Privacy notice
Kinga, operated by Data-Lock Ltd · Last updated 26 September 2026
This notice says what Kinga holds about you, who can see it, who else receives it, and how long it is kept. It is written to be read by the person it is about, not by a lawyer.
1. Who is responsible for your data
Kinga is a product of Data-Lock Ltd, a Kenyan company.
Data-Lock Ltd is the data controller for the parts Kinga decides itself — how you are identified and signed in, how the platform is secured, and what Kinga charges. Where Kinga simply records what your SACCO decides — who it admits, what it collects, who holds office — Data-Lock acts as a data processor for your SACCO, and your SACCO is the controller of that.
In practice this means a request to either Kinga or your SACCO reaches the right place, and neither can send you away.
2. What Kinga holds
| About you | Why |
|---|---|
| Your name, phone number and national ID | To identify you as a member of your SACCO, and because a SACCO cannot admit a member it cannot identify. |
| Your PIN | Stored only as a one-way hash. Kinga cannot read your PIN, and neither can anyone at Kinga. |
| Your savings, shares, welfare contributions, loans and repayments | They are the reason the app exists. |
| Your stage, route and motorcycle registration | Your SACCO organises its members by where they work. |
| Your insurance cover, and any claim | To collect your instalments and to lodge a claim on your behalf. |
| Your next of kin and emergency contact | So somebody can be reached if you are hurt. These are another person's details, and Kinga treats them that way. |
| A photograph, if you add one | So the chairman and an officer can see it is you. |
Location. The Kinga app does not ask for your phone's location. The emergency button lets you choose your area from a list instead. Kinga does not track you, does not run in the background, and does not upload where you have been.
Camera. The app asks for the camera only on a Kinga staff phone, to scan the code on a membership card at a training event. It reads the code and nothing else: no photograph is taken, kept or sent. If the camera is refused, the code can be typed instead.
If you join a partner programme
Kinga sometimes carries a programme run by a partner organisation, such as a training for SACCO officials. Joining one is your choice. Nothing below is shared unless you apply and agree to that programme's own notice in the app, and saying no never changes anything else in Kinga.
| About you | Why |
|---|---|
| Your name, phone number, SACCO and the office you hold | So the partner can organise the programme and contact you about it. |
| Any training needs you choose to tell them | So the training fits you. It is optional. |
| When you checked in and out of each session | To record attendance, which is what the programme reports on. |
| The M-Pesa number you give for a transport refund, and the M-Pesa code of the payment | The partner sends the refund to your own M-Pesa and records the code in Kinga. Kinga moves no money: it only records that the partner paid. |
| Where the scan happened, and photographs or other media from the event, only if the programme uses them and you agree | Evidence for the programme's reports. It is taken by the staff phone, not yours, and saying no never affects your place or your refund. |
A partner never receives your national ID, your savings, your loans or your insurance records. You can withdraw from a programme in the app at any time; what was already shared before you withdrew cannot be recalled.
3. Who can see it
- You, in the app.
- Your SACCO's officials — chairman, secretary, treasurer — see your membership, your contributions and your standing. They do not see your PIN.
- Kinga staff, through a console that requires a named sign-in and records who looked at what.
- Nobody else, unless it is listed in section 4.
4. Who else receives it
| Who | What they get | Why |
|---|---|---|
| Birdview Microinsurance | Your name, ID, date of birth, contact details, and — if you enrol dependants or beneficiaries — theirs, including any medical conditions you declare | They are the insurer. They cannot issue cover to a person they have not been told about. |
| Co-operative Bank | Your phone number, your name and your member number, when you pay | Your SACCO banks there, and the payment prompt has to reach your handset. |
| MobileSasa | Your phone number, and the text of any message sent to you | They deliver Kinga's SMS. |
| Crash diagnostics, a push-notification token, and — if you use the in-app assistant — what you ask it and the account details it needs to answer | Crash reporting, notifications, and the assistant. See section 5. | |
| OpenRouter, and the AI company whose model it routes to | If you use the in-app assistant while Kinga has chosen an OpenRouter model: what you ask it and the account details it needs to answer | A second AI service Kinga can use for the assistant. See section 5. |
| A programme partner you chose to join — today, I Choose Life - Africa (Jiinue Business Accelerator) | What section 2 lists under "If you join a partner programme", and only after you agree | They run the programme: the training, the attendance, and any transport refund. |
| Contabo | Your member records, stored on the server Kinga rents from them | They run the server that holds Kinga's records, in the United States. See section 5. |
Kinga does not sell your data, and does not share it for advertising.
