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Privacy Policy

  1. Your privacy is important to us. This privacy policy explains how the personal data Pakakumi collects, how Pakakumi process it, and for what purposes through your use of this platform and the choices you can make about the way your information is collected and used. We are committed to protecting and respecting your privacy.

    This policy should be read together with the Terms of Service of use of Pakakumi i services and products through this platform. The policy applies to all customers using while using this platform.

  2. Definitions of Terms: In this policy the following terms shall have the following meaning:

    “Account” means Pakakumi account used to access our platform and services.

    “Law” means applicable law in Kenya including but not limited to the Constitution of Kenya 2010, the Data Protection Act, 2019, the Betting Control and Licensing Board, Cap 131, the Proceeds of Crime and Anti-Money Laundering Act, 2009 and any other relevant law in Kenya relating to Data Protection and Privacy.

    “Our Platform” means this Pakakumi site https://pakakumi.com

    “Payment” means any funds deposits or withdrawals in your account

    “Personal data” means any information relating to an identified or identifiable natural person. It can include obvious identifiers like your name but also identification numbers, location, online identifiers and/or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.

    “Services” means products offered under Pakakumi platform.

    “Us”, “We” means is reference to Pakakumi.

    “You” “Your” means is reference to Customer.

  1. Customers acknowledge and accept that it is necessary for Pakakumi to collect and otherwise store personal data in order to allow customers access and use Pakakumi and in order to allow customers to participate in betting activities. Customers hereby acknowledge and accept that all telephone calls made by customers to Pakakumi may be recorded for their own protection and benefit.
  2. Pakakumi may collect data every time you interact with our platform including the following instances:
    • When opening account with us.
    • When resetting your password.
    • When making payments either deposits or withdrawals.
    • When placing bets.
    • When you interact with our customer service team.
    • When you participate in our marketing promotions.
    • When you otherwise provide information to us through the platform or elsewhere.
  3. Pakakumi acknowledges that in collecting personal details as stated in the previous provision, Pakakumi will protect your personal information and respect your privacy in accordance with best business practices, the Data Protection Act, 2019 and applicable laws.
  4. Pakakumi, whether directly or through third party suppliers, may collect information regarding your use of our services, including but not limited to:
    • Your name, username and password;
    • Your personalized account details;
    • Your contact details including mobile phone number;
    • Your Mobile Money Wallet account details;
    • Your country of residence;
    • Your biodata including your age;
    • Device IDs or unique identifiers, device and software characteristics (such as type and configuration), connection information, statistics on pages views, statistics on your bet slips and history, referral URLs, ad data, IP addresses and standard web log information;
    • With your consent, the location of your device;
    • Information collected via the use of cookies, web beacons and other technologies.
    • Any website that referred you to the platform, together with any online and any other marketing campaigns/ promotions that relates to our Services;
    • Your betting, gaming and payments (deposits and withdrawals) history on the Service and other account transaction;
    • Information that you provide as part of Know Your Customer (KYC), Due Diligence and Enhanced Due Diligence checks, including copies of identification documentation and source of funds;
    • Behavior on our Service as you click around the platform;
    • Online and Bulk sms marketing and promotional campaigns you receive or subscribe to in relation to the Service.
  5. You will only be able to access services in our platform only by registering with us and opening an Account. To open account, You must provide us with at least your name, mobile phone number / Mobile Money Wallet account number, username and a password.
  6. Pakakumi will collect and process your personal data about you in order to enable your account opening and also to meet its regulatory and legal requirements while providing gaming services. If you fail to provide that information- such as your registered mobile phone number to confirm your identity and age and consent to being over 18 years- we may be unable to sign you up and provide you sought services.
  7. Pakakumi will only use such collected customer personal data either to allow customers to participate in betting activities provided by us and to carry out operations relevant to customer participation in these activities.
  8. Customer data will not be disclosed to third parties, unless such disclosure is necessary for processing of customer requests in relation to participation in the betting activities (such as making payments) in order to fulfill the agreement we have with you or unless it is required by law or to a regulatory agency such as (without limitation) the Betting Control and Licensing Board and the Financial Reporting Centre and any successor body(ies) authorized to regulate gaming activities and financial intelligence respectively under the laws of Kenya. Customers hereby consent to such disclosures. We also process your data when it is in our legitimate interest to do this and when these interests are not overridden by your data protection rights. Examples of this include processing your data to provide us with information on how our platform is used and can be improved and ensuring compliance with our terms and conditions. The disclosure of customer information to any other third party will be done only if acknowledged by the customer.
  9. In order to provide customers with an efficient service, Pakakumi and/or its service providers may require transferring customer data from one country to another. Customers hereby consent to data being transferred in this manner.
  10. In the processing of customer betting account and associated transactions, Pakakumi may have recourse to regulatory agencies such as Betting Control and Licensing Board, fraud detection agencies, Financial Reporting Center and Directorate of Criminal Investigations. Customers hereby consent to such disclosures.
  11. Pakakumi is regulated by Betting Control and Licensing Board (BCLB) as provided in Betting, Lotteries and Gaming Act, Cap 131 and thus required to comply with range of legal and regulatory requirements as set out in law, some of which involve the use of personal information and/ or set out timescales for which we need to keep that information. To comply with these legal requirements, we carry out checks at any time to ensure that our customers bet and play responsibly and legally including prevention of underage betting. It is an offence for underage (persons below 18 years of age) to participate in gambling activities in Kenya. Please check our responsible gaming policy.
  12. We are also subject to laws and regulations relating to other aspects of our business, such as payment processing or complaint handling and some of these may require us to retain personal information for a specified period of time, which may even extend after your account has been closed.
  13. Betting operators in Kenya are required under Proceeds of Crime and Anti-Money Laundering Act, 2009, to prevent money laundering, fraud, terrorism financing and flow of illicit funds. To abide by this legal requirement, we may monitor, share and store (up to seven years) information on accounts deemed to have suspicious transactions with Financial Reporting Centre and Betting Control and Licensing Board and other crime and fraud investigative agencies as required by law. We shall do this legally and in accordance with law.
  14. Privacy Rights: Our Privacy policy is in compliance with Data Protection Act, 2019. The policy covers activities we are obliged to do in order to provide our services legally, responsibly and in accordance with regulatory requirements as well as in fulfilling our agreement with you ( Read our Terms of Service), in order to ultimately protect our customers and our business. We cannot provide you with our services without carrying out these activities outlined in this privacy policy. If you don’t want your data used in any of way, your option is to not use our services and close your account.
  15. Pakakumi may also share your information in the following circumstances;
    • In event of a merger, joint venture, sale, restructure, acquisition, assignment, transfer, or disposition of all or any portion of our business assets, stock (including in connection with any bankruptcy or similar proceedings).
    • If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms of service.
    • In order to prevent fraud, cheating and money laundering we may disclose your information on betting and gaming history to third parties including but not limited to to, any relevant regulator, crime investigative agencies, financial institutions and law enforcement agencies or any body that deals with the investigation of alleged offences including a committee of Parliament or when asked to do so by a Court of law.

