Privacy Policy

Francton Limited, operating as Garisea (“Garisea”, “we”, “us”), runs Garisea, a vehicle marketplace serving Kenya. We connect buyers with dealers and with licensed finance, insurance and other automotive businesses.

This Privacy Policy explains what personal information we collect when you use garisea.com or the Garisea app for iOS and Android as a buyer or visitor, how we use it, who we share it with, and your rights. Dealers and partners using dealer.garisea.com, partner.garisea.com or the dealer side of the app have their own privacy notices.

We wrote this Policy to meet the Kenya Data Protection Act, 2019 (“the Act”). It also follows the EU General Data Protection Regulation (GDPR) where that law applies.

Francton Limited, operating as Garisea, is the data controller for the personal information described in this Policy.

When you send an enquiry to a dealer, lender, insurer or other business on Garisea, that business receives your details and becomes an independent data controller for them. Its own privacy policy then applies to what it does with them, for example when it calls you, emails you from its own account, or you visit its premises.

Our data protection contact is [email protected].

We collect information you give us, information we collect automatically when you use Garisea, and information we receive from others.

3.1 Information you give us

• Account — your name, email address, phone number and password. We store the password only as a salted bcrypt hash, so we never see it.
• Profile — profile photo and preferences such as theme and currency.
• Enquiries — your name and contact details as you enter them, your message, the vehicle, and how you want to be contacted (call, WhatsApp, email or in-app chat). Tapping Call or WhatsApp on a car sends the seller an enquiry with your details.
• Test drives and trade-ins — your preferred date, the viewing location and your notes; for a trade-in, your vehicle's make, model, year, mileage, condition and photos.
• Finance and insurance requests — the vehicle and the figures you choose. For finance: deposit, loan amount, term, rate and monthly payment. For insurance: cover type, how you use the vehicle and the premium shown.
• Messages and reviews — messages you exchange with businesses in Garisea, and the reviews, ratings and photos you post. Reviews show your name and profile photo publicly. In a chat, the other side can see when you are typing and when you have read their messages.
• Cars you buy and offers you claim — when a dealer records that you bought a car you enquired about on Garisea, or you tell us you bought it, we record the car, the dealer and the date. When you claim an offer, we record the offer, the code we give you and whether it was used.
• Garisea Assistant — what you type to the Garisea Assistant and its replies, whether or not you are signed in, and, if you are signed in, the preferences it remembers (Section 4.1).
• Searches — the words and filters you search with.
• Your choices — for example whether you agreed to receive offers on WhatsApp, and when and where you agreed, or whether you accepted a dealer's request to contact you.
• Support — anything you send to our support team.

3.2 Information we collect automatically

• Device and browser — IP address, browser type and version, operating system, device model, screen size, language and time zone.
• Device identifier — a random ID stored on your device, which links your browsing to your account when you sign in or send an enquiry.
• Usage — the pages and vehicles you view, the searches you run, what you click, and the ads shown to you and clicked.
• How you arrived — campaign tags in the link you followed, Google or Meta click IDs, the referring website and the first page you landed on, including which Garisea QR code you scanned and where it was printed. We save these with an enquiry you send.
• App identifiers — a per-install ID and a push token to deliver notifications. On iPhone, the Advertising Identifier only if you allow tracking (Section 14).
• Location — only if you allow it, to show nearby dealers and fill in the viewing location for a test drive. You can turn it off in your phone's settings.
• Error data — when something fails, the error details and the ID of the signed-in account. For errors on our servers this can include your email address.
• Cookies and similar storage — see our Cookie Policy.

3.3 Information from others

• Sign in with Google — your name, email, profile picture and a Google account ID. Never your Google password.
• Sign in with Apple — an Apple ID for you and, the first time only, your email (or an Apple relay address if you chose “Hide my email”) and your name if you shared it. We also keep an Apple token, encrypted with AES-256-GCM, so we can revoke your Apple sign-in when you delete your account, as Apple requires.
• Lenders and insurers — the quote or reply a partner sends you through Garisea.
• Dealers — when a dealer records that you bought a car you enquired about, we record the sale, its date and the sale price against your enquiry.

