Privacy Policy
Your privacy is important to us. This policy explains how we collect, use, and protect your personal information in compliance with the Kenya Data Protection Act 2019 and international data protection standards.
Effective Date: January 2025 | Last Updated: January 2025
Table of Contents
1. Data Controller Information
Kenya Tchoukball Federation ("KTF," "we," "us," or "our") is the data controller responsible for your personal information collected through our website and services.
Data Controller: Kenya Tchoukball Federation
Registered Address: Nairobi, Kenya
Website: https://tchoukball.ke
Data Protection Officer: [email protected]
General Inquiries: [email protected]
Phone: +254 729 356 779
By using our website at tchoukball.ke or our services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our data practices, please discontinue use of our website and services.
2. Information We Collect
2.1 Personal Information You Provide
We collect information you voluntarily provide when you:
- Create an account: Full name, email address, phone number, password, profile photo
- Register as a member/player: Date of birth, gender, National ID/passport number, postal address, nationality
- Register for teams/clubs: Team affiliation, playing position, jersey number, emergency contact information
- Register for events: Dietary requirements, accessibility needs, travel information
- Make purchases: Billing address, shipping address, M-Pesa phone number
- Subscribe to communications: Email address, communication preferences
- Contact us: Name, email, phone number, message content
- Connect via social media: Social media profile information (if you link accounts)
2.2 Sensitive Personal Data
We may collect the following sensitive/special category data with your explicit consent:
- Health information: Medical conditions relevant to player safety, allergies, disabilities requiring accommodation
- Biometric data: Photos for player identification (if applicable)
Note: Under the Kenya Data Protection Act 2019, sensitive personal data requires explicit consent and is subject to additional protections.
2.3 Information Collected Automatically
When you visit our website, we automatically collect:
- Device information: IP address, browser type and version, operating system, device type
- Usage data: Pages visited, time spent on pages, click patterns, referring/exit pages
- Location data: Approximate geographic location based on IP address
- Cookies and similar technologies: Session cookies, persistent cookies, pixel tags (see Section 7)
2.4 Information from Third Parties
We may receive information about you from:
- Social media platforms: When you log in using Facebook, Google, or other social accounts
- Payment processors: Transaction confirmation from M-Pesa/Safaricom
- International Federation (FITB): Player registration verification
- Partner organizations: Sports Kenya, SASDEF, other sports bodies
3. Legal Basis for Processing
Under the Kenya Data Protection Act 2019 (Section 30) and in alignment with GDPR principles, we process your personal data based on the following lawful grounds:
| Processing Activity | Legal Basis |
|---|---|
| Account creation and management | Contract performance |
| Membership and player registration | Contract performance |
| Processing payments | Contract performance |
| Event registration | Contract performance |
| Marketing communications | Consent (opt-in) |
| WhatsApp/SMS notifications | Consent (opt-in) |
| Website analytics | Legitimate interests |
| Fraud prevention and security | Legitimate interests |
| Health/medical information | Explicit consent |
| Legal compliance (tax, sports regulations) | Legal obligation |
| FITB international registration | Contract performance / Consent |
Legitimate Interests: Where we rely on legitimate interests, we have conducted a balancing test to ensure your rights and freedoms do not override our interests. You may request details of this assessment by contacting our Data Protection Officer.
