Privacy Policy

WORKKE PRIVACY POLICY

Effective Date: July 16, 2025

Last Updated: August 10, 2026

1. Introduction

WorkKE ("WorkKE", "we", "our", or "us") respects your privacy and is committed to protecting personal information entrusted to us.

This Privacy Policy explains how WorkKE collects, uses, stores, shares, protects, and otherwise processes personal data when you access or use the WorkKE website, mobile applications, marketplace, Digital Stores, messaging services, payment and wallet features, training services, digital tools, and related services collectively referred to as the "Platform."

This Policy applies to Clients, freelancers, Vendors, merchants, cybercafés, Digital Store operators, buyers, trainers, businesses, and other Users of WorkKE.

WorkKE processes personal data in accordance with applicable data protection requirements, including the Kenya Data Protection Act, 2019 and applicable regulations.

By accessing or using WorkKE, you acknowledge the data-processing practices described in this Policy.

Where consent is required for a particular processing activity, WorkKE will seek appropriate consent.

2. Information We Collect

The information we collect depends on how you use WorkKE.

2.1 Personal and Contact Information

We may collect:

• full name;
• email address;
• mobile phone number;
• physical or postal address;
• date of birth where required;
• profile photograph;
• country or general location;
• preferred communication information; and
• other information you voluntarily provide.

2.2 Identity Verification Information

Where identity or business verification is required, we may collect:

• National ID or Passport details;
• selfie or live identity-verification information;
• verified mobile phone number;
• verified email address;
• KRA PIN;
• business registration information;
• Certificate of Incorporation or Registration;
• proof of address;
• bank or M-PESA verification information; and
• other information reasonably required for identity, security, fraud-prevention, payment, or regulatory purposes.

Some identity-verification services may be provided by approved third parties.

2.3 Account and Profile Information

We may collect information associated with your WorkKE account, including:

• username;
• profile details;
• biography;
• skills;
• work experience;
• portfolio information;
• service categories;
• business information;
• Store information;
• account preferences;
• verification status;
• ratings and reviews;
• transaction history;
• saved settings; and
• account status.

3. Marketplace and Freelance Activity

When you participate in the WorkKE marketplace, we may process information relating to:

• jobs posted;
• proposals submitted;
• jobs applied for;
• project awards;
• contracts;
• milestones;
• project requirements;
• project files;
• work submissions;
• order activity;
• transaction status;
• communications between Users;
• disputes;
• reviews and ratings; and
• marketplace activity.

This information may be necessary to operate the marketplace, support transactions, investigate disputes, prevent fraud, and enforce WorkKE policies.

4. Digital Stores and Product Information

Where you operate, browse, purchase from, or interact with a WorkKE Digital Store, we may process information relating to:

• Store ownership and administration;
• product listings;
• product descriptions;
• product categories;
• prices;
• orders;
• purchases;
• digital deliveries;
• download availability;
• access activity;
• product reviews;
• refunds;
• disputes;
• intellectual property complaints; and
• Store performance and marketplace activity.

For digital products, WorkKE may maintain technical records showing whether a digital product was made available, accessed, delivered, or downloaded.

These records may be used for customer support, fraud prevention, payment administration, intellectual property investigations, and dispute resolution.

5. Payment and Wallet Information

When you use WorkKE payment, wallet, escrow, deposit, withdrawal, or payout services, we may process information including:

• M-PESA transaction references;
• payment references;
• wallet balances and activity;
• deposits;
• transaction history;
• payout history;
• withdrawals;
• refunds;
• reversals;
• chargebacks;
• bank account information;
• mobile-money information;
• transaction amounts;
• transaction status; and
• payment-provider information.

WorkKE may use approved third-party payment providers to process payments.

For security reasons, WorkKE does not store full debit or credit card details where those details are handled directly by the relevant payment provider.

Payment providers may process personal information under their own applicable privacy and security requirements.

6. Communications and Messages

When you communicate through WorkKE, we may process:

• messages;
• attachments;
• sender and recipient information;
• timestamps;
• job or transaction associations;
• moderation information; and
• other communication metadata.

Messages may be processed where reasonably necessary to:

• provide WorkKE messaging services;
• protect Users;
• resolve disputes;
• prevent fraud;
• investigate abuse;
• detect attempted marketplace circumvention;
• enforce Platform rules; and
• maintain marketplace integrity.

Users should avoid sharing unnecessary sensitive personal information through Platform communications.

7. Contact Guard and Marketplace Moderation

WorkKE may use automated and manual systems to identify possible attempts to share prohibited Contact Information, move transactions outside WorkKE, circumvent marketplace fees, or violate WorkKE policies.