• Run the marketplace — show listings, send your enquiries and requests to the businesses you choose (or, for a “No preference” finance or insurance request, to the partners described in Section 6.2), arrange test drives, and calculate estimates.
• Offers for your new car — for 60 days after you buy a car through Garisea, show you offers for your car from service, parts, tyre and detailing businesses, and from banks and insurers (motor cover and car finance only), on Garisea, and send you one push notification about them. We check every offer before you see it. A business never learns who viewed its offer unless you claim it (Section 6.3).
• Help you find the right car — rank results, keep “Recently viewed” and “Saved vehicles”, and recommend vehicles.
• Answer you with AI — the Garisea Assistant uses your messages to answer your questions and find cars for you (Section 4.1). We may also use AI to understand what you type into search.
• Keep in touch — send account emails, enquiry updates, push notifications, one-time passcodes by SMS, and WhatsApp alerts, and send offers (Section 13).
• Measure ads — count views and clicks on ads, and credit an enquiry to the ad or campaign that led to it (Section 6.6).
• Keep Garisea safe — limit abuse, spot fake accounts and listings, check reviews and messages against our Acceptable Use Policy (partly with automated and AI tools), and act on reports.
• Improve Garisea — use analytics to see which features people use and where things break. Analytics is on by default and you can switch it off (Section 15).
• Meet legal duties — answer lawful requests from Kenyan regulators, courts and law enforcement, and keep the records the law requires.

4.1 The Garisea Assistant

The Garisea Assistant answers your questions about cars, prices, finance, insurance and using Garisea, on the website and in the app.

• What we keep — your messages and the assistant's replies, including the cars it showed you. If you are signed in, your chats are stored with your account. If you are not, they are stored with a random identifier for your browser or phone, so only that browser or phone can open them; when you sign in there, they move to your account. Authorised Garisea staff can read chats to help you, check the quality of answers and act on abuse.
• Who processes your messages — an AI service provider processes them for us, on our instructions (Section 6.4), and an automated safety check reads each message to keep abuse out. We don't use your chats to sell placements, and no one can pay to appear in the assistant's answers: every car it shows you is an ordinary search result.
• What it remembers — when you are signed in, the assistant remembers the preferences you tell it, so you don't have to repeat them: your budget, the body types, makes, fuel and gearbox you like, your town, and what the car is for. It remembers nothing else, and nothing while you are signed out. Memory is on by default. To see what it remembers, clear it or turn memory off, go to Profile → Settings → Privacy & Data on the website, or Profile → Privacy & Data → Assistant memory in the app. Turning memory off also deletes what it remembered.
• What it does for you — the assistant sends an enquiry or a test-drive request only after you tap Confirm on the request it shows you. The seller then gets the same details as for an enquiry you send from the car's page (Section 6.1). When you ask it to, it can also save a search for you or open a support ticket.
• Deleting chats — delete any chat from your chat list at any time. How long we keep chats is in Section 7.

Under the Act, and GDPR Article 6 where it applies, we rely on:

• Contract — to provide the service you signed up for: your account, enquiries, requests and messages, and the Garisea Assistant's answers.
• Legitimate interests — to keep Garisea safe, to run analytics, to measure and report on ads, including Garisea's own advertising, and to improve the service. We weigh these interests against your rights, use only what we need, and let you object (Section 9).
• Legitimate interests, with an opt-out — to send offers by push notification and email, which are on until you switch them off (Section 13), and for the Garisea Assistant to remember your preferences between chats, which is on until you turn it off (Section 4.1).
• Consent — for offers on WhatsApp, tracking on iPhone, location, and sharing your contact details with a dealer after a buyer signal. You can withdraw consent at any time.
• Legal obligation — to keep records the law requires and answer lawful requests.

We share your information only to provide the service, with your consent, or when the law requires it. We don't sell your personal information.

Every form that sends your details to a dealer, lender, insurer or other business says so beside its send button, and names who will receive them. Sending the form is your agreement to that sharing. We keep a record of when you sent it and the wording you were shown.

6.1 Dealers and other sellers

When you send an enquiry, book a test drive or ask for a trade-in valuation, we share your name, contact details and message with the seller, along with the vehicle. The seller is the dealer or, for a bank recovery sale, the lender selling a car it has repossessed. The seller needs these to reply. A seller you never contact never sees your details. If a dealer doesn't reply in reasonable time, we may pass your enquiry to another dealer with a similar vehicle (see our Terms of Service, Section 6).

