Privacy Policy

Smart. Safe. Seamless.

1

Introduction & Overview

This Privacy Policy outlines how Safiri by Citrus ("the Platform") collects, processes, stores, and protects personal and other data from users of the Parent/Student account. The purpose of this Policy is to ensure transparency in our data practices and to affirm our commitment to protecting the privacy of parents, guardians, and students who use our school transport platform.

Compliance with Kenyan Data Protection Laws

This Policy complies with Kenyan Data Protection laws, including the Data Protection Act (2025), as well as any other applicable regulations. It applies exclusively to users of the Parent/Student account.

Real-time Visibility and Control

Our platform is designed to provide real-time visibility and control over school transport, including live bus tracking, transport schedule notifications, secure communication with school administrators and drivers, and student safety monitoring.

2

Definitions

For clarity and consistency throughout this Policy, the following terms are defined:

Personal Data

Any information relating to an identified or identifiable natural person, such as names, contact details, and location data.

Processing

Any operation performed on personal data, including collection, recording, storage, organization, modification, retrieval, consultation, use, disclosure, or deletion.

Data Subject

Any Parent/Student account user whose personal data is processed by the Platform.

Data Controller

Citrus Labs Limited, which determines the purposes and means of processing personal data.

Data Processor

Any third party engaged by Citrus Labs Limited to process personal data on its behalf.

Sensitive Data

Data that requires special protection under Kenyan law, such as data related to children or other sensitive personal information.

Cookies

Small data files placed on your device to enhance user experience and facilitate tracking of usage patterns.

3

Data Collection

Safiri by Citrus collects the following types of data from Parent/Student account users:

Personal Information

This includes full name, contact details (email address, phone number), child's information (name, grade, school), home address, and any other identification information provided during registration.

Usage Data

Information about how users interact with the Platform, including login timestamps, session durations, feature usage, and activity logs.

Device Information

Data related to the device used to access the Platform, such as IP address, device type, operating system, browser type, and mobile device identifiers.

Cookies and Tracking Data

Information collected via cookies and similar technologies to enhance user experience, remember preferences, and analyze usage patterns.

Sensitive Data

If applicable, any sensitive personal information related to the student (such as special needs or health information) will be processed with additional safeguards in accordance with Kenyan law.

Data may be collected directly from users during account registration, through the use of the Platform, and through automated data collection tools integrated within the Platform.

5

Purpose & Use of Data

Data collected from Parent/Student account users is processed for the following purposes:

Service Delivery

To provide live bus tracking, transport schedule notifications, student safety monitoring, and secure communication with school administrators and drivers.

Customer Support

To address user inquiries, provide technical support, and resolve issues.

System Improvement

To analyze usage data and feedback for continuous enhancement of the Platform's functionality and user experience.

Security

To protect the Platform and its users, including fraud prevention, incident response, and monitoring for unauthorized access.

Compliance

To ensure adherence to legal and regulatory obligations, particularly those related to child safety and data protection.

Marketing & Communication

To send users updates about new features, security alerts, and relevant promotional information, subject to user consent.

6

Data Storage & Security Measures

Data Storage

Personal data is stored on secure, cloud-based servers managed by reputable third-party service providers. The data retention period is determined based on the purposes for which the data is collected and in compliance with applicable legal requirements.

Security Measures

To protect user data, the Platform implements:

Encryption

Data is encrypted in transit and at rest using industry-standard encryption protocols.

Access Controls

Strict access controls and multi-factor authentication are employed to restrict access to personal data.

Regular Audits

Periodic security audits and vulnerability assessments to identify and mitigate risks.

Data Backup

Robust data backup procedures and disaster recovery plans to prevent data loss.

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Data Sharing & Third-Party Disclosures

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User Rights

Parent/Student account users have the following rights regarding their personal data:

Right to Access

The right to request access to the personal data held by Citrus Labs Limited.

Right to Rectification

The right to request correction of any inaccurate or incomplete personal data.

Right to Erasure

The right to request deletion of personal data, subject to legal and contractual constraints.

Right to Restrict Processing

The right to request limitations on the processing of personal data in certain circumstances.

Right to Data Portability

The right to obtain personal data in a structured, commonly used, and machine-readable format.

Right to Object

The right to object to the processing of personal data based on legitimate interests or for direct marketing purposes.

Users may exercise these rights by contacting us using the contact details provided in Section 12.

9

Cookies & Tracking Technologies

Usage of Cookies

The Platform may use cookies and similar tracking technologies to enhance the user experience, remember preferences, analyze usage patterns, and facilitate certain platform functionalities. These technologies collect information about your browsing behavior and help us improve our services.

User Management

Users can manage or disable cookies through their browser settings, though this may affect the functionality of the Platform. Most modern browsers allow you to:

  • View and delete existing cookies
  • Block or allow cookies from specific websites
  • Block third-party cookies
  • Block all cookies (though this may impact functionality)
  • Delete all cookies when you close your browser
10

Data Breach Notification

Detection and Reporting

The Platform employs monitoring systems to detect any data breaches. In the event of a breach, Citrus Labs Limited will promptly investigate and take remedial measures to contain and address the incident.

Notification Procedures

Affected users will be notified of a data breach involving their personal data within 72 hours of discovery, when feasible. Regulatory authorities will be informed in accordance with Kenyan law. The notification will include information about the nature of the breach, potential consequences, and measures taken to address it.

Response Plan

A comprehensive data breach response plan is in place to mitigate potential harm and prevent future breaches. This includes procedures for containing the breach, assessing its impact, notifying affected parties, and implementing corrective measures.

11

Policy Updates

Amendments

Citrus Labs Limited reserves the right to update this Privacy Policy periodically to reflect changes in our practices, legal requirements, or platform functionality. Material changes will be communicated to users via email or through prominent notices on the Platform.

User Acceptance

Continued use of the Platform after any such updates constitutes acceptance of the revised Privacy Policy. We encourage users to review the Privacy Policy periodically to stay informed about how we protect their information.

12

Contact Information and Complaints

For questions, clarifications, or complaints regarding this Privacy Policy, please contact:

Email

legal@citruslabs.co.ke

Mailing Address

P.O. Box 23983 - 00100

Phone

+254 112 400 000

Escalation Process

If you believe your personal data has been mishandled or you wish to escalate a complaint, you may also contact the relevant data protection authority in Kenya.

13

Governing Law & Jurisdiction

Governed by Laws of Kenya

This Privacy Policy and any disputes arising in connection with it shall be governed by and construed in accordance with the laws of Kenya, without regard to its conflict of law principles.

Exclusive Jurisdiction of Courts in Nairobi

Any legal action or proceeding related to this Privacy Policy shall be brought exclusively in the courts of Nairobi, Kenya, and you consent to the personal jurisdiction of such courts.

By using the Safiri by Citrus Platform as a Parent/Student account user, you acknowledge that you have read, understood, and consent to the collection, processing, storage, and sharing of your personal data as described in this Privacy Policy.

Ready to Experience Safiri by Citrus?

With Safiri by Citrus, every detail is engineered to deliver a smart, safe, and seamless school transport experience. Join us today and stay connected with your child's journey every step of the way.