Gombea Privacy Policy
Gombea respects your privacy and is committed to handling personal information responsibly, transparently and securely.
This Privacy Policy explains what information Gombea collects, why we collect it, how we use it, when it may be shared, how long it may be retained, and the choices and rights available to you.
Gombea is an independent information aggregation platform. We are not a government service and are not affiliated with, operated by, or endorsed by any government institution, political party, candidate or campaign.
This policy applies to the Gombea website, applications and related services.
1. Who We Are
Gombea is operated by:
ZOTE TECHNOLOGIES
Kenya
Privacy enquiries:
[email protected]
For applicable data protection laws, the entity identified above acts as the data controller for personal data processed through Gombea unless stated otherwise.
2. Information We Collect
The information we collect depends on how you use Gombea.
Account Information
If you create a Gombea account, we may collect:
- name or display name
- email address
- username
- account identifier
- password in securely hashed form
- profile image, if provided
- information you choose to add to your profile
- account preferences
- account creation and login information
We do not store your password in readable form.
Public Profile Information
Gombea may allow users to create public profiles.
Information you deliberately designate as public may be visible to other Gombea users and potentially to people accessing Gombea without an account.
This could include:
- display name
- username
- profile photograph
- biography
- other information you deliberately choose to publish
Your email address, password, precise location, advertising identifier and private account information are not public profile information.
Before publishing information to your public profile, consider whether you are comfortable making that information publicly accessible.
Where product controls permit it, you may edit or remove public profile information.
3. Location Information
Location is an important part of Gombea because political representation is geographic.
With your permission, Gombea may use your device location to determine information such as your:
County
→ Constituency
→ Ward
and to show representatives and civic information relevant to that location.
We will request location access when it is required for a location-based feature.
Where practical, Gombea will provide alternatives such as manually searching for a county, constituency, ward or place.
We aim to request only the level of location accuracy necessary to provide the feature being used.
Gombea does not require continuous background location tracking for its core map and representative-discovery functionality.
We will not make your precise device location publicly visible on your Gombea profile.
4. Analytics and Device Information
We may collect technical and usage information to understand how Gombea is being used and to improve reliability and performance.
This may include:
- device type
- operating system
- browser type
- application version
- language
- approximate location derived from network information
- IP address
- pages or screens viewed
- interactions with features
- session information
- crash information
- diagnostic information
- referring pages
- performance information
We may use analytics providers to process some of this information on our behalf.
Where consent is legally required for particular analytics technologies, we will request that consent before activating them.
5. Advertising
Gombea may display advertising to help fund the service.
Advertising partners may process information such as:
- advertising identifiers
- device information
- approximate location
- advertising interactions
- impressions
- clicks
- technical information required to deliver and measure advertising
Where required by law or platform policy, personalised advertising will only be enabled after the appropriate consent has been obtained.
Users who do not consent to personalised advertising may still receive contextual or non-personalised advertising where permitted.
We will respect applicable device-level advertising preferences and advertising-identifier controls.
Gombea does not sell users' personal and sensitive information in exchange for money.
6. Location and Advertising
Location information provided for Gombea's map and representative-discovery features will not automatically be used for personalised advertising merely because location permission has been granted.
If Gombea ever proposes using permission-based device location for advertising purposes, that use will be clearly disclosed and any consent required by applicable law or platform policy will be obtained.
Location permission will not be requested solely for advertising.
7. How We Use Personal Information
We may process personal information to:
- create and manage accounts
- authenticate users
- provide public profiles
- provide map and location features
- identify relevant electoral areas
- show representatives relevant to a selected location
- remember user preferences
- provide saved features
- operate and improve Gombea
- understand application usage
- measure application performance
- diagnose errors
- maintain security
- prevent fraud and abuse
- communicate important service information
- provide advertising
- measure advertising performance
- comply with legal obligations
- respond to privacy and data-protection requests
We will not use personal information for materially incompatible purposes without establishing an appropriate legal basis and, where required, obtaining additional consent.
8. Legal Bases for Processing
Depending on the information and circumstances, Gombea may rely on different lawful bases for processing.
These may include:
Contract
Where processing is necessary to provide a service you requested, such as creating and maintaining your account.
