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Privacy Policy

Last updated on July 8, 2026

Swappa Electronics Ltd (“Swappa Electronics”, “we” or “us”) operates an online store for renewed and pre-loved consumer electronics (the “Store”), available in Kenya through our website and its related pages.

This Privacy Policy (the “Policy”) applies to everyone who uses our Store. It explains:

  • how we collect and process your Personal Data as a user of the Store (“you” or “your”), and
  • your rights over that data and how to exercise them.

It works together with our Cookies Policy, also available on the Store. We do not knowingly collect data from anyone under 18 without the consent of a parent or guardian, and minors cannot make a purchase without that consent. All capitalised terms are defined in the Glossary (section 8).

Who collects your personal data?

Your Personal Data is collected and processed by:

  • Swappa Electronics Ltd, a company registered in Kenya.
  • Registered office: Nairobi, Kenya.

Protecting your privacy is fundamental to us. We are committed to handling your Personal Data in line with the Kenya Data Protection Act, 2019 and the guidance of the Office of the Data Protection Commissioner (ODPC).

Why do we use your personal data?

We collect and use your Personal Data for the following main purposes:

2.1 Providing the services offered on the Store

  • Giving you access to and letting you browse the Store.
  • Managing the orders you place and any trade-in offers you request.
  • Running our customer care and after-sales service. We may contact you by email, phone or SMS (including automated SMS) to help with your account, an order or a trade-in, as permitted by law.
  • Creating and letting you sign in to your customer account.
  • Processing payments (including M-Pesa and card), trade-in payouts, and any payment-related claims.
  • Providing optional add-on services such as device protection plans.

2.2 Marketing and sales activities

  • Sending you newsletters and offers where you have chosen to receive them.
  • Showing you personalised content and offers based on your interests and browsing.
  • Measuring and improving our advertising with our partners, and building marketing audiences on social platforms.
  • Running promotions, contests and referral or student programmes.
  • Analysing our customer base to understand our customers better and tailor our offers.

2.3 Improving our services

  • Producing statistics on how the Store is used and analysing browsing behaviour to improve it.
  • Recording calls, messages and chats with our customer care to train our team and improve our service.
  • Running surveys and collecting reviews and feedback.

2.4 Preventing and fighting fraud and security incidents

  • Detecting and preventing fraud.
  • Verifying your identity when handling certain claims (for example a lost or damaged parcel), either manually or with a trusted verification provider. Where biometric checks are used, we rely on your consent.
  • Preventing and managing security incidents and other unlawful activity on the Store.

2.5 Meeting legal and tax obligations

  • Managing disputes and legal claims.
  • Meeting our accounting and record-keeping obligations.
  • Handling requests to our Data Protection Officer about your rights.
  • Reporting to the relevant tax authorities in connection with the Trade-in service where required.

What personal data do we collect?

Data collected through the Store. We collect and process your Personal Data when you create or update your account, place an order or use the Trade-in service, contact our customer care, take part in a promotion or contest, or leave a review. Some data is also collected automatically as you browse, in particular through Cookies. This includes:

  • your name, email address, phone number, delivery address and billing address;
  • your payment details — note that only our payment provider sees your full card details;
  • your order information and history;
  • the unique identifiers (such as IMEI or serial number) of devices you buy or trade in;
  • data about your connection and browsing on the Store (such as IP address and pages viewed);
  • information you give us in promotions, surveys or contests;
  • your reviews, comments, messages and claims;
  • recordings of your calls to customer care, unless you object;
  • results from our fraud-detection checks.

If you use our Trade-in service, we also collect the details needed to pay you and to meet tax rules — such as your name, National ID and, where the law requires it above a set threshold, your KRA PIN. We may hold a payout if you do not provide correct, complete and matching details.

Where a transaction is blocked by our anti-fraud checks, or where there is a dispute about delivery, we may ask for a copy of your ID and other supporting documents (such as proof of address or a signed declaration) so that we and our shipping partner can assess the situation. To speed this up, we may offer a live identity check handled by a trusted provider, which compares your ID with a short selfie video; this uses your biometric data and relies on your consent. If you prefer not to use it, we will offer an alternative.

Data collected through Social Login. If you create or sign in to your account using Google or Apple, they share your email address (and sometimes your name) so we can set up or connect your account.

Data from other sources. As part of fraud prevention, we may receive additional information about you from verification providers and cross-check it with what we already hold.

How long do we keep your personal data?

We keep your Personal Data only for as long as needed for the purposes described in this Policy, in line with the Kenya Data Protection Act, 2019. After that we delete or anonymise it, unless the law requires or allows us to keep it longer (for example to meet legal, tax or accounting obligations).

Who do we share your personal data with?

Whenever data is shared, we take the steps needed to keep it secure and confidential, in line with applicable data-protection law. We may share your data with:

  • Refurbishment and repair partners — the data needed to prepare, repair or inspect a device connected to your order or trade-in.
  • Couriers and logistics partners — the data needed to deliver or collect your device.
  • Insurers and brokers — where you take out a protection plan, the data needed to arrange and manage it.
  • Payment providers — including M-Pesa and card processors, to take payment securely and pay out trade-ins.
  • Service providers acting for us — such as customer care, fraud prevention, analytics, marketing and IT/hosting providers. They may only access the data needed for their task and may not use it for anything else.
  • Authorities — where required by law or by a decision of a regulator or court.
  • Advertising and social partners — to measure our campaigns and build marketing audiences.

We do not sell your Personal Data. You can object to the use of your data for advertising at any time by changing your Cookies settings through the “Cookies” link at the bottom of the Store. For more detail, see our Cookies Policy.

What are your rights regarding your personal data?

Your rights. You may request access to your Personal Data and its correction or, where appropriate, deletion. In certain cases you may also object to processing, ask us to restrict it, or ask for data portability, subject to the conditions in the law.

How to exercise your rights. You can, at any time:

  • delete your account from the “My profile” section of your account;
  • stop marketing messages using the “unsubscribe” link in any promotional email, or by changing your preferences in “My profile”;
  • change your Cookies preferences using the “Cookies” link at the bottom of the Store;
  • view and update your account details (contact, billing and delivery addresses) in “My profile”;
  • object to a call being recorded when you contact customer care;
  • send comments to our customer care if one of your transactions was blocked by our anti-fraud checks.

You can also exercise your rights, or ask us any question about how we use your data, by contacting us through our contact page or by writing to Swappa Electronics Ltd, Data Protection Officer, Nairobi, Kenya. Please give your full name and the email address linked to your account. If we have reasonable doubt about your identity, we may ask for a copy of an official ID. You also have the right to lodge a complaint with the Office of the Data Protection Commissioner (ODPC).

Policy updates

We may update this Policy from time to time, in particular to reflect changes in the law, regulation or technology. The current version is always available on the Store.

Personal data glossary

Cookie a small file or tracker placed on your device and read when you browse the Store, open an email or use an app, whatever the device.
Data Protection Officer the person within Swappa Electronics responsible for making sure we handle your Personal Data in line with the law.
Personal Data information that can identify you, directly or indirectly — such as your name, contact details, customer number, image, voice or IP address.
Purpose the reason we use your Personal Data — the “why” behind the processing.
Processing any operation carried out on Personal Data, from collecting it to using, storing, sharing or deleting it.
Store our online shop and its related pages operated by Swappa Electronics.