When you ask for finance or insurance on a vehicle, the dealer selling it may be told that a buyer is interested. The dealer sees only a label such as “Buyer A8F2”. It gets your name and contact details only if you accept its request to contact you.

6.2 Lenders and insurers

When you ask for a finance or insurance quote:

• If you choose a lender or insurer, we send your request only to that partner.
• If you choose “No preference”, we may share your request with up to 5 licensed partners that can serve the vehicle. One of them may see it first, for a short time, before the others. If the car is a bank recovery sale, the lender selling it may see your finance request first.

Each partner receives your name, email address, phone number and message, the vehicle, and the figures in your request (Section 3.1). A partner without a paid plan sees your request with your contact details hidden; they are shown to it only if it takes a paid plan. Partners don't see how you arrived at Garisea.

Partners are licensed businesses and independent controllers of what they receive. Their own privacy policies apply, so please read them.

6.3 Service, parts, tyre and detailing businesses

When you send an enquiry to one of these businesses, or claim one of their offers for a car you bought, we send that business your name, email address, phone number and message, and the car. Only the business you chose receives it. When you claim an offer, the business gets your email address and phone number as well as your name, so it can contact you to arrange the offer. We also give you a code to show the business, and you can cancel a claim you haven't used. The business is an independent controller of what it receives.

6.4 Service providers

We use service providers to run Garisea. They act on our instructions and may use your information only to provide their service to us. The kinds of provider we use are:

• Hosting, database and caching — to run our servers, apps and database. Data is encrypted in transit and at rest.
• Email, SMS and WhatsApp delivery — to send account messages, alerts, one-time passcodes and offers (Section 13).
• Push notifications — to deliver alerts to your browser or phone.
• Image and video hosting — to store and serve photos, videos and documents.
• Analytics — to understand how Garisea is used, including Google Analytics on the website and Firebase in the app (Section 15).
• Error monitoring — to find and fix errors (Section 3.2).
• Maps — to show dealership and viewing-location maps.
• Bot protection — to keep automated abuse out.
• Background jobs and internal alerts — to run scheduled work such as reminders, and to alert our team to problems.
• AI — an AI service provider, acting for us, processes what you type to the Garisea Assistant (signed in or not), with what the assistant needs to answer you, such as earlier messages in the chat, the cars it found and the preferences it remembers; search words we ask it to interpret; and reviews and messages we check for abuse. Businesses can ask it to draft a reply to your enquiry; that request includes your name and message, but not your email address or phone number.

A full list of our service providers is available from [email protected].

6.5 Advertising and measurement partners

To run and measure Garisea's own ads, and to learn which campaign brought you to the app, we share limited data with Meta (Facebook, Instagram) and Google:

• What we share — your email address, phone number and Garisea account ID in scrambled (hashed) form, used only to match you to an ad; your IP address, browser details and the IDs in Meta's cookies; your device's advertising ID in the app (on iPhone only if you allow tracking); and key actions. On the website these are page views, vehicle views, searches (including what you typed), saved vehicles, sign-ups and enquiries. In the app they are installs, sign-ups and enquiries. We never send your email address or phone number unscrambled.
• When — on the website, by default, until you switch Advertising off in Cookie settings. In the app, subject to your tracking and advertising-ID settings.
• Why — to measure whether our ads work, to show Garisea's ads to people who have visited Garisea, and to attribute app installs. Not to let Meta or Google advertise other companies' products to you.
• Your control — turn off Advertising in Cookie settings; on iPhone, don't allow tracking; on Android, reset or limit your advertising ID. You can also manage ads directly with Meta and Google.

Meta and Google are independent controllers of what they receive and follow their own privacy policies.

6.6 Advertisers

Businesses that advertise on Garisea see how their ads perform: views, clicks, and the number of enquiries that followed a click on their ad. If you click a business's ad and send it an enquiry within 24 hours, we credit the enquiry to that ad. We don't give advertisers a list of the people who saw or clicked their ads.

We don't share buyer-level personal data with partners through market-data products.

6.7 Legal disclosure

We may disclose your information when Kenyan law requires it, for example under a court order, a regulator's formal request, or a criminal investigation by the Directorate of Criminal Investigations (DCI). We will tell you about the request unless the law forbids it.

6.8 Business transfers

If Garisea is sold, merged or restructured, your information may pass to the new owner under the same privacy commitments. We will email you before that happens.

We keep personal information only as long as we need it for the purposes in this Policy. Then we delete it or anonymise it so it no longer identifies you.