    In any of the above circumstances, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights as enshrined in Constitution of Kenya 2010 and the Data Protection Act, 2019, our obligations and the obligations of the third parties under applicable laws.

  16. Storage and Security of your personal information: We understand that the security of your personal information is important to you. When handling personal information, security is paramount and we seek to ensure that personal information is adequately protected. We use reasonable administrative, logical and physical controls, including passwords protection, to safeguard your personal information against lost, theft and unauthorized access, user or modification.

    However, it must be noted that the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your personal information.

  17. We store all your data in Kenya. In instances where we may need to store or transfer data outside Kenya, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be in Kenya. This includes ensuring that such storage and transfer is undertaken under a legal contractual framework between us and any third party and complies with Kenyan law and applicable international law and norms.
  18. Duration of Storage of Data: Your data will always be deleted if we no longer need it in accordance with our policy and Data Protection laws. We shall retain personal information for as long as we reasonably require it for legal, accounting or business purpose and subject to us not having any legal or regulatory requirement to retain your information, your information will not be kept for longer than 7 years after you have closed your account. However, in some instances we may be required to retain your information indefinitely (instances of self-exclusion). We will take all necessary steps to ensure that the privacy of information is maintained for the period of retention.
  19. Underage Restrictions: Our platform is not intended for use to persons under 18 years of age. By providing your information to us via this platform or otherwise you represent to us that you are at least 18 years old and acknowledge that your information can be used to verify that this is the case.
  20. Contact information: All questions, comments and requests regarding this privacy policy should be addressed to customer support@pakakumi.com
  21. Changes: We reserve the right to change this Privacy Policy at any time. Any changes will be posted on this platform and you will be deemed to have accepted the terms of the Privacy Policy on your first use of the platform following the alterations. We recommend that you check this page regularly to keep up to date.
  22. Your rights: Under the Data Protection Act, 2019 as a data subject you have a number of rights. Some of these rights only apply in specific circumstances and are qualified in several respects by legal exemptions. We will advise you in our response to your request if we are relying on any such exemptions. Some of these rights include:
    1. Right to be informed of the use to which your personal data is to be put;
    2. Right to access your personal data in our custody;
    3. Right to object to the processing of all or part of your personal data;
    4. Right to correction of false or misleading data;
    5. Right to deletion of false or misleading data;
    6. Right to data portability;
    7. Right to erasure; and
    8. Right to not be subject to decision based solely on automated processing.

    23. The data Controller for your information is:
    Reys and Meys Limited of Postal Address 102509-00101 Nairobi.

    The Data processor for your information is:
    Reys and Meys Limited of Postal Address 102509-00101 Nairobi.

    This Privacy Policy was last updated on 14th January 2025.