Consent
Where you have actively agreed to processing, such as certain location, analytics, advertising or optional features.
Where processing relies on consent, you may withdraw that consent.
Legitimate Interests
Where processing is reasonably necessary to operate, secure, understand or improve Gombea and those interests do not override your rights and interests.
Legal Obligation
Where information must be processed or retained to comply with applicable law.
Other lawful bases may apply where permitted by applicable data protection legislation.
9. Political Opinions and Sensitive Information
Gombea is a political-information platform, but using Gombea does not necessarily reveal a user's political beliefs.
We will not assume that:
- viewing a politician means you support them
- viewing a political party means you belong to it
- viewing an electoral area establishes your political preference
- reading particular political news establishes a political opinion
We will not deliberately infer a user's political beliefs merely from ordinary browsing activity for the purpose of creating advertising profiles.
Users should also avoid publishing sensitive personal information unnecessarily through their public profiles.
10. Public Information About Representatives
Gombea also processes information about politicians, candidates, public officials and other people connected with public life.
This information is generally different from information collected about Gombea users.
It may originate from publicly available sources such as:
- Parliament
- Senate
- electoral authorities
- county governments
- county assemblies
- government publications
- gazettes
- political parties
- public professional biographies
- election records
- reputable news organisations
- other publicly accessible sources
This information may include:
- name
- photograph
- public office
- electoral area
- political affiliation
- election history
- education
- professional history
- parliamentary activity
- publicly stated biographical information
- public statements
- relevant news coverage
Gombea processes such information for the purpose of providing an independent public-information and civic-discovery service.
Where appropriate, Gombea records the source and date on which information was obtained or verified.
11. Accuracy of Public Information
Public information can change.
Political representatives may:
- change political affiliation
- resign
- lose office
- be replaced
- participate in a by-election
- receive a new appointment
Official sources themselves may sometimes be incomplete or slow to update.
Gombea therefore aims to show source and verification information where practical.
Users may report information they believe is incorrect.
A user report does not automatically alter the public record. Gombea may review available sources before making a correction.
12. Sharing Information
We may share personal information with service providers where reasonably necessary to operate Gombea.
These may include providers of:
- cloud infrastructure
- hosting
- content delivery
- authentication
- analytics
- security
- error monitoring
- advertising
- customer support
These providers may process information only for authorised purposes and subject to applicable contractual and legal requirements.
We may also disclose information where reasonably necessary to:
- comply with applicable law
- respond to a valid legal process
- protect users
- investigate fraud or security incidents
- protect Gombea's legal rights
If Gombea or its operating business is reorganised, acquired or transferred, information may be transferred as part of that transaction subject to applicable legal safeguards.
13. Google Services
Gombea may use services provided by Google, including services relating to analytics, application distribution and advertising.
Where Google technologies are used, information may be processed in accordance with Google's applicable privacy terms and user controls.
Gombea will configure such services with the objective of minimising unnecessary personal-data collection.
Where required, users will be given appropriate choices concerning analytics and personalised advertising.
14. Meta / Facebook Services
Gombea may use services or technologies provided by Meta where these are integrated into the platform.
If such services are introduced, Gombea will disclose the relevant integration and the categories of information transferred.
Gombea will not provide Meta with information beyond what is necessary for the enabled service and permitted by applicable law and platform requirements.
Where consent is required, the relevant integration will not operate until appropriate consent has been obtained.
15. Cookies and Similar Technologies
The Gombea website may use cookies, local storage and similar technologies.
These may be used for:
- authentication
- security
- preferences
- application functionality
- analytics
- advertising
Technologies necessary for providing a service requested by the user may operate without optional consent where permitted by law.
Where consent is required for analytics, personalised advertising or other optional technologies, users will be given appropriate controls.
Users will be able to change applicable consent preferences later.
Further information is available in our Cookie Policy.
16. Data Retention
We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including applicable legal, security and operational requirements.
Retention periods may vary by data type.
For example:
Account information may be retained while an account remains active.
Security logs may be retained for a limited period where necessary to investigate abuse or security incidents.
Advertising and analytics information will be retained according to configured retention periods and applicable provider settings.
When an account is deleted, personal information associated with the account will be deleted or anonymised within a reasonable period unless continued retention is required or permitted by law.
