Effective Date: 20th November 2025
1. Introduction
Wambugu International Limited (“we”, “us”, or “our”) is committed to protecting the personal data of our website visitors, clients, leads, and business partners. This Privacy Policy explains how we collect, use, disclose, and protect your personal data in compliance with the Kenya Data Protection Act, 2019.
2. Data Controller
Wambugu International Limited is the Data Controller under Kenyan law. Our Data Protection Officer (DPO) can be contacted at:
Email: info@wambugu.co.ke
Address: P.O Box 2551 – 00200 Nairobi, Kenya.
3. What Personal Data We Collect
We may collect and process the following categories of personal data when you use our website or engage with our services:
- Identity data: name, gender, date of birth
- Contact data: email address, phone number, postal address
- Property-related data: preferences (location, type, budget), search history
- Transaction data: offers, viewings, contracts, payment information
- Professional data: job title, employer (if relevant)
- Marketing data: how you want to be contacted, communication preferences
- Technical data: IP address, browser type, device information, cookies
- Other data: any other personal data you provide when you contact us, or register for services.
4. Legal Basis for Processing
Under the Kenya Data Protection Act, 2019, we rely on the following lawful bases to process your data:
- Consent — when you agree to receive our newsletters or marketing information.
- Performance of a contract — to provide you with real estate services, to facilitate property transactions, viewings, etc.
- Legitimate interests — for our business operations (e.g., improving our website, marketing, analytics), provided such interests do not override your rights.
- Legal obligation — to comply with regulatory requirements (e.g., anti-money laundering checks).
These principles are aligned with the obligations under the Data Protection Act.
5. How We Use Your Data
We use the personal data we collect for the following purposes:
- To match you with suitable properties (sale, rent, investment)
- To communicate with you (via phone, email, SMS) about our services, property news, or updates
- To conduct due diligence, verifications, and, if needed, credit checks
- To process transactions, contracts, and payments
- To personalize and improve your experience on our website
- To send you marketing communications (only if we have your consent)
- To analyse our business performance, trends, and client behaviour
- To comply with legal and regulatory obligations
6. Disclosure of Personal Data
We may share your personal data with:
- Our affiliates and business partners (e.g., co-agents, developers)
- Professional advisers (solicitors, valuers, surveyors) involved in transactions
- Service providers (CRM software, IT providers, verification services)
- Regulatory authorities when required by law (e.g., for AML/KYC)
- Third parties in a transaction (e.g., landlords, buyers) as needed to facilitate property deals
We will not sell your personal data. If data is transferred outside Kenya, we ensure that appropriate safeguards are in place in accordance with relevant data protection laws.
7. Data Retention
We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including:
- Completing any transaction (sale, rental, advisory)
- Complying with legal obligations
- Handling any disputes, complaints, or ongoing service obligations
After the retention period, we will securely delete or anonymize your data.
8. Data Security
We take data security seriously and implement a variety of measures to protect your personal data:
- Physical, technical, and organizational controls (e.g., access controls, encryption)
- Regular security risk assessments and audits
- Staff training on data protection
- Incident response plan to deal with data breaches
9. Your Rights Under the Kenya Data Protection Act
Under Kenyan law, you have the following rights as a data subject:
- Right to be informed: We must tell you what data we collect and how we use it.
- Right of access: You can request a copy of your data held by us.
- Right to correction: You can ask us to correct inaccurate or incomplete data.
- Right to erasure (“right to be forgotten”): Under certain conditions, you may request deletion of your personal data.
- Right to restrict processing: You can request that we limit how we use your data.
- Right to data portability: You may ask for your data in a structured, machine-readable format.
- Right to object: You can object to processing in cases such as direct marketing.
- Right to withdraw consent: Where processing is based on consent, you can withdraw it at any time.
To exercise these rights, please contact our DPO using the details above.
10. Cookies and Tracking Technologies
On www.wambugu.co.ke, we use cookies and similar tracking technologies to:
- Improve site functionality and performance
- Understand how users use our website
- Personalize content and property recommendations
- Provide better user experience
We will present a cookie banner / notice on our site to explain how users can manage or opt out of non-essential cookies.
11. Marketing Communications
If you consent to receive marketing (property alerts, newsletters, updates), you can opt out at any time by:
- Unsubscribing via the link in our emails
- Contacting our DPO
- Changing your communication preferences in your account (if applicable)
We only send marketing communications if you have given explicit consent, or where we have a lawful basis (legitimate interest) and you have not objected.
12. Changes to the Privacy Policy
We may update this Privacy Policy from time to time. When we make material changes, we will:
- Post a prominent notice on our website
- Notify affected users via email (if we have your contact)
Your continued use of our services / website after those changes constitutes acceptance of the new policy.
13. Contact & Complaints
If you have any questions, concerns, or complaints about how Wambugu International Limited handles your personal data, you can:
- Contact our Data Protection Officer at info@wambugu.co.ke