• Encryption in transit — connections to garisea.com, dealer.garisea.com, partner.garisea.com, our API and the app use TLS 1.2 or higher.
• Encryption at rest — our production database is encrypted at rest. Apple sign-in tokens are also encrypted with AES-256-GCM before we store them.
• Passwords — stored only as salted bcrypt hashes. No one at Garisea can see your password.
• Sign-in — access tokens last 30 minutes and refresh tokens rotate on every use. The app stores them in the iPhone Keychain or Android Keystore; the website stores them in secure, httpOnly cookies.
• Signing out — Log out ends your session on that browser or device only. Sign out everywhere (in Profile → Settings) ends every session on your account, on other browsers and in the app. Changing or resetting your password and deleting your account do the same (a password change keeps the device you changed it on signed in). Those other sessions normally stop working within seconds, not when their sign-in would otherwise expire.
• Account lockout — after 5 failed sign-in attempts in 30 minutes, we lock the account for a short time and email you.
• Signed webhooks — we check the signature on incoming payment, email and media notifications before trusting them.
• Access controls — our staff get access to personal data by role, and we log administrative actions. Support staff see only what they need to help you.
• Reviews — we review our systems for security issues and rotate secrets every 90 days, and at once if we suspect a compromise.

No system is completely secure. If a personal data breach affects you, we will notify the Office of the Data Protection Commissioner within 72 hours of becoming aware of it, and tell you without undue delay where the breach puts you at real risk.

Under the Act (and GDPR Articles 15–21 where they apply) you have these rights:

• Access and portability — on the website, go to Profile → Settings → Download my data. You get a JSON file straight away, and can download it once every 24 hours. It contains your profile, saved vehicles, the reviews you wrote about dealers and vehicles, your enquiries (date, type, status, vehicle and business), a list of your AI assistant chats, your last 500 notifications, your notification and messaging choices, your support tickets, and your searches from the last 90 days. For anything the file doesn't include, such as the text of your messages, email [email protected].
• Correction — edit most details in Profile → Settings. For anything you can't change yourself, email [email protected].
• Deletion — delete your account in Profile → Settings → Delete Account, on the website or in the app. When you delete your account, we:
  • remove your name, email address, phone number and photo from your account, and sign you out everywhere;
  • remove your name, email address and phone number from the enquiries and offer claims you sent, and your contact details from the messages you wrote; and
  • show “Former user” instead of your name on your reviews, and remove your photo from them.
  Businesses that already received your enquiries keep their own copies as independent controllers; ask them directly if you want those deleted. We keep what the law requires, such as the audit log, and data that no longer identifies you.
• Garisea Assistant — delete any chat from your chat list. See, clear or turn off what the assistant remembers in Profile → Settings → Privacy & Data on the website, or Profile → Privacy & Data → Assistant memory in the app (Section 4.1).
• Objection — object to processing based on our legitimate interests. For example, switch off analytics (Section 15) or offers (Section 13), or email [email protected].
• Withdrawing consent — withdraw any consent in your settings, your phone's settings or Cookie settings. It doesn't affect what we did before.
• Restriction — ask us to pause processing while we look into a complaint. Email [email protected].
• Complaint — if you think we have mishandled your data, complain to the Office of the Data Protection Commissioner (Kenya).

We respond to rights requests within the time the law requires.

Most of our servers and service providers are outside Kenya. Our main database is hosted in the United States, and most of our providers are based in the United States; our SMS provider is in Kenya. When we transfer your information outside Kenya we do so under section 48 of the Act, relying on contracts that require the recipient to protect it, and on encryption in transit and at rest.

The Act treats some information as sensitive, for example your health, ethnic origin, beliefs, biometric data, marital status, family details or sex. We don't ask for this. A finance, insurance or trade-in request describes a vehicle and a proposed loan or policy. If you put sensitive information in a message, review or support ticket, ask us to delete it.

Garisea is for adults aged 18 and over. We don't knowingly collect information from anyone under 18. If you think a child has given us information, email [email protected] and we will delete it.

We send offers and updates — price drops, new arrivals, flash deals and matches for your saved searches — by push notification and in the app (never by email), a weekly summary by email, and offers for a car you have bought by push notification only. They are on when you create an account, and you can switch each one off at any time. We send offers on WhatsApp only if you agree.