4. How We Use Your Information
We use the collected information for the following purposes:
4.1 Core Services
- Create and manage your account and membership
- Process registrations for teams, clubs, and events
- Process transactions, orders, and payments via M-Pesa
- Manage player statistics, rankings, and match records
- Issue membership cards and player licenses
- Facilitate participation in national and international competitions
4.2 Communications
- Send transactional emails (order confirmations, registration confirmations)
- Send important service announcements and updates
- Send newsletters and marketing communications (with your consent)
- Respond to your inquiries and provide customer support
- Send WhatsApp/SMS notifications (with your consent)
4.3 Safety and Compliance
- Ensure player safety during events and competitions
- Comply with sports federation regulations (FITB, Sports Kenya)
- Prevent fraud and protect against security threats
- Comply with legal obligations under Kenyan law
4.4 Improvement and Analytics
- Analyze website usage to improve our services
- Develop new features based on user needs
- Conduct research for the development of tchoukball in Kenya
5. Information Sharing & Disclosure
We do not sell, rent, or trade your personal information to third parties for their marketing purposes. We may share your information only in the following circumstances:
5.1 Service Providers
- Payment Processing: Safaricom (M-Pesa) for transaction processing
- Hosting Services: Cloud infrastructure providers for website hosting
- Email Services: Email delivery providers for communications
- Analytics: Website analytics services (with anonymized data where possible)
5.2 Sports Organizations
- International Federation of Tchoukball (FITB): Player registrations for international competitions
- Sports Kenya: National sports regulatory compliance
- SASDEF: Sports development and heritage requirements
- Event Organizers: Tournament and event participant information
5.3 Legal Requirements
We may disclose your information when required to:
- Comply with applicable laws, regulations, or legal processes
- Respond to lawful requests from public authorities
- Protect the rights, property, or safety of KTF, our users, or others
- Enforce our terms and policies
5.4 Business Transfers
In the event of a merger, acquisition, or sale of assets, your personal information may be transferred to the acquiring entity. We will notify you of any such change and any choices you may have regarding your information.
6. Data Retention Periods
We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected. Specific retention periods are:
| Data Type | Retention Period | Reason |
|---|---|---|
| Account information | Duration of account + 3 years | Service provision, legal claims |
| Membership records | 7 years after expiry | Legal compliance, audit requirements |
| Transaction records | 7 years | Tax and financial regulations |
| Player statistics | Indefinitely (anonymized) | Historical sports records |
| Marketing consent | Until withdrawn + 1 year | Proof of consent |
| Website analytics | 26 months | Usage analysis |
| Support communications | 3 years | Service improvement, dispute resolution |
After the retention period, data is either securely deleted or anonymized for statistical purposes. You may request earlier deletion subject to our legal obligations.
9. Messaging & Communications
9.1 WhatsApp Business
We may use WhatsApp Business to communicate with members and users. When you opt in to receive WhatsApp messages:
- Your phone number is shared with WhatsApp (Meta) for message delivery
- Message content may include event updates, order notifications, and member communications
- WhatsApp may process metadata in accordance with their privacy policy
- You can opt out at any time by texting "STOP" or updating your preferences in your account
WhatsApp messages are subject to WhatsApp's Privacy Policy.
9.2 SMS Communications
With your consent, we may send SMS messages for:
- M-Pesa payment confirmations
- Event reminders and urgent notifications
- Account security alerts
9.3 Email Communications
- Transactional emails: Order confirmations, password resets (cannot be opted out)
- Marketing emails: Newsletters, promotions (requires opt-in, can unsubscribe anytime)
10. Your Data Protection Rights
Under the Kenya Data Protection Act 2019 and international standards, you have the following rights:
Right of Access
Request a copy of the personal data we hold about you, free of charge.
Right to Rectification
Request correction of inaccurate or incomplete personal data.
Right to Erasure ("Right to be Forgotten")
Request deletion of your personal data, subject to legal retention requirements.
Right to Restriction of Processing
Request that we limit how we use your data in certain circumstances.
Right to Data Portability
Receive your data in a structured, commonly used, machine-readable format.
Right to Object
Object to processing based on legitimate interests or for direct marketing.
Right to Withdraw Consent
Withdraw consent at any time where processing is based on consent.
Right to Lodge a Complaint
Lodge a complaint with the Office of the Data Protection Commissioner (ODPC) Kenya.
How to Exercise Your Rights
- Self-service: Update your information in your account settings
- Email request: Send a request to [email protected]
- Phone: Contact us at +254 729 356 779
- Written request: Send to our registered address
Verification: We may need to verify your identity before processing your request. We will respond within 30 days as required by the Kenya Data Protection Act 2019.
Data Deletion Request: To delete your account and associated data, email [email protected] with the subject line "Data Deletion Request" and include your registered email address and phone number for verification.