These systems may analyse Content submitted through Platform areas including:

• messages;
• job descriptions;
• proposals;
• product descriptions;
• Store listings; and
• other relevant marketplace Content.

Detection may include potential:

• phone numbers;
• email addresses;
• disguised Contact Information;
• WhatsApp or Telegram details;
• direct payment requests;
• suspicious links;
• attempts to bypass WorkKE escrow or payments; and
• other potential policy violations.

Where relevant Content is detected, WorkKE may:

• display a warning;
• flag the Content;
• mask certain information;
• replace information with a notice such as "[contact hidden]";
• maintain a moderation record; or
• refer the activity for review.

7.1 Moderation Records

For security, fraud prevention, appeals, dispute resolution, policy enforcement, and audit purposes, moderation records may include:

• original submitted Content;
• moderated Content;
• sender information;
• recipient information where applicable;
• detection reason;
• severity or classification;
• timestamps;
• relevant marketplace surface;
• warnings;
• previous policy violations;
• account restrictions; and
• actions taken by WorkKE.

Access to original moderated Content is limited to persons who require such access for legitimate operational, security, support, legal, fraud-prevention, dispute, or compliance purposes.

WorkKE will not retain moderation information indefinitely merely because it was flagged. Retention is subject to WorkKE's applicable retention requirements and the purposes for which the information is required.

8. Automated Processing and Decision-Making

WorkKE may use automated technologies to assist with:

• fraud detection;
• suspicious-transaction detection;
• Contact Guard;
• spam prevention;
• account security;
• risk assessment;
• identity-verification support;
• prohibited-Content detection;
• marketplace integrity; and
• Platform moderation.

Automated systems may flag activity for action or human review.

Where a decision is made solely through automated processing and produces legal effects or similarly significantly affects a User, WorkKE will apply the protections required by applicable law.

Where applicable, Users may request:

• information about the relevant automated processing;
• human review;
• reconsideration of an applicable decision; or
• correction of an incorrect decision.

Kenyan law specifically protects data subjects from certain decisions based solely on automated processing and provides mechanisms for notification and reconsideration. The General Regulations additionally require safeguards including meaningful information about the logic involved, error prevention, measures to minimize inaccuracies, and the ability to obtain human intervention.

9. Technical and Device Information

When you use WorkKE, we may automatically collect technical information such as:

• IP address;
• browser type;
• operating system;
• device type;
• device identifiers;
• session information;
• login information;
• timestamps;
• referring pages;
• error logs;
• system logs;
• security events; and
• technical performance data.

This information helps WorkKE maintain Platform security, diagnose technical problems, prevent fraud, and improve reliability.

10. Usage Information

We may process information about how Users interact with WorkKE, including:

• pages visited;
• features used;
• searches performed;
• listings viewed;
• jobs posted;
• jobs applied for;
• proposals submitted;
• products viewed;
• products purchased;
• Store activity;
• messages exchanged;
• support requests;
• downloads;
• account activity; and
• interactions with Platform features.

Where appropriate, information may be aggregated or anonymised for analytics and service improvement.

11. Customer Support Information

When you contact WorkKE support, we may process:

• your name and contact information;
• account information;
• support messages;
• screenshots;
• attachments;
• transaction information;
• dispute information;
• technical logs; and
• other information needed to investigate your request.

Support interactions may be retained where reasonably necessary for customer service, security, dispute resolution, training, audit, and legal purposes.

12. How We Use Personal Information

WorkKE may process personal information to:

• create and administer accounts;
• authenticate Users;
• verify identities;
• manage Vendor and Store accounts;
• facilitate marketplace transactions;
• facilitate Digital Store purchases;
• deliver digital products;
• process payments and payouts;
• maintain wallet activity;
• administer escrow or transaction protections;
• provide Platform messaging;
• provide customer support;
• detect and prevent fraud;
• protect accounts;
• detect marketplace circumvention;
• moderate Content;
• enforce WorkKE policies;
• process disputes and refunds;
• respond to intellectual property complaints;
• prevent misuse of the Platform;
• improve Platform functionality;
• diagnose technical problems;
• conduct permitted analytics;
• communicate important service information;
• comply with legal requirements; and
• establish, exercise, or defend legal claims.

WorkKE applies data-protection principles including limiting processing to appropriate purposes and retaining personal data only as reasonably necessary.

13. Legal Bases for Processing

Depending on the nature of the processing and applicable law, WorkKE may rely on one or more lawful bases, including:

Performance of a Contract

Processing may be necessary to provide services requested by you, operate your account, process marketplace transactions, deliver products, administer payments, or otherwise perform our agreement with you.