• Email — click Unsubscribe in any of our emails, or turn categories off in Profile → Notification Preferences.
• Push — turn categories off in Notification Preferences, or turn notifications off in your phone's settings.
• WhatsApp — we send offers on WhatsApp only after you say yes, and we record when and where you agreed. Turn them off in your settings at any time. You can also reply STOP to any WhatsApp message from us. STOP blocks all our WhatsApp messages to your number, including alerts about your enquiries, and the texts we would send instead. Reply START to get alerts again; this doesn't sign you back up for offers.

While you have an account, we send messages you need, such as sign-in codes, password resets, account notices and replies to your enquiries. You can't opt out of security messages.

The app asks for these permissions. Each is optional, and you can change any of them in your phone's settings.

• Camera and photos — to add photos to a review, a trade-in or a support ticket.
• Location (while using the app) — to show nearby dealers and fill in a viewing location.
• Notifications — for enquiry updates, messages, price drops and account notices.
• Tracking (iPhone only) — whether we may link your app activity to your device's Advertising Identifier. It is off unless you allow it.

The app uses Firebase for app analytics and Meta's App Events tool to count installs, sign-ups and enquiries for our own ads. Switch analytics off in Profile → Privacy & Data. The app stores your sign-in tokens in the iPhone Keychain or Android Keystore, and your preferences, recently viewed vehicles and cached photos on your device. Our Cookie Policy (Section 7) lists this storage.

The app's Apple privacy manifest declares the data the app collects and why.

We use cookies and similar storage as described in our Cookie Policy. Analytics is on by default. Switch it off with Cookie settings in the website footer, in Profile → Settings, in the app under Profile → Privacy & Data, or by sending a Global Privacy Control signal from your browser. Advertising cookies work the same way: on by default, and switched off by the same controls. If you switch analytics off we still count that an ad was shown or clicked, without a device identifier, a session or anything about you.

We use automated systems to:

• rank search results and recommend vehicles;
• answer you in the Garisea Assistant, which suggests cars but never sends an enquiry or request for you until you tap Confirm (Section 4.1);
• order lenders and insurers by what you would actually pay for the vehicle (or by their advertised rate if you haven't chosen a vehicle); a partner's paid plan only breaks ties;
• decide which partners receive a “No preference” request (Section 6.2);
• show businesses how likely an enquiry is to lead to a sale; and
• filter fake listings, spam and abusive content.

None of these decisions has a legal or similarly significant effect on you within section 35 of the Act. They affect order and presentation, not whether you can use Garisea. If you think an automated decision has harmed you, for example your review was wrongly hidden, email [email protected] and a person will review it.

If you apply for a job at Garisea, by emailing [email protected], through our Careers page, or speculatively, we use the information in your application to assess you and run the hiring process.

17.1 What we collect

• Your application — name, contact details, CV, cover letter, work history, education, skills and anything else you include.
• Assessment — emails, interview notes and feedback.
• Referees — their contact details, if you give them. Please check they are happy to be named first.

17.2 How we use it and our lawful basis

We use it to assess your application, talk to you, arrange interviews and decide. Our lawful basis is taking steps at your request before a possible employment contract, and our legitimate interest in recruiting. We don't sell applicant data or use it for advertising.

17.3 Who sees it

Only Garisea's hiring team and the people involved in the decision, plus service providers such as our email host acting on our instructions. We don't share applications with dealers, partners or other third parties.

17.4 How long we keep it

If we hire you, your application becomes part of your employment record and our staff privacy notice applies. If not, we keep it for up to 12 months in case a suitable role opens, then delete it, unless you ask us to delete it sooner or agree to us keeping it longer.

17.5 Your rights

Ask to see, correct or delete your application at any time by emailing [email protected]. The rights in Section 9 apply.

We may update this Policy as Garisea changes or the law requires. We will email you about a material change at least 14 days before it takes effect, and show a notice in the app. The “Last updated” date at the top shows the latest version. If you keep using Garisea after the change takes effect, the updated Policy applies.

For privacy questions, complaints or to use your rights:

• Privacy questions, rights requests, complaints, trust and safety and general support: [email protected], our data protection contact.
• Job applications, and anything about an application you have already sent: [email protected].
• Francton Limited, operating as Garisea.

To complain to the Kenyan regulator: Office of the Data Protection Commissioner — www.odpc.go.ke.