Privacy Policy

1. Who is responsible for your data

Pinned Apex Limited is the data controller for this website. It decides what personal data is collected here and why, and it is registered with the Office of the Data Protection Commissioner as a data controller. The service is operated day to day by Giga Cypher Systems Ltd in association with Pinned Apex Limited, as the Terms describe.

Registered office: Gatakaini House No. 1 (Pop Man House), 6th floor / roof top, Nyakatch Lane, Nairobi CBD. Postal address: P.O. Box 966–00200, Nairobi. Telephone: 0141 677 677 or 0141 678 678. Email: support@pinnedflow.app.

For anything about your data, write to support@pinnedflow.app, or to the registered office above.

Pinned Apex Limited is registered with the Office of the Data Protection Commissioner of Kenya as a data controller, registration number 444-6649-741E.

Our data protection contact is Purity Akoth. Write to support@pinnedflow.app or call 0141 678 678, and address anything in writing to the registered office above.

2. The short version

• If you send a parcel, we keep your account details, the parcel details and a record of the payment.
• If somebody sent you a parcel, we hold your name, your phone number and the address you give us — even though you never signed up with us.
• We use Google Analytics to understand how the site is used.
• Money is handled by Safaricom through M-Pesa. We never see your M-Pesa PIN.
• We do not sell personal data. [CONFIRM: confirm this as a standing commitment before publication.]

3. What this policy covers

It covers pinnedflow.app, including the pages you reach from a link we text you — the choice page at /p/<code> and the tracking page at /track/<code>.

It does not cover the Pinned Flow Android app, which has its own policy at /privacy. That policy is the one Google Play relies on, and it stays as it is.

It does not cover other companies' websites or apps that we link to.

4. What we collect

If you have an account: your name, phone number and, for business accounts, an email address and either a password or a Google sign-in. Business accounts also hold branch names and addresses, staff names and phone numbers, and the number used for billing.

About a parcel: where it starts and where it is going, the Pod or address at each end, the size, the speed, any special handling, a declared value if you give one, and the receiver's name, phone number and any note you add for them.

If somebody sent you a parcel: your name and phone number as the sender gave them, and the address or Pod you choose on your link. See section 9.

Payments: the M-Pesa number used and the reference Safaricom returns. We never receive or store your M-Pesa PIN.

Location: when you press a button that uses your location — to find Pods near you, or to set a pickup point — your browser asks you first. If you say no, you can type the place instead.

If you message our assistant: what you type is sent to OpenAI so a reply can be produced. Do not put anything in that box you would not want processed outside Pinned.

Device and usage: your IP address, browser and device type, the pages you open and how you got to them.

Messages we send: a record that an SMS or WhatsApp message was sent to a number and whether it was delivered.

5. Why we use it, and our lawful basis

• To carry a parcel and tell everyone involved where it is — performance of a contract, and for receivers, our legitimate interest in completing the delivery the sender asked for.
• To take payment and keep a record of it — performance of a contract and a legal obligation to keep accounting records.
• To send the SMS or WhatsApp message that gives a receiver their link and, where one applies, their handover code — legitimate interest in completing the delivery.
• To answer questions and support accounts — performance of a contract and legitimate interest.
• To keep the service safe, investigate misuse and prevent fraud — legitimate interest.
• To understand how the site is used, through analytics — consent. See section 6.
• To show you Pinned advertising on other platforms, if and when we do it — consent. See section 7.
• To meet legal and regulatory duties — legal obligation.

6. Cookies and similar technologies

Some cookies are necessary for the site to work at all. Others are not, and those should only run with your agreement.

• Essential: keeping you signed in, keeping your place in a form, and protecting forms from abuse. The site cannot work without these.
• Analytics: Google Analytics, loaded through Google Tag Manager, which tells us which pages are used and how people move through them. The tag manager itself loads on every page, but it is told what it may do: until you agree, it stores nothing on your device and records the visit to Google without an identifier in it, so we can count visits without knowing whose they were. Google Firebase analytics is treated the same way. [CONFIRM: is Firebase analytics switched on in production?]
• Advertising: only if you agree to it. These let Meta (Facebook and Instagram) and TikTok know that a browser visited us, so that Pinned adverts can reach you on those platforms later. If you do not agree, no advertising pixel loads and neither platform is told anything about your visit. A Meta domain verification tag is present either way, which only proves we own the domain — it does not track anyone.
• You are asked on your first visit, and analytics and advertising are two separate choices — you can agree to one without the other, because agreeing to be counted is not agreeing to be followed. Until you choose, only the essential cookies run. You can change your mind at any time using Cookie choices in the footer of any page, and we ask again after six months.
• Your choice is kept in a cookie on your own device. We do not keep a record of it on our side, because for the many people here who never sign in there would be nothing to attach it to except an IP address — which would mean collecting more data about you, not less.

7. Advertising and retargeting

Plainly: if we switch on advertising tools, a visit to this site can be used to show you Pinned adverts later on other platforms, such as Facebook, Instagram or TikTok. Those platforms are told that a browser visited us, usually through an identifier made from an email address or phone number that has been scrambled first, so the platform cannot read the original.

The platforms are Meta, covering Facebook and Instagram, and TikTok. Each is loaded only if you have agreed to advertising cookies, which is a choice of its own on the banner and not part of agreeing to analytics. Refuse it, or simply not answer, and neither one loads.