5. Where your data is held
Your member records — savings, contributions, membership, identity — are held on a server Kinga rents from Contabo, a hosting company. That server is in the United States. Kinga handles them under Kenya's Data Protection Act wherever they are stored.
Three more things go to Google, also outside Kenya, and the assistant may use OpenRouter instead:
- Crash diagnostics. When the app fails, a report goes to Google so it can be fixed. It contains device and error information.
- Push notifications. Your phone's notification token is held by Google, which is how a notification reaches a handset at all.
- The in-app assistant. If you use it, your question and the account details needed to answer it are sent to Google's Gemini service. If you hold office in your SACCO and ask about your members, their names are not sent: Kinga looks the list up itself, and Google sees only your question and the counts. If you would rather Google did not see your question at all, do not use the assistant — every other part of the app works without it.
- OpenRouter. Kinga can have the assistant answered by a model reached through OpenRouter, a service outside Kenya, instead of Google, or when Google is busy. The same rules apply: your question and the account details needed to answer it, and never other members' names. Some of the models it reaches, especially free ones, may keep what they are sent. The same choice stands: if you would rather not, do not use the assistant.
6. How long it is kept
| What | How long | Why |
|---|---|---|
| Your contributions and receipts | Seven years after they are recorded | Financial record-keeping obligations. Your SACCO's books have to survive you leaving it. |
| The audit trail — who did what, and when | Indefinitely | It cannot be edited or deleted, by anyone, including Kinga. That is what makes it worth having: it protects you in a dispute as much as it protects Kinga. See section 8. |
| Your identity details, PIN and sign-in codes | While you are a member, and 30 days after you ask to leave | They exist to sign you in and for nothing else. |
| SMS delivery records | With the phone number partly hidden, and never the message text | Kinga is billed per message and has to be able to check the bill. |
| Your membership card's scan code | 24 hours | A card is a claim about now. Old codes stop working by themselves. |
7. Your rights
Under the Kenya Data Protection Act, 2019 you may ask to:
- be told what Kinga holds about you;
- get a copy of it;
- have something wrong corrected;
- have it deleted, within the limits in section 8;
- object to how it is used, or withdraw a consent you gave;
- complain to the Office of the Data Protection Commissioner.
Kinga answers within 30 days and does not charge for it.
8. What deleting your account would and would not remove
Kinga would rather tell you this before you ask than after.
Removed: your name, phone number, national ID, email, your PIN, your sign-in codes, any photograph or document you uploaded, your vehicle details, and the next-of-kin and emergency contacts you gave.
Kept, but no longer connected to you: the contributions and receipts themselves. The amounts and the dates stay in your SACCO's books, because those books have to balance and other people's records depend on them — but they stop naming you.
Kept as it is, and we cannot change this:
- The audit trail. It is technically impossible to edit or delete, on purpose. It can contain your name.
- Records of things other people did — a payment somebody else made for you, a decision your chairman took about your membership.
- Insurance cover that is still in force, or a claim still open. An insurer cannot pay out on a policy it has been told to forget.
- Records another organisation's ledger already references, such as premiums already reported to Birdview.
If you ask to delete your account, nothing is removed for 30 days and you can cancel at any point in that window. After it, the removed parts are genuinely gone — Kinga does not keep a copy to restore from, because keeping one would make the deletion meaningless. If you come back later, you can bring the copy of your data you downloaded and Kinga can restore it.
9. How to ask
Write to privacy@kinga.co.ke, or speak to your SACCO's chairman, who can pass the request on. Kinga will need to confirm it is really you before acting — usually a code to the number already on your record.
If you are not satisfied, you may complain to the Office of the Data Protection Commissioner, Kenya, at odpc.go.ke.
10. Changes to this notice
The date at the top says when it last changed. When something material changes — a new recipient, a new purpose — Kinga will say so in the app rather than only editing this page.