Privacy Policy - Dukamneti Sports

Effective date: 20th September, 2026

1. Data Controller

The data controller responsible for your personal data is:

DUKAMNETI ONLINE SHOPS
Business Name: BN-RPC2MXMX
Republic of Kenya
Email: support@dukamneti.co.ke

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our services and the choices you have associated with that data. Unless otherwise defined in this Privacy Policy, terms used have the same meanings as in our Terms and Conditions.

2. Data We Collect

We collect the following categories of personal data:

Account Data

When you register, we collect:

  • Email address
  • First name and last name
  • Username

Lawful basis: Performance of a contract — necessary to create and manage your account and provide subscription access.

Payment Data

When you subscribe, payment transactions are processed by our payment providers (PayPal, M-Pesa/Safaricom). We do not store your full card details. We retain records of transaction IDs, subscription status, and payment amounts.

Manual M-Pesa code verification and Subscription Credit. If you submit an M-Pesa transaction code, we ask Safaricom for the details of that transaction and store the response in full. It can include the amount, the date and time, the transaction status and type, the receiving business name, and the paying party's name and phone number (or, for bank payments, the bank's name). When you submit a code while choosing a subscription plan, we also keep your IP address, browser details and advertising cookie identifiers only until that payment has been processed, so we can report your subscription to Meta for advertising measurement; they are then deleted. We also store your Subscription Credit balance and a ledger of credits and purchases. This information is visible only to authorised administrators and is never shown to other users.

Code-entry attempts. We record each M-Pesa code you enter, when you entered it and the result, so we can prevent misuse such as guessing codes. These records are kept with your payment records.

Lawful basis: Performance of a contract; legal obligation (financial record-keeping); legitimate interests (fraud prevention and resolving payment disputes).

Terms Acceptance Records

Each time you accept our Terms and Conditions and Privacy Policy (at sign-up, when a new version is published, or when you top up Subscription Credit) we record which version you accepted, the date and time, your IP address (including any forwarding chain), and your browser's user agent. We also keep a permanent copy of every version of these documents.

Lawful basis: Performance of a contract; legal obligation; legitimate interests (evidencing the terms that applied to you and defending legal claims).

Usage Data

We automatically collect information about how you use our website, including:

  • IP address
  • Browser type and version
  • Pages visited and time spent
  • Device type and unique device identifiers
  • Referring URLs

Lawful basis: Legitimate interests — to maintain, improve, and secure the website.

Push Notification Subscriptions

If you opt in to browser push notifications, we store your browser's push subscription token (endpoint URL and encryption keys) to deliver match alerts and tip updates. No personally identifiable information is contained in the token itself.

Lawful basis: Consent — you explicitly enable notifications via the opt-in prompt. You can withdraw consent at any time by disabling notifications in your browser settings.

Cookies and Tracking Data

We use the following types of cookies:

  • Strictly necessary cookies — Django session and CSRF tokens required for the website to function. No consent required.
  • Analytics cookies — Google Analytics 4 (GA4) to understand how visitors use the website. Data is pseudonymised.
  • Social/marketing cookies — Facebook SDK, used for social login and audience engagement.

You can configure your browser to refuse all cookies. Disabling strictly necessary cookies will prevent you from logging in or using subscription features.

Lawful basis: Strictly necessary cookies — legitimate interests. Analytics and marketing cookies — consent (where required by applicable law).

3. How We Use Your Data

PurposeData usedLawful basis
Provide and maintain the websiteAccount, UsageContract performance
Process subscription paymentsAccount, PaymentContract performance
Send match alerts and tip updatesPush subscription, EmailConsent
Customer supportAccount, correspondenceContract performance / Legitimate interests
Improve our servicesUsage, AnalyticsLegitimate interests
Fraud prevention and securityUsage, AccountLegitimate interests / Legal obligation
Verify manual M-Pesa payments and manage Subscription CreditPayment, AccountContract performance / Legitimate interests
Record your acceptance of our termsTerms acceptance recordsContract performance / Legal obligation / Legitimate interests
Comply with legal obligationsAccount, PaymentLegal obligation

4. Data Retention

  • Account data: Retained for the duration of your account. Deleted within 30 days of a verified deletion request, subject to legal obligations.
  • Payment records: Retained for 7 years to comply with financial and tax record-keeping obligations. This includes the M-Pesa verification responses and Subscription Credit ledger described above.
  • Terms acceptance records: Retained for 7 years after the acceptance, or longer if needed to establish, exercise or defend a legal claim, even if you delete your account.
  • Usage / analytics data: Retained for up to 26 months in Google Analytics (pseudonymised). Server logs retained for up to 90 days.
  • Push notification tokens: Retained until you unsubscribe or the token expires. Invalid tokens are deleted automatically.

