Privacy Policy

Last updated: 01/02/2026

Pamoja Safeguarding (“we”, “us”, “our”) is committed to protecting your privacy. This Privacy Policy explains how we
collect, use, store, and protect personal data under the Kenya Data Protection Act, 2019 and, where
applicable, the UK GDPR.

1. Who We Are

Pamoja Safeguarding provides counselling, mental wellbeing, and safeguarding services.

Base of operations: Kenya
Data Controller: Pamoja Safeguarding
Contact: pamojamentalhealth@pamojasafeguarding.com
Website: pamojasafeguarding.com

2. Personal Data We Collect

Information you provide

Name
Email address
Phone number
Organisation (if applicable)
Information you submit via forms, email, or other enquiries

Special category data

If you engage with counselling or safeguarding-related services, you may share sensitive personal data (for example,
wellbeing or health-related information). We only process this where strictly necessary and with appropriate safeguards.

Technical data (including analytics)

IP address (may be processed by our analytics tools)
Browser type and version
Device and operating system
Pages visited, session duration, and interactions with the site
Approximate location (derived from IP address)

3. How We Use Your Data

We use your data to:

Respond to enquiries and requests
Provide counselling, wellbeing, and safeguarding services
Communicate with you about services or updates you request
Maintain, secure, and improve our website
Measure website performance and usage via Google Analytics
Comply with legal and safeguarding obligations

We do not sell your personal data.

4. Legal Bases for Processing

Under applicable data protection laws, we rely on the following lawful bases (as relevant):

Consent – where you provide it (e.g. submitting an enquiry form). You can withdraw consent at any time.
Contract / service provision – where processing is necessary to provide requested services.
Legal obligation – where we must comply with legal or safeguarding duties.
Legitimate interests – to operate, secure, and improve our website and services, where these interests do not override your rights.

For special category data, we process it only with explicit consent or where legally permitted/required
for safeguarding and service provision.

5. Google Analytics

We use Google Analytics to understand how visitors use our website and to help us improve it. Google
Analytics may collect information such as your IP address (which may be truncated or processed in a manner configured by
the site owner), device information, and your interactions with the site.

Google may process this data on our behalf as a service provider. Google may store or process data outside of Kenya and
outside of the UK/EU depending on its infrastructure.

Opt-out options: You can use browser settings to block cookies (see Cookies section below). You can also
use Google’s opt-out tools where available (for example, the Google Analytics opt-out browser add-on).

6. Cookies

Cookies are small files stored on your device. We use cookies that are necessary for site operation and, where enabled,
analytics cookies to measure and improve performance (including Google Analytics).

You can control cookies through your browser settings, including blocking or deleting cookies. If you disable cookies,
some parts of the site may not function as intended.

7. International Data Transfers

Personal data may be transferred to and processed in Kenya. If UK/EU personal data is involved, Kenya is
not currently recognised as an adequacy country under UK GDPR. We apply appropriate safeguards, including:

Secure hosting and encrypted connections where available (e.g. HTTPS)
Access controls and confidentiality procedures
Data minimisation (only collecting what is necessary)

Where third-party providers (such as Google) process data internationally, those transfers are governed by their
applicable safeguards and contractual terms.

8. How We Store and Protect Your Data

We store data securely and restrict access to authorised persons only.
We use appropriate technical and organisational measures to protect personal data.
We retain personal data only for as long as necessary for the purpose it was collected, or as required by law.

9. Sharing Your Data

We may share personal data only where necessary:

With trusted service providers (e.g. website hosting, email services, analytics providers such as Google Analytics)
Where required by law, regulation, or safeguarding obligations

We require service providers to protect personal data and use it only for the services they provide to us.

10. Your Rights

Depending on your location and applicable law, you may have the right to:

Access your personal data
Request correction of inaccurate data
Request deletion/erasure (where applicable)
Object to or restrict processing
Request data portability (where applicable)
Withdraw consent at any time (where processing is based on consent)

To exercise your rights, contact us using the details above.

11. Complaints

Kenya: You may lodge a complaint with the Office of the Data Protection Commissioner (ODPC):
https://www.odpc.go.ke

UK (if applicable): You may also complain to the Information Commissioner’s Office (ICO):
https://www.ico.org.uk

12. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated revision date.