Contract performace and legal obligaiton.
Network identifiers (device's MAc, IP address we assign you, host Name if your devices shares one)	These Idebtifiers allow us to grant you subscription session and prevent abuse.	Contract performance - s.30(b)
Transaction details	TO prevent fraud and voucher abuse.	Our legitimate interest - s.30f
Session logs	Complying with the law (KRA) and any directives from CA	Logal obligation - s.30(c)
Phone number	Marketing (SMS, about new packages, and updates - only is opted in )	Your consent - s.30(a), withdrawable any time

4 . Who we share the data we collect with

Sfaricom PLC - To process M-Pesa Payments (phone number nad amount submitted by customer)

Fodabe Solutions - The operator of the Fodabe Solutions Billing system which hosts our managament system on our behalf as our data processor.

The kenya revenue authority - when required to disclose ransaction records

The communication authority of Kenya / law enforcement - when compelled by a lawful order

WE do not sell your data, and we do not transfer it outside Kenya without the safeguards required in Part VI of the Act

5. How long do we keep it

Data	Rention Period
Payment Records (M-Pesa transaction codes, and amounts)	5 years- Tax Procedures Act
Session Logs (start/end, MAC, IP, bytes Used)	7 Months from session end
Marketing Consent	Until you withdral consent

After the rention we parmanently delete the data.

6. Your rights

Under the Act , you have the right to:

Be informed about how your data if processed (this policy)

A copy of teh dta we hold for you (your phone number, amount, transaction code, and session details shared after a successfull purchase.)

Rectify wrong or incomplete data

Erase your data subject to data we must keep by the law

Restrict or object to processing -including to opt out of narketing at anytime.

Lodge a compliant with teh ODPC if you believe we have mishadled your data

To excersise any of these right, conatct us support@fodabe.co.ke 0759841454 phone/whatsapp . We will respond within 7 working days.

7. Security

We apply reasonable technical and organistional security measures to protect your data, Including TLS-encrypted transport, password hashing, Role based Access Controls, and audited backups. If a breach haapens affecting our operations, systems or data, we will notify you and the ODPC within 72 hours as required by the s.43 of teh Act

8. Parental Guidance

Our services is intended for users aged 18 and above. If under the age of 18, consent should be sought from parent / guardian to make purchase on your behalf.

9. Changes to this policy

WE may update this policy from time to time . the "Last Update" date at the top shows when it was last changed. Material changes will be updated on our captive portal(s).

10. Contact

Fodabe Solutions
Address
support@fodabe.co.ke
0759841454 phone/whatsapp

Privacy policy