Legal Obligations

Processing may be necessary to comply with applicable laws, regulatory requirements, lawful requests, tax requirements, fraud-prevention obligations, or other legal duties.

Legitimate Interests

Where permitted by applicable law, WorkKE may process information for legitimate interests such as:

• Platform security;
• fraud prevention;
• protecting Users;
• preventing marketplace abuse;
• improving services;
• customer support;
• dispute resolution; and
• protecting WorkKE's legal and commercial interests.

WorkKE will consider applicable User rights when relying on legitimate interests.

Consent

Where required, WorkKE may process personal information based on your consent.

Where processing relies on consent, you may withdraw that consent subject to applicable law and the nature of the processing.

14. Information We Share

WorkKE does not sell or rent personal information as a business practice.

We may disclose information where reasonably necessary to:

Payment Providers

For payment processing, refunds, payouts, fraud prevention, transaction investigation, or related financial services.

Identity and Verification Providers

For identity verification, fraud prevention, and account security.

Hosting and Technology Providers

For hosting, infrastructure, storage, messaging, analytics, security, technical support, and Platform operations.

Clients, Vendors and Marketplace Users

Limited information may be made available where necessary for Users to transact, communicate, deliver products or services, or participate in the marketplace.

Professional Advisers

Information may be shared with lawyers, auditors, accountants, insurers, or other professional advisers where reasonably necessary.

Regulators and Authorities

Information may be disclosed to courts, regulators, government authorities, law enforcement, or other authorized bodies where:

• legally required;
• necessary to comply with lawful requests;
• necessary to protect legal rights; or
• reasonably necessary to investigate suspected unlawful activity.

Corporate Transactions

Where WorkKE undergoes a merger, acquisition, restructuring, financing, sale, or transfer of all or part of its business, information may be transferred subject to applicable data-protection requirements.

Routine personal-data sharing arrangements should be supported by appropriate safeguards and agreements under Kenya's General Regulations.

15. Public Marketplace Information

Some information submitted to WorkKE is intended to be publicly visible.

Depending on how you use the Platform, this may include:

• profile name;
• profile photograph;
• skills;
• portfolio;
• services;
• Vendor information;
• Store name;
• Store Content;
• product listings;
• ratings;
• reviews; and
• other information that you intentionally publish.

Users should not publish information they do not want publicly available.

WorkKE may restrict certain personal Contact Information from public marketplace areas for privacy, safety, fraud prevention, or marketplace-protection purposes.

16. Cookies and Similar Technologies

WorkKE may use cookies and similar technologies to:

• keep Users signed in;
• maintain sessions;
• remember preferences;
• provide security features;
• prevent fraud;
• understand Platform usage;
• improve performance; and
• personalize applicable Platform functionality.

Where legally required, consent will be sought for applicable non-essential cookies.

Users may manage cookies through their browser or available Platform controls. Disabling essential cookies may affect Platform functionality.

17. Marketing Communications

Where permitted by applicable law, WorkKE may send Users information about:

• Platform features;
• marketplace opportunities;
• Digital Store features;
• training;
• promotions;
• products; or
• other WorkKE services.

Where required, marketing communications will be based on appropriate consent or another lawful basis.

Users may opt out of eligible marketing communications using available unsubscribe or preference-management mechanisms.

Opting out of marketing does not prevent WorkKE from sending necessary service, account, transaction, security, payment, or legal communications.

18. Data Security

WorkKE implements reasonable administrative, organisational, and technical measures designed to protect personal information against:

• unauthorized access;
• unlawful disclosure;
• loss;
• alteration;
• misuse;
• destruction; and
• unauthorized processing.

Measures may include, where appropriate:

• access controls;
• authentication;
• encryption;
• security logging;
• infrastructure safeguards;
• role-based permissions;
• monitoring;
• secure payment integrations;
• security testing; and
• incident-response procedures.

No internet-based system can guarantee absolute security.

Users are responsible for protecting their account credentials and should promptly notify WorkKE of suspected unauthorized account activity.

19. Personal Data Breaches

Where WorkKE becomes aware of a personal-data security incident, we may:

• investigate the incident;
• take measures to contain or mitigate it;
• determine affected information and Users;
• preserve appropriate evidence;
• notify applicable authorities where required;
• notify affected Users where required; and
• take measures intended to prevent recurrence.

Any required notifications will be handled in accordance with applicable data-protection requirements.

20. Data Retention

WorkKE retains personal information only for as long as reasonably necessary for the purpose for which it is processed, subject to applicable legal and operational requirements.

