Etterx Limited · Legal
Privacy Policy
Last updated: 19 October 2026 · Nairobi, Kenya
1. Introduction & who we are
Etterx Limited is based in Nairobi, Kenya. This policy explains how we handle personal data on our website, in our engineering services and through EtterxConnect under the Kenya Data Protection Act, 2019 and applicable regulations. For website enquiries and our own account administration, Etterx is a data controller. For customer messaging data, we normally act as a data processor. Contact business@etterx.com or +254 706 330 465.
2. Information we collect
We collect contact details and enquiry content you provide, including name, company, email address, phone number and project information. EtterxConnect account data may include profile details, credentials, billing information and support requests. On customers’ instructions, we process WhatsApp Business numbers, recipient identifiers, message content where needed for delivery or chatbot operations, and message metadata such as timestamps and delivery status. Usage data may include IP address, device and browser information, page activity, diagnostics and cookie identifiers.
3. How we use information
We use information to respond to enquiries, deliver and maintain services, administer accounts, process payments, provide support, route messages, operate customer-configured chatbots, secure systems and comply with legal obligations. We use service diagnostics to improve reliability. Marketing communications require an appropriate lawful basis and include a way to opt out. We do not use customer messaging data for unrelated purposes without a lawful basis and appropriate instructions.
4. Legal basis for processing
Depending on the activity, processing relies on your consent, steps at your request before a contract or performance of a contract, compliance with legal obligations, or legitimate interests such as fraud prevention and service security, balanced against your rights. Where consent is required, you may withdraw it without affecting prior lawful processing. Sensitive personal data receives the additional protections and conditions required by Kenyan law.
5. WhatsApp / Meta data processing
Customers remain data controllers for their messaging data and are responsible for lawful collection, appropriate notices, recipient opt-in and lawful chatbot instructions. Etterx acts as a processor, using that data only on documented customer instructions, subject to our agreements and legal obligations. Meta’s WhatsApp Business terms and privacy policies also apply; Meta may process data in its own capacity. We assist customers with rights requests and security obligations where applicable. Contact the business you messaged first for requests about its conversations; we will support the controller.
6. Sharing with third parties
We do not sell personal data. We may share necessary information with authorised cloud hosting and infrastructure providers, messaging platforms such as Meta, payment providers such as M-Pesa, analytics providers where used, and professional advisers. Providers receive access limited to their role and are subject to appropriate confidentiality and data protection arrangements. We may disclose information where legally required or to protect rights and prevent unlawful activity. Customer messaging data is shared only as authorised by the customer or required by law.
7. International data transfers
Some service providers may process data outside Kenya. Before such transfers, we assess the destination and apply safeguards required by Kenyan law, including adequate protection, appropriate contractual commitments or another permitted transfer basis. Where consent or additional conditions are required, we obtain or meet them. Contact us for information about safeguards relevant to your data.
8. Data retention
We keep personal data only for as long as reasonably necessary for the purposes described here, relevant contracts and legal obligations. Enquiries are retained while being handled and for an appropriate follow-up period; account records for the account relationship and necessary legal or accounting periods. Customer messaging retention follows documented customer instructions and agreed service settings. When retention ends, data is deleted or anonymised; backups expire through their normal secure lifecycle. Some records may be retained for legal claims or statutory requirements.
9. Data security
We apply appropriate technical and organisational safeguards, including access controls, least-privilege access, encryption where appropriate, monitoring and secure operational practices. No system can guarantee absolute security. We assess suspected incidents and notify the relevant controller, the Office of the Data Protection Commissioner and affected individuals when required by law, within applicable statutory timeframes.
10. Your rights
Subject to applicable legal limits, you may request access to your data, correction of inaccurate information, deletion, objection to processing, restriction where applicable and portability. You may withdraw consent and ask how your data is used. We verify identity proportionately and respond within applicable legal timeframes. For customer messaging data, direct your request to the relevant customer/controller. You may complain to the Office of the Data Protection Commissioner, Kenya, at https://www.odpc.go.ke. Contacting us first does not limit that right.
11. Cookies
Essential cookies or similar storage may support security and necessary service operation. Non-essential analytics or advertising cookies, if introduced, require appropriate information and consent before activation where required. You can manage cookies through browser settings and any consent controls provided. Disabling essential storage may affect account functionality. This policy does not itself activate analytics or tracking cookies.
12. Children’s privacy
Our website and EtterxConnect are intended for businesses and adults, not children under 18. We do not knowingly collect children’s personal data for our own purposes without appropriate parental or guardian consent and safeguards required by law. Customers must ensure lawful handling of any children’s data they instruct us to process. Contact us if you believe a child’s information has been provided improperly.
13. Changes to this policy
We may update this policy when our services, practices or legal requirements change. The last-updated date identifies the current version. We will provide additional notice of material changes where required, and obtain fresh consent where necessary.
14. Contact us
For privacy questions or rights requests, contact Etterx Limited, Nairobi, Kenya: business@etterx.com; +254 706 330 465. Please describe your request without sending unnecessary sensitive information. If the request relates to messages sent to one of our customers, identify that business so we can direct or assist the request appropriately.