• You can stop it at the platform: Meta through Accounts Centre, ad preferences; TikTok through Settings, ads; Google through My Ad Centre.
• You can also refuse or clear cookies in your browser, or use your browser's do-not-track or tracking-protection settings.
• Refusing advertising cookies does not stop you sending or receiving a parcel. Nothing about the delivery depends on it.

8. Who else receives your data

We share only what each one needs to do its job.

• Safaricom (M-Pesa): the paying phone number and the amount, to take payment and confirm it.
• Google: analytics and tag management; maps and route distances; sign-in if you use a Google account; and Firebase where it is enabled.
• Meta: the receiver's phone number and the message text, where a notification is sent over WhatsApp.
• Africa's Talking: the phone number and the message text, where a notification is sent by SMS.
• T.LY: the link we shorten before texting it. T.LY therefore sees the link address and when it is opened.
• OpenAI: the text of a question you type into our assistant, to produce a reply.
• Bestwond: the commands that open a Pod compartment, so a locker can be opened for your parcel.
• Riders and host staff: the name, phone number and address needed to collect or deliver your parcel, and nothing else.
• Professional advisers, and the authorities where the law requires it.
• Meta and TikTok, for advertising, and only if you have agreed to advertising cookies: that a browser visited particular pages on this site, and — where it applies — an identifier made from a phone number or email address, scrambled first so the platform cannot read the original. If you have not agreed, they receive nothing.

9. If you never signed up with us

Most people who open a Pinned link never created an account. This section is for you.

Your name and phone number reached us because the person sending you a parcel typed them in. We did not get them from anywhere else, and we do not buy contact lists.

We use them for one thing: getting that parcel to you. That means texting you the link, showing you where the parcel is, taking payment if the sender arranged for you to pay, and giving the rider what they need to reach you.

If you choose an address on your link, we keep it so the rider can find you. If you tell us to collect at a Pod instead, we keep that choice.

Your link is private. Anyone holding it can see that parcel's status, so treat it like a key and do not post it publicly.

You can object to us holding your details, or ask us to delete them, using section 12. Be aware of the consequence: if you object before the parcel reaches you, we may not be able to deliver it, and we will tell the sender we could not complete it.

We do not use a receiver's phone number to market to them. [CONFIRM: confirm this as a standing commitment — it is a decision, not a technical fact.]

10. Sending data outside Kenya

Some of the companies in section 8 process data outside Kenya — Google, Meta, OpenAI and T.LY among them. That means your data may be handled in other countries.

The Data Protection Act, 2019 allows a transfer out of Kenya only on specific grounds, including that the transfer is necessary to perform a contract with you, or that appropriate safeguards are in place.

[CONFIRM: which ground is relied on for each of these transfers, and what safeguards are in place — for example standard contractual clauses in each vendor's terms? This needs an advocate's view before publication.]

11. How long we keep it

We keep data only as long as there is a reason to.

• Account details, while the account is open, and then [CONFIRM: retention period after an account is closed].
• Parcel and delivery records: [CONFIRM: retention period].
• Payment records: [CONFIRM: retention period, bearing in mind the tax and accounting rules that apply].
• Message delivery records: [CONFIRM: retention period].
• Analytics data: [CONFIRM: the retention setting configured in Google Analytics].
• Assistant conversations: [CONFIRM: how long these are kept by us, and what OpenAI retains under its terms].

12. Your rights

Under the Data Protection Act, 2019 you have the right to be told what we hold about you and to get a copy; to have it corrected if it is wrong; to have it deleted; to object to how we use it; to ask us to restrict its use while a complaint is looked at; and to receive it in a portable form.

To use any of these, write to support@pinnedflow.app with enough detail for us to find your records — for example the phone number you used or a parcel reference. We may ask you to confirm who you are before we act, so that nobody else can obtain your data by asking.

[CONFIRM: the period within which Pinned undertakes to respond.]

13. Consent, and taking it back

Where we rely on your consent — analytics and, in future, advertising — you can withdraw it at any time. Withdrawing it does not undo anything already done while the consent was in place, and it does not affect anything we do on another basis, such as carrying a parcel you have paid for.

To change your mind about analytics, use Cookie choices in the footer of any page and choose again. If a new kind of cookie is ever introduced — advertising, for example — we ask everybody again rather than treating an old agreement as covering it.

14. Children

This service is not meant for children. You must be 18 or older to open an account. [CONFIRM: minimum age — the Terms carry the same question.]

We do not knowingly collect data about children. A receiver's details are given to us by the sender, so it is possible for a parcel to be addressed to a young person without our knowing. [CONFIRM: what should happen when we learn a receiver is a child?]

If you believe a child's data is held by us, write to support@pinnedflow.app and we will remove it.

15. If you want to complain

Please tell us first, at support@pinnedflow.app, so we can put it right.

You also have the right to complain to the Office of the Data Protection Commissioner (ODPC), the authority responsible for data protection in Kenya. [CONFIRM: the current ODPC postal address, telephone and complaints link to publish here.]

16. Changes to this policy

Effective date: [CONFIRM: the date this policy takes effect once it is approved].

When we change this policy we will update this page and change the effective date. Where a change matters to you, we will say so on the site and, where it is appropriate, tell account holders directly.