11. Data Security Measures
We implement appropriate technical and organizational measures to protect your personal data:
Technical Measures
- Encryption: SSL/TLS encryption for all data in transit (HTTPS)
- Password Security: Bcrypt hashing for stored passwords
- Access Controls: Role-based access to personal data
- Secure Payments: PCI-DSS compliant payment processing via M-Pesa
- Regular Updates: Security patches and software updates
- Backups: Regular encrypted backups with secure storage
Organizational Measures
- Staff training on data protection
- Data protection impact assessments for high-risk processing
- Vendor due diligence for third-party processors
- Incident response procedures
Your Responsibility: You are responsible for keeping your account credentials confidential. Use a strong password and enable two-factor authentication if available. Notify us immediately at [email protected] if you suspect unauthorized access to your account.
12. Children's Privacy
We are committed to protecting the privacy of children in accordance with the Kenya Children Act and international child protection standards.
Age Requirements
- Users must be at least 13 years old to create an account
- Users under 18 require parental/guardian consent for registration
Youth Player Registration
For players under 18, we collect information with verifiable parental/guardian consent:
- Player name, date of birth, and contact information
- Parent/guardian name and contact details
- Medical information relevant to player safety
- Consent for photography/video at events (optional)
Parental Rights
Parents/guardians may review, correct, or request deletion of their child's information by contacting [email protected]. We do not share children's information with third parties for marketing purposes.
13. International Data Transfers
Your personal data may be transferred to and processed in countries outside Kenya. These transfers occur when:
- FITB Registration: Player data is shared with the International Federation of Tchoukball in Switzerland
- International Events: Participant information is shared with host countries for tournaments
- Cloud Services: Our hosting and service providers may process data in various jurisdictions
- Social Media Platforms: Meta (USA/Ireland) for Facebook/WhatsApp services
Safeguards
In accordance with Section 48 of the Kenya Data Protection Act 2019, we ensure appropriate safeguards for international transfers:
- Transfers to countries with adequate data protection laws
- Standard contractual clauses with service providers
- Binding corporate rules where applicable
- Your explicit consent for specific transfers
14. Automated Decision-Making
We may use automated processing in limited circumstances:
- Fraud Detection: Automated systems may flag suspicious transactions for review
- Player Rankings: Statistics-based automated ranking calculations
- Email Filtering: Automated spam detection on communications
We do not use solely automated decision-making that produces legal effects or similarly significantly affects you without human review.
You have the right to request human intervention, express your point of view, and contest any automated decision by contacting us.
15. Data Breach Notification
In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will:
- Notify the Office of the Data Protection Commissioner (ODPC) within 72 hours as required by law
- Communicate the breach to affected individuals without undue delay if there is a high risk
- Provide information about the nature of the breach, likely consequences, and measures taken
- Offer guidance on steps you can take to protect yourself
We maintain incident response procedures and regularly test our breach notification processes.
16. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons.
- The "Last Updated" date at the top will be revised
- Material changes will be communicated via email or website notice
- Continued use of our services after changes constitutes acceptance
- We encourage you to review this policy periodically
For significant changes affecting your rights, we will seek your renewed consent where required by law.
17. Contact & Complaints
Contact Us
For questions about this Privacy Policy, to exercise your data rights, or for any privacy-related concerns:
Kenya Tchoukball Federation
Data Protection Officer
Email: [email protected]
General: [email protected]
Phone: +254 729 356 779
Address: Nairobi, Kenya
Lodge a Complaint
If you believe your data protection rights have been violated and we have not addressed your concerns satisfactorily, you have the right to lodge a complaint with:
Office of the Data Protection Commissioner (ODPC)
Website: www.odpc.go.ke
Email: [email protected]
Location: Nairobi, Kenya
Or contact us directly:
Kenya Tchoukball Federation
Data Protection Contact
Email: [email protected]
Phone: +254 745 170 881
Location: Nairobi, Kenya
Have questions about your privacy or data rights?
8. Social Media & Third-Party Platforms
8.1 Social Login
If you choose to register or log in using a social media account (Facebook, Google, etc.), we receive:
We do not post to your social media accounts or access your contacts without your explicit permission.
8.2 Social Media Widgets
Our website may include social media features (share buttons, embedded feeds). These features may:
8.3 Meta (Facebook/Instagram) Integration
We may use Meta technologies for:
Your data shared with Meta is subject to Meta's Privacy Policy. You can manage your Meta privacy settings through your Facebook/Instagram account.