Donexa

1. Who We Are

Donexa ("we", "us") operates the social networking platform at 254gencash.co.ke. We are a data controller for the purposes of Kenya's Data Protection Act, 2019, and process personal data in accordance with that Act and its regulations.

2. What We Collect

We collect information you provide when you register and use Donexa, including:

• account details: name, username, email address, phone number, password (stored hashed), date of birth;
• profile information you choose to add: biography, education, work, skills, interests, relationship status, website, location, avatar and cover photos;
• content you create: posts, comments, messages, stories, groups, business pages;
• technical data: device and browser information, IP address, log data and cookies used for authentication, security and analytics.

3. Children's Data

Donexa implements age-appropriate safeguards and, where legally required, age verification and parental/guardian consent mechanisms for children's personal data. Under Kenya's Data Protection Act, consent of a parent or guardian is required before processing a child's personal data, along with appropriate age-verification mechanisms.

A checkbox stating "I am 18" alone is not sufficient. Donexa applies privacy-by-design, age-appropriate privacy settings and parental controls. If you believe your child has provided personal data to Donexa without your consent, contact us and we will take steps to remove it.

4. Why We Process Data (Legal Basis)

We process personal data where: you have given consent (for example, when you create a profile or follow a business); processing is necessary for the performance of the contract with you (providing the service); processing is necessary for compliance with a legal obligation (for example, Kenya's Prevention of Terrorism Act, the National Cohesion and Integration Act, and the Computer Misuse and Cybercrimes Act); or processing is necessary for legitimate interests that do not override your rights (for example, platform security and moderation).

5. How We Use Data

• to provide, operate and secure the platform;
• to personalise your feed and recommend content;
• to detect, prevent and act against prohibited content — including automated risk screening of posts, comments, profile information, group and business descriptions, supplemented by human review where context matters;
• to respond to user reports and enforce our Terms and Community Standards;
• to comply with legal obligations and lawful requests from competent authorities.

6. Who We Share Data With

We do not sell personal data. We may share data with: service providers who host and operate the platform (on cPanel shared hosting with appropriate safeguards); professional advisers; and competent authorities where we are legally required to do so or where necessary to protect the safety and rights of users (for example, reporting suspected child sexual exploitation or serious threats).

7. Retention

We retain personal data only for as long as necessary for the purposes described in this Policy, for legitimate business purposes, and to satisfy legal, regulatory, tax or accounting requirements. Moderation events and reports are retained as an audit trail and to keep the platform safe. When you delete your account, your personal data is removed or anonymised, except where retention is required by law.

8. Security

We implement appropriate technical and organisational measures to protect personal data, including password hashing, HTTPS in transit, CSRF protection, access controls, and restricted administrative access. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

9. Your Rights

Under Kenya's Data Protection Act you have the right to:

• be informed of the collection and use of your personal data;
• access the personal data we hold about you;
• request correction of inaccurate or incomplete data;
• request deletion of your data;
• restrict or object to processing in certain circumstances;
• data portability;
• not be subject to automated decision-making that significantly affects you without appropriate safeguards — which is why moderation decisions are supplemented by human review;
• lodge a complaint with the Office of the Data Protection Commissioner (ODPC).

To exercise any of these rights, contact us through the platform or at our registered contact details. We will respond within the timeframe required by law.

10. Cookies and Similar Technologies

We use essential cookies and session identifiers to keep you logged in and to protect the platform (for example, CSRF tokens). We do not use third-party advertising cookies.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Continued use of Donexa after changes are published constitutes acceptance of the updated policy.

12. Contact

Questions, requests or complaints regarding your personal data may be sent to our data protection contact at the platform's registered contact details, or to the Office of the Data Protection Commissioner (ODPC), Kenya.