Privacy Policy

1. Who we are

Genmars Tech is a software studio registered in Kenya under the Registration of Business Names Act (Cap. 499, Section 14), registration number BN-93S95J2J, owned by Edwin Muchemi Wamuyu and operating under the trading name UrbanTrends.dev. Our registered address is Floor 5, Room 354, GTC Towers, Chiromo Road, Nairobi Westlands District, Westlands, P.O Box 00100, 00800 Westlands.

We are the data controller for personal information collected through our website (urbantrends.dev) and our products: RentFlow, PortfolioU, TrendyyLeads, AcademyOS, and Developer Tools.

2. What data we collect

We collect the following categories of personal data:

• Account data — name, email address, organisation name, and password (hashed) when you create an account.
• Contact data — email address and any message content if you contact us via forms.
• Payment data — M-Pesa phone numbers and transaction references processed through Safaricom Daraja. We do not store full card numbers; card payments (if any) are handled by PCI-DSS compliant processors.
• Usage data — pages visited, features used, timestamps, and IP address collected via our analytics infrastructure.
• Device data — browser type, operating system, and screen resolution collected automatically.
• KYC data — where required by Kenyan law or a product's compliance requirements, national ID numbers or business registration numbers.

3. How we use your data

We use your personal data to:

• Provide, operate, and maintain our products and services.
• Process payments and reconcile transactions.
• Send you transactional emails (account creation, password reset, payment receipts).
• Respond to support enquiries.
• Improve our products through aggregated, anonymised analytics.
• Comply with applicable Kenyan law, including the Kenya Revenue Authority's eTIMS requirements where relevant.

We do not sell your personal data to third parties. We do not use your data for automated decision-making that produces legal or similarly significant effects without human review.

4. Legal basis for processing

We process your data under the following legal bases (consistent with Kenya's Data Protection Act, 2019):

• Contract performance — to deliver the services you signed up for.
• Legitimate interests — for security monitoring, fraud prevention, and product improvement, where our interests do not override your rights.
• Legal obligation — where Kenyan law requires us to retain or report data.
• Consent — for optional marketing emails, which you can withdraw at any time.

5. Data sharing and third parties

We share data only with:

• Safaricom (Daraja API) — to initiate and verify M-Pesa payments.
• KRA eTIMS — to submit tax invoice data where legally required.
• Infrastructure providers (cloud hosting, database, email delivery) — under data processing agreements that require them to protect your data.
• Law enforcement — where required by a valid Kenyan court order or legal process.

6. Data retention

We retain account data for the life of your account plus 7 years after closure (to satisfy Kenyan tax retention requirements). Payment transaction records are retained for 7 years. Usage analytics are retained for 2 years. You may request earlier deletion subject to our legal retention obligations.

7. Your rights

Under Kenya's Data Protection Act, 2019, you have the right to:

• Access the personal data we hold about you.
• Correct inaccurate or incomplete data.
• Request deletion of your data (subject to legal retention obligations).
• Object to processing based on legitimate interests.
• Data portability — receive your data in a structured, machine-readable format.
• Withdraw consent for marketing at any time.

To exercise these rights, email us at privacy@urbantrends.dev. We will respond within 30 days.

8. Cookies

We use strictly necessary cookies for session management and authentication. We use analytics cookies (first-party only) to understand how our site is used. We do not use third-party advertising cookies. You can disable cookies in your browser settings; this may affect site functionality.

9. Data security

We implement industry-standard technical and organisational measures to protect your data, including TLS encryption in transit, encryption at rest, access controls, and regular security reviews. See our Security Policy for more detail.

10. International transfers

Our infrastructure may be hosted outside Kenya. Where data is transferred internationally, we ensure adequate protection through contractual clauses or equivalent safeguards consistent with Kenya's Data Protection Act.

11. Children

Our products are not directed at children under 18. We do not knowingly collect personal data from minors. If you believe a minor has provided us data, contact us immediately.

12. Changes to this policy

We may update this policy. Material changes will be communicated by email or a prominent notice on our website at least 14 days before taking effect. Continued use of our services after the effective date constitutes acceptance.

13. Contact

For privacy-related queries, contact us at:
Genmars Tech
Floor 5, Room 354, GTC Towers, Chiromo Road
Westlands, Nairobi, Kenya · P.O Box 00100, 00800
Email: privacy@urbantrends.dev