Legal & Privacy

Privacy Policy

We believe privacy is a right, not an afterthought. This policy explains clearly what we collect, why we collect it, and how you stay in control.

Effective: 1 May 2025 Kenya Data Protection Act 2019 GDPR Aligned

Plain language summary: Elegant Haven collects only what is necessary to run our platform. We do not sell your data. We do not show you ads. You can request deletion of your data at any time. Full details are below.

Section 01
Who We Are

Elegant Haven KE ("Elegant Haven", "we", "us", "our") is a property discovery and booking platform operating at eleganthavenke.com and all associated mobile applications and services. We connect guests with property hosts and sellers across Kenya and beyond.

We act as the data controller for all personal information collected through our platform. This Privacy Policy applies to all visitors, registered users, hosts, guests, and property enquirers who interact with our services.

We process personal data in accordance with the Kenya Data Protection Act 2019, the EU General Data Protection Regulation (GDPR) where applicable to EU-resident users, and all other applicable data protection legislation.

Section 02
Information We Collect

We collect information you provide directly and data generated automatically when you use our platform:

CategoryExamplesWhen Collected
IdentityFull name, profile photoAccount registration, host listing
ContactEmail address, phone number, physical addressRegistration, booking, enquiry forms
Booking dataCheck-in/out dates, unit selected, guest countReservation flow
Payment referenceM-Pesa transaction reference, amountPayment confirmation — we never store card details
Property dataListing details, photos, videos, ownership documentsHost or seller listing submission
ReviewsWritten review text, star ratingsPost-stay review submission
Device & usageIP address, browser type, pages visited, session durationAutomatically on all page visits
Approximate locationCity and country inferred from IP address — not precise GPSAutomatically — used for proximity listing sorting
CommunicationsMessages sent to us via email or contact formsWhen you contact us
OTP verificationEmail address used in verification flowDuring host listing registration
Section 03
How We Use Your Information

We use your personal data only for the purposes below. We never use it in ways incompatible with these purposes.

To provide our services — processing bookings, reservations, and property sale enquiries, and facilitating M-Pesa payment instructions between guests and hosts.
To verify listings — reviewing ownership documents submitted by hosts and sellers to confirm legitimacy before approving listings on the platform.
To personalise your experience — sorting listings by your approximate location, surfacing relevant properties, and remembering your session preferences.
To send transactional communications — booking confirmations, OTP codes, payment instructions, enquiry responses, and important account notifications.
To send marketing emails (only with your consent) — new listings, seasonal offers, and platform updates. You may unsubscribe at any time via the link in any email or by contacting us.
To improve the platform — analysing aggregated, anonymised usage data to understand how our platform is used, identify bugs, and improve features.
To comply with legal obligations — retaining records as required by Kenyan law, responding to lawful authority requests, and preventing fraud and misuse.
Section 04
Legal Basis for Processing

Under the Kenya Data Protection Act 2019 and the GDPR, we are required to have a lawful basis for processing your personal data. We rely on the following grounds:

Legal BasisWhen We Apply It
Contract performanceProcessing your booking, reservation, or listing — necessary to fulfil the agreement between you and Elegant Haven.
Legitimate interestsPlatform analytics, fraud prevention, security monitoring, and improving user experience — where our interests do not override your fundamental rights.
Legal obligationRetaining financial and booking records as required by Kenyan law; responding to lawful requests from public authorities.
Your consentSending optional marketing and promotional communications. You may withdraw consent at any time without affecting lawfulness of prior processing.
Section 05
Data Sharing & Third Parties

We do not sell your personal data. We do not share your information with advertisers. We do not allow third parties to target you with advertisements through our platform.

We may share your data only in the limited circumstances below:

With hosts and sellers — when you make a booking or enquiry, we share your name, phone number, and email with the relevant property host or seller to facilitate the transaction.
With service providers — trusted third-party providers who help us operate the platform (e.g. email delivery, server hosting, analytics). These providers process data only on our instructions and are bound by confidentiality obligations.
With payment processors — M-Pesa payment is handled directly between you and Safaricom. We receive only a transaction reference and confirmation; we do not store financial credentials.
For legal compliance — we may disclose data to law enforcement or regulatory authorities if required to do so by applicable law or a valid court order.
In a business transfer — if Elegant Haven is involved in a merger, acquisition, or sale of assets, your data may be transferred as part of that transaction. You will be notified in advance.
Section 06
Data Retention

We retain your personal data only for as long as necessary for the purposes described in this policy, or as required by law.

Data TypeRetention Period
Account and profile dataFor the life of your account, plus 2 years after account closure
Booking and reservation records7 years (for financial and legal compliance)
Property listing data and documentsDuration of listing plus 3 years after removal
ReviewsIndefinitely, as they form part of our public platform record
Communications (emails, enquiries)2 years from last interaction
Server and access logs90 days, unless required longer for security investigations
Marketing consent recordsUntil consent is withdrawn, then archived for 3 years

When data is no longer required, it is securely deleted or anonymised so that it can no longer be linked to you.

Section 07
Your Rights

Under the Kenya Data Protection Act 2019, you have the following rights regarding your personal data. To exercise any of these rights, contact us at reservations@eleganthavenke.com. We will respond within 30 days.

Right to Access

Request a copy of all personal data we hold about you, free of charge.

Right to Rectification

Request correction of inaccurate or incomplete personal data we hold.

Right to Erasure

Request deletion of your data where there is no compelling reason to continue processing it.

Right to Object

Object to processing based on legitimate interests, including direct marketing.

Right to Restrict

Request that we restrict processing of your data while a complaint is being investigated.

Right to Portability

Receive your data in a structured, machine-readable format to transfer to another provider.

Withdraw Consent

Withdraw consent for marketing or optional processing at any time without penalty.

Right to Complain

Lodge a complaint with the Office of the Data Protection Commissioner of Kenya (ODPC).

Section 08
Security

We implement appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These include:

Encrypted data transmission — all data transmitted between your browser and our servers uses TLS/HTTPS encryption.
Access controls — personal data is accessible only to staff who need it to perform their role, governed by role-based access permissions.
OTP email verification — listing hosts must verify their email address using a one-time code before a listing is submitted, reducing the risk of fraudulent submissions.
No financial credential storage — we do not store M-Pesa PINs, card numbers, or any payment credentials. Payment is handled entirely by Safaricom's M-Pesa infrastructure.

Despite our measures, no internet transmission is completely secure. If you believe your data has been compromised, please contact us immediately at reservations@eleganthavenke.com.

Section 09
Children's Privacy

Our platform is intended for users aged 18 years and over. We do not knowingly collect personal data from children under the age of 18. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately at reservations@eleganthavenke.com and we will delete the information promptly.

Section 10
Policy Updates

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. When we make material changes, we will notify you by email (if you have an account) and by displaying a prominent notice on our website for at least 30 days before the changes take effect.

The date at the top of this policy indicates when it was last revised. Continued use of our platform after the effective date constitutes your acceptance of the updated policy.

We encourage you to review this policy periodically. All previous versions are available on request.

Section 11
Contact Us

If you have any questions about this Privacy Policy, wish to exercise your rights, or want to raise a concern, please reach out to us:

Elegant Haven Privacy Team

We aim to respond to all privacy requests within 30 days. For urgent matters please include "URGENT" in your subject line.

You also have the right to lodge a complaint with the Office of the Data Protection Commissioner of Kenya (ODPC) at www.odpc.go.ke.