Retention periods may depend on factors such as:

• account status;
• transaction history;
• payment requirements;
• dispute status;
• fraud risk;
• security investigations;
• identity-verification requirements;
• legal requirements;
• tax or accounting obligations;
• intellectual property claims;
• moderation investigations; and
• establishment or defence of legal claims.

Different categories of data may therefore have different retention periods.

When information is no longer reasonably required, WorkKE may:

• securely delete it;
• anonymise it;
• pseudonymise it; or
• otherwise dispose of it appropriately.

Kenya's General Regulations require controllers and processors to establish retention schedules with appropriate review periods and to delete, anonymise, or pseudonymise information when its processing purpose has expired, subject to lawful exceptions.

21. International Data Transfers

WorkKE may use technology, cloud, payment, verification, or other service providers that process personal information outside Kenya.

Where personal information is transferred outside Kenya, WorkKE will take measures required by applicable law to ensure the transfer is subject to appropriate safeguards.

Depending on the circumstances, those safeguards may involve:

• adequacy protections;
• appropriate contractual safeguards;
• applicable consent where legally permitted;
• legal necessity; or
• other transfer mechanisms authorized by applicable law.

International transfers of personal information are subject to specific requirements under Kenya's data-protection framework.

22. Your Data Protection Rights

Subject to applicable law and relevant exemptions, Users may have rights including the right to:

• be informed about processing of their personal data;
• access their personal data;
• request correction of inaccurate information;
• request completion of incomplete information;
• request deletion or erasure where applicable;
• object to certain processing;
• request restriction of certain processing;
• receive personal data in an applicable portable format;
• withdraw consent where consent is the relevant lawful basis;
• request applicable human review of qualifying automated decisions; and
• lodge a complaint with the Office of the Data Protection Commissioner.

The ODPC identifies access, rectification, erasure, portability, objection and restriction among the rights available to data subjects.

Some rights are subject to legal exceptions. For example, deletion may not be available where information must be retained to comply with a legal obligation or establish, exercise, or defend a legal claim.

WorkKE may verify your identity before processing a data-rights request to prevent unauthorized disclosure or alteration of personal information.

23. Children's Privacy

WorkKE is not intended to be used independently by children under thirteen (13).

Users aged between thirteen (13) and eighteen (18) may only use WorkKE in accordance with applicable WorkKE eligibility requirements and with appropriate consent and supervision of a parent or legal guardian where required.

WorkKE may apply additional safeguards to personal information relating to children.

Where WorkKE learns that personal information relating to a child has been collected or processed contrary to applicable law or Platform requirements, WorkKE may restrict the applicable account and take appropriate steps regarding the information.

24. Third-Party Websites and Services

WorkKE may contain integrations or links to third-party services, including:

• payment providers;
• portfolio platforms;
• professional networks;
• file-sharing tools;
• design tools;
• source-code platforms; and
• other services used in marketplace transactions.

WorkKE does not control the independent privacy practices of third-party services.

Users should review applicable privacy policies before providing personal information directly to third parties.

25. Changes to This Privacy Policy

WorkKE may update this Privacy Policy to reflect changes in:

• applicable law;
• regulatory guidance;
• Platform functionality;
• Digital Stores;
• payment systems;
• security practices;
• moderation systems;
• automated technologies; or
• business operations.

The Last Updated date at the beginning of this Policy will show when it was most recently revised.

Where appropriate or legally required, material changes may be communicated through:

• the Platform;
• email;
• account notifications; or
• another reasonable method.

26. Privacy Requests and Complaints

Users may contact WorkKE regarding:

• access requests;
• corrections;
• deletion requests;
• data portability;
• objections;
• processing restrictions;
• consent withdrawal;
• automated-decision review;
• privacy complaints;
• suspected privacy incidents; or
• questions about this Policy.

WorkKE may request reasonable information necessary to verify the identity of the person making the request.

Users also have the right to lodge applicable complaints with the Office of the Data Protection Commissioner (ODPC).

27. Contact Us

For questions, concerns, complaints, or requests concerning personal information or this Privacy Policy:

WorkKE

Privacy & Data Protection

Email: contact@workke.co.ke

Phone: +254 706 188 133

Postal Address: P.O. Box 1196-40200, Kenya

Website: www.workke.co.ke

Our Commitment to Privacy

WorkKE is committed to handling personal information responsibly and maintaining a secure and trusted marketplace.

As WorkKE develops new marketplace, Digital Store, payment, communication, training, and technology features, we will continue reviewing our privacy and security practices and updating this Policy where appropriate.