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Privacy Policy

Last updated: May 13, 2026

Territory: clipsavv operates from Kenya and this Policy is written for users whose personal data we process in connection with our Kenyan operations and the Data Protection Act, No. 24 of 2019 (the “Act”) and subsidiary legislation, as interpreted by the Office of the Data Protection Commissioner (ODPC).

This Privacy Policy describes how clipsavv (“we”, “us”, or “our”) collects, uses, discloses, and protects personal data when you use our websites, applications, and related services (collectively, the “Services”).

This document is provided for informational and draft purposes only and does not constitute legal advice. You should have Kenyan-qualified counsel review it before publication.

1. Who we are

Depending on how you use the Services, we may act as a data controller (we decide why and how personal data is processed) or, in limited cases, as a data processor on behalf of another party (for example, a brand client). When we are the controller, we are responsible for this Policy and for meeting our obligations under the Act.

You can contact us using the details in Section 14 below.

2. Personal data we may collect

We may collect:

  • Identity and account data — such as name, email address, phone number, and authentication details when you register or sign in.
  • Profile and activity data — such as social handles, clip submissions, campaign participation, payouts-related information, and how you use the Services.
  • Technical data — such as device type, browser, IP address, approximate location derived from IP, and logs.
  • Communications — messages or feedback you send to us.

We aim to collect only what is adequate, relevant, and limited to what is necessary for the purposes set out in this Policy (data minimisation).

3. Lawful bases and purposes (Kenya)

Under the Act, we will process personal data only where we have a lawful basis, which may include:

  • Consent — where we ask for it (for example, optional marketing or certain cookies where required).
  • Performance of a contract — to provide the Services you request, including payouts and account administration.
  • Legal obligation — to comply with Kenyan law, court orders, or regulatory requests where applicable.
  • Legitimate interests — for example, securing our systems, preventing fraud or abuse, and improving the Services, where those interests are not overridden by your rights.

We use personal data to:

  • Operate, maintain, and improve the Services.
  • Authenticate users and protect the security and integrity of the platform.
  • Communicate with you about the Services (including support, notices, and where permitted, marketing).
  • Facilitate campaigns, submissions, and payments (including M-Pesa or other payment partners, where used).
  • Comply with law and enforce our agreements.
  • Analyse usage in aggregated or de-identified form where appropriate.

Where we rely on consent, you may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing before withdrawal, and may limit certain features.

4. How we share personal data

We may share personal data with:

  • Service providers (processors) who assist us with hosting, analytics, payments, communications, identity, or similar functions, under written contracts that require them to protect personal data and process it only on our instructions, where the Act applies.
  • Professional advisers where legally required or reasonably necessary.
  • Public authorities when required by Kenyan law or a lawful request, or to protect life, safety, or legal rights.
  • Business transfers — in connection with a merger, acquisition, or asset transfer, subject to applicable requirements under the Act.

We do not sell your personal data. If we ever use personal data in ways that could be characterised as a “sale” under future Kenyan guidance, we will update this Policy and obtain any consent or opt-out mechanism required.

5. International transfers

We are based in Kenya. Personal data may be processed in Kenya and, where we use services hosted outside Kenya, transferred subject to Chapter 3 of the Act and any regulations issued thereunder — for example, where the destination ensures an adequate level of protection, or where appropriate safeguards (such as approved mechanisms or contractual clauses) are in place, or where a lawful exception applies.

We will take steps to ensure that any cross-border transfer remains protected in line with the Act.

6. Retention

We retain personal data only as long as necessary for the purposes described in this Policy, including to satisfy legal, accounting, or reporting requirements under Kenyan law, resolve disputes, and enforce agreements. Retention periods may vary by data category.

7. Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or destruction, having regard to the nature of the processing and the risks involved. No online service is completely secure; please use strong passwords and protect your credentials.

8. Your rights under the Act

Subject to the Act and any exceptions, you may have the right to:

  • Be informed about processing (this Policy and any supplementary notices).
  • Access personal data we hold about you.
  • Rectify inaccurate or incomplete personal data.
  • Erase personal data in certain circumstances.
  • Restrict processing in certain circumstances.
  • Object to processing based on legitimate interests, where applicable.
  • Data portability where processing is automated and based on consent or contract, where the Act provides for this.
  • Withdraw consent where processing is based on consent.
  • Not be subject to solely automated decisions with legal or similarly significant effects, where such rights apply under the Act.

Exercising rights: Contact us at the details in Section 14. We may need to verify your identity. We will respond within timelines permitted or required by the Act.

Complaints: If you are not satisfied with our response, you may lodge a complaint with the Office of the Data Protection Commissioner (ODPC) in Kenya. Information on the ODPC is available at the official government portal (search “ODPC Kenya” for current contact details and forms).

9. Children

The Services are not directed at children below the age at which they can validly consent to data processing under Kenyan law (often 18 for many contexts; counsel should confirm for your product). We do not knowingly collect personal data from children without appropriate parental or guardian authority where required. If you believe we have collected such data, contact us and we will take appropriate steps.

10. Cookies and similar technologies

We may use cookies, local storage, and similar technologies for essential operation, preferences, analytics, or security. Where the Act or ODPC guidance requires consent for non-essential cookies or similar tools, we will obtain it before use. You can control some technologies via your browser or device settings.

11. Data Protection Impact Assessment and registration

Where we undertake processing that is likely to result in high risk to data subjects, we will comply with applicable requirements under the Act (for example, data protection impact assessments where required).

Where we are required to register or notify the ODPC as a data controller or processor, we will comply with applicable Kenyan thresholds and procedures from time to time in force.

12. Changes to this Policy

We may update this Policy to reflect changes in law, our practices, or the Services. We will post the revised Policy, update the “Last updated” date, and provide further notice where the Act requires (for example, for material changes). Continued use of the Services where permitted may constitute acknowledgement of the update; where consent is required for new processing, we will obtain it separately.

13. Contact (data protection)

For privacy requests, questions about this Policy, or to exercise your rights under the Act, contact us at support@clipsav.com (you may also publish a Kenyan postal address alongside this contact).

Please include enough detail for us to identify your account and the nature of your request.

This template is for internal and counsel review. It is not a substitute for advice under Kenyan law.