1. Who we are
Delace Technologies Limited (Delace, we) runs delace.co.ke and sells vehicle tracking and telematics equipment, electronics, office equipment and supplies from Nairobi, Kenya. For the personal data described in this policy we are the data controller under the Data Protection Act, 2019 (the Act).
This policy explains what we collect, why, who we share it with, where it is stored, how long we keep it, and your rights. It applies to the Site, our emails, and orders, quotations, receipts and installations we handle. Questions or requests: [email protected] or +254 717 520 648.
It is designed to give the notice required before collection under the Data Protection Act, 2019 and reflects the Data Protection (General), Registration, and Complaints Handling Regulations, 2021. It does not replace any mandatory protection available to you under Kenyan law.
2. Personal data we collect
| Category | Examples | Source |
|---|---|---|
| Account details | Name, email address, password (stored only as a salted hash), optional phone number and company | You, when you sign up |
| Order and contact details | Name, phone, email, delivery address, order notes, items requested, pickup or dispatch choice | You, when you request an order |
| Transaction records | Quotations, receipts and tax invoices, payment method and reference (such as an M-Pesa code), KRA PIN if you give it for invoicing | You and our staff |
| Installation records | Vehicle registration and make, device serial numbers and IMEI, installation location and date, job card notes | You and our technicians |
| Communications | Emails, calls and messages with us, and your email preferences | You |
| Technical data | IP address, browser type, pages requested and times, used for security and rate limiting | Your device, automatically |
We do not ask for sensitive personal data as defined in the Act (such as health, biometric, ethnic or religious data). We do not collect card numbers; future online payments will be handled by licensed payment providers.
3. Why we use it, and our lawful basis
Section 30 of the Act lets us process personal data only on a lawful basis. We rely on:
| Purpose | Lawful basis |
|---|---|
| Creating and securing your account, confirming your email | Performance of a contract with you |
| Handling order requests, contacting you to confirm them, delivery, collection and installation | Performance of a contract, or steps you asked for before one |
| Quotations, receipts, tax invoices (including KRA eTIMS) and accounting records | Legal obligation |
| Warranty claims, returns, complaints and customer support | Performance of a contract and legal obligation |
| Keeping the Site secure, preventing fraud and abuse, rate limiting | Legitimate interests (protecting our customers and systems) |
| Business analytics on orders and sign-ups (aggregated where possible) | Legitimate interests (improving our products and service) |
| Sending offers and product updates | Your consent, which you can withdraw at any time |
We do not make decisions about you based solely on automated processing that produce legal or similarly significant effects.
4. Marketing emails
- We send offers and product updates only if you ticked the box to receive them (the box can be unticked when you sign up).
- Every marketing email has an Unsubscribe link that works in one click, and you can also ask us by email. We stop marketing to you promptly, as section 37 of the Act and its regulations require for commercial use of personal data.
- Unsubscribing does not stop service emails we need to send about your account, orders, quotations or receipts.
- We do not sell or rent your personal data, and we do not share it with others for their own marketing.
7. Transfers outside Kenya
Some of our providers may store or process data outside Kenya, and their networks may route data through other countries. Under sections 48 to 50 of the Act and the Data Protection (General) Regulations, 2021, we make those transfers only where the required safeguards, lawful transfer condition or consent is in place. These may include contractual data-protection commitments, an assessment of the destination and provider, and records of the transfer.
We do not transfer sensitive personal data abroad. You can ask us for details of the safeguards for a particular transfer.
8. How long we keep it
| Data | Kept for |
|---|---|
| Account details | While your account is open, then deleted or anonymised within 90 days of closure (unless needed for the records below) |
| Unconfirmed sign-ups | Confirmation links expire after 24 hours; unconfirmed accounts may be removed after 30 days |
| Orders, quotations, receipts, invoices and payment records | 5 years after the transaction, as tax law requires (Tax Procedures Act, 2015) |
| Installation records | For the warranty period plus 1 year |
| Marketing preferences | Until you unsubscribe, then a suppression record so we don't email you again |
| Security and server logs | Up to 90 days, unless needed to investigate an incident |
When data is no longer needed we delete it or anonymise it so it can no longer identify you.
9. How we protect it
- Data is encrypted in transit (HTTPS/TLS) and stored with providers that encrypt data at rest.
- Passwords are never stored in readable form; we keep only a salted scrypt hash.
- Access to customer data is limited to staff who need it, behind authenticated, admin-only access, and email confirmation links work once and expire.
- We limit request rates and sign-in attempts to protect accounts from automated attacks.
- If a personal data breach is likely to put your rights at risk, we will notify the Data Protection Commissioner within 72 hours of becoming aware of it, and tell you without undue delay where there is a high risk to you, as section 43 of the Act requires.
10. Your rights
Under section 26 and related provisions of the Act you have the right to:
- Be informed about how your data is used (this policy).
- Access the personal data we hold about you.
- Correct data that is inaccurate, out of date or incomplete.
- Delete data that is no longer needed or was processed unlawfully, subject to records we must keep by law.
- Object to processing based on legitimate interests, and to direct marketing at any time.
- Withdraw consent at any time, without affecting earlier processing.
- Data portability: receive your data in a structured, commonly used format, or have it sent to another controller.
- Restrict processing in certain circumstances, for example while we check its accuracy.
- Not be subject to decisions based solely on automated processing (we do not make such decisions).
To exercise a right, email [email protected] from the address on your account or tell us how to verify your identity. There is normally no charge. We will respond within the applicable time limit. For example, the General Regulations set seven days for an access request and fourteen days for an objection or restriction request; if we lawfully decline a request, we will explain why and tell you about your right to complain.
11. Children
The Site is for adults and businesses. Accounts and orders are for people aged 18 or over, and we do not knowingly collect personal data from children. If you believe a child has given us personal data, contact us and we will delete it.
12. Tracking devices and the data they generate
When we sell or install a GPS tracker, dashcam, fuel sensor or driver ID device, we keep the installation records listed above. The location, driving and camera data the device produces afterwards is sent to the tracking platform you choose, not to Delace, unless we have agreed in writing to provide that service.
If you use these devices on vehicles driven by employees or others, you are usually the data controller for that data. You must tell drivers what is collected and why, process it lawfully and securely, and handle their requests under the Act. Our Terms of Service set out how devices must be used.
13. Complaints
If you are unhappy with how we handle your data, please contact us first at [email protected] so we can try to put it right. You also have the right to complain to the Office of the Data Protection Commissioner (ODPC), the regulator in Kenya, through www.odpc.go.ke.
14. Changes to this policy
We review this policy at least once a year and whenever we change how we handle personal data, for example when online payments or analytics launch. The version and effective date are shown at the top. If a change is significant we will notify account holders by email before it applies.
15. Contact us
- Delace Technologies Limited (data controller), Nairobi, Kenya
- Email: [email protected], with “Privacy” in the subject line
- Phone: +254 717 520 648 (Monday–Saturday, 8:00 AM–6:00 PM (EAT))