5. Third-Party Service Providers

We share data with the following processors, who are contractually bound to use it only for the purposes we specify:

  • Google LLC — Google Analytics 4 (usage analytics), Google Sign-In. Privacy Policy
  • Meta Platforms, Inc. — Facebook SDK (social login, audience engagement). Privacy Policy
  • PayPal Holdings, Inc. — Payment processing for subscriptions. Privacy Policy
  • Safaricom PLC (M-Pesa) — Mobile payment processing. Privacy Policy
  • Mailgun Technologies, Inc. — Transactional email delivery. Privacy Policy
  • Amazon Web Services, Inc. (AWS) — Cloud hosting, file storage (S3), and CDN (CloudFront). Data may be stored in the EU (Frankfurt region). Privacy Policy
  • Google Firebase / FCM — Push notification delivery for Android and web browsers. Privacy Policy
  • Apple Inc. — Push notification delivery for Safari/iOS users. Privacy Policy

6. International Data Transfers

Your data may be transferred to and processed in countries outside your own, including the United States, where data protection laws may differ from those in your country. Where we transfer data from the European Economic Area (EEA) or the United Kingdom to third countries, we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses (SCCs) or the UK International Data Transfer Agreement (IDTA), or we transfer to countries with an adequacy decision.

AWS stores data in the EU (eu-central-1, Frankfurt) where possible. For further information on the safeguards in place, contact us at support@dukamneti.co.ke.

7. Disclosure of Data

We may disclose your Personal Data where required to:

  • Comply with a legal obligation or court order
  • Protect and defend the rights or property of Dukamneti Sports
  • Prevent or investigate fraud or wrongdoing
  • Protect the personal safety of users or the public
  • Protect against legal liability

We do not sell your personal data to third parties.

8. Security of Data

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction, including HTTPS encryption, access controls, and regular security reviews. However, no method of internet transmission or electronic storage is 100% secure.

9. Your Rights

Depending on your jurisdiction, you have the following rights regarding your personal data. To exercise any of them, email support@dukamneti.co.ke or use our contact form. We will respond within 30 days.

  • Right of access — Request a copy of the personal data we hold about you.
  • Right to rectification — Request correction of inaccurate or incomplete data.
  • Right to erasure — Request deletion of your personal data where there is no legitimate reason for us to continue processing it.
  • Right to restriction — Request that we restrict processing of your data in certain circumstances.
  • Right to data portability — Request a machine-readable copy of the personal data you provided to us.
  • Right to object — Object to processing based on legitimate interests or for direct marketing purposes.
  • Right to withdraw consent — Where processing is based on consent (e.g. push notifications), you may withdraw it at any time without affecting the lawfulness of prior processing.
  • Right to lodge a complaint — You have the right to complain to a data protection supervisory authority in your country of residence. EU users may contact their national DPA (list at edpb.europa.eu). UK users may contact the ICO at ico.org.uk.

10. Links To Other Sites

Our website may contain links to third-party sites. We have no control over and assume no responsibility for the content or privacy practices of those sites. We encourage you to review the privacy policy of every site you visit.

11. Children's Privacy

Dukamneti Sports does not address anyone under the age of 18. We do not knowingly collect personal data from anyone under 18. If you are a parent or guardian and believe your child has provided us with personal data, please contact us and we will delete it promptly.

12. Changes To This Privacy Policy

We may update this Privacy Policy from time to time. Each published update is a new version and we keep a permanent history of every version. We will notify you of material changes by email and/or a prominent notice on our website, and will update the effective date at the top of this page. When a new version is published, you must review and accept it before you can continue to use the website or your account; if you decline, you can sign out. See section 10 of our Terms and Conditions.