Backups may retain deleted information temporarily until they are overwritten according to the normal backup cycle.
Public information about politicians and public office holders may be retained historically where appropriate to preserve election and public-office history.
17. Account Deletion
You may request deletion of your Gombea account and associated personal information.
Gombea will provide an account-deletion mechanism within the service or through a clearly accessible web process where required.
Deleting an account will not necessarily remove information that:
- must legally be retained
- has been anonymised
- forms part of legitimate security records
- must temporarily remain in backups
- concerns a public representative independently obtained from public sources rather than from their Gombea user account
Where information has been deliberately published publicly by a user, we will take reasonable steps to remove that information when the associated account is deleted, subject to applicable legal exceptions.
18. Your Data Protection Rights
Depending on your location and applicable law, you may have rights including the right to:
- be informed about how your information is used
- access personal information held about you
- request correction of inaccurate or incomplete information
- request deletion where applicable
- object to certain processing
- request restriction of processing
- withdraw consent
- request portability of applicable information
- object to direct marketing
- raise concerns about automated decision-making where applicable
These rights are subject to applicable legal conditions and exceptions.
To exercise a privacy right, contact:
[email protected]
We may need to verify your identity before fulfilling certain requests.
19. Complaints
If you have concerns about how Gombea handles your personal information, please contact us first so we can investigate.
You may also have the right to lodge a complaint with the relevant data protection authority.
In Kenya, the supervisory authority is the Office of the Data Protection Commissioner (ODPC).
Users located in jurisdictions where the GDPR applies may also have the right to complain to their relevant national data protection supervisory authority.
20. International Data Transfers
Some technology providers used by Gombea may process information outside Kenya or outside the country in which you live.
Where personal information is transferred internationally, Gombea will take appropriate steps required by applicable data protection law to protect that information.
These measures may include contractual safeguards, recognised adequacy mechanisms or other legally permitted transfer mechanisms.
21. Security
We use reasonable technical and organisational safeguards designed to protect personal information.
Measures may include:
- encryption in transit
- secure password hashing
- restricted administrative access
- access controls
- security monitoring
- software and dependency updates
- data minimisation
- secure infrastructure configuration
No internet service can guarantee absolute security.
Users should use a strong, unique password and keep their login credentials confidential.
22. Children and Young People
Gombea's public political information may be browsed without creating an account.
Additional safeguards may apply where a child or young person creates an account or where Gombea processes their personal information.
Where parental or guardian consent is legally required, Gombea will seek the required authorisation before processing personal information on the basis of consent.
We do not knowingly use children's personal information for behavioural advertising or create advertising profiles based on a child's political interests.
Public-profile functionality for younger users may be restricted where necessary to protect their privacy and comply with applicable law and platform requirements.
If we discover that personal information relating to a child has been collected contrary to applicable requirements, we will take appropriate steps to remove or restrict it.
Parents or guardians may contact:
[email protected]
with relevant privacy concerns.
23. Automated Processing and AI
Gombea may use automated systems to organise publicly available information.
Examples may include:
- categorising professional histories
- classifying news topics
- summarising public information
- identifying references to representatives
- analysing aggregated political data
- generating statistical insights
Automated classifications may be imperfect.
Where appropriate, Gombea will distinguish generated analysis from original source material and provide mechanisms for reporting inaccuracies.
We do not intend to make decisions producing legal or similarly significant effects about Gombea users solely through automated processing.
24. Changes to This Policy
Gombea may update this Privacy Policy as the platform develops or legal and regulatory requirements change.
The latest version will always show its effective or last-updated date.
Where a change materially affects how personal information is processed, we may provide additional notice or seek consent where required.
25. Contact Us
Questions, requests or concerns regarding privacy can be directed to:
Gombea
Email: [email protected]
Data Protection Officer, if appointed: [email protected]
Independent Platform Notice
Gombea is an independent information aggregation platform.
It is not affiliated with, operated by, or endorsed by the Government of Kenya, any county government, political party, candidate, campaign, Parliament, electoral authority or other public institution unless a specific relationship is expressly stated.
References to public bodies, politicians and political parties identify the subjects or sources of information and do not imply endorsement of Gombea.