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Privacy Policy

Last updated: 27 June 2025

Kumsai LTD (doing business as "Mara Hilltop", "we", "our", "us") respects your privacy. This Policy explains how we collect, use, disclose, and protect personal data when you interact with our WhatsApp guest-concierge service and marahilltop.com (together, the "Services").

1. Who we are

Kumsai LTD

Three Bees Complex, opposite Drifield Kenya Ltd,

Maasai Road, off ICD Road, off Main Mombasa Road,

P.O. Box 18095-00500, Nairobi, Kenya

KRA PIN P051847757C

Email: nj@marahilltop.com

Tel: +254 713 290 093

For EU/UK GDPR matters, we act as the data controller.
For California residents, we comply with the California Consumer Privacy Act (CCPA).

Our Data-Protection Officer can be reached at nj@marahilltop.com.

2. Information we collect

CategoryDetailsSource
IdentificationName, phone number, nationality, age-rangeYou
Booking detailsCheck-in/out dates, room type, special requestsYou / booking engine
Conversation contentMessages you send to the bot, feedback formsYou
Technical dataWhatsApp metadata (timestamps, device type), IP address when using our websiteAutomatic

We do not knowingly collect data from children under 18 and the Services are not intended for them. If you are 15-17 and use the concierge, please obtain a parent or guardian's consent.

3. Why we process your data

PurposeLegal basis (GDPR)
Provide, confirm, or modify your lodging reservationContract performance
Respond to questions / guest supportContract performance
Send arrival, departure, or safety noticesLegitimate interest
Improve Services & prevent fraudLegitimate interest
Meet legal / tax obligationsLegal obligation
Marketing messages only if you opt-inConsent

4. Sharing of data

We share necessary data with trusted processors:

  • Property-management / booking-engine provider (stores your reservation)
  • Cloud hosting & analytics services (secure message processing)

All processors are bound by confidentiality and data-protection agreements. We do not sell your personal information.

5. International transfers

Data may be transferred outside Kenya (e.g., EU/US). We use safeguards such as Standard Contractual Clauses (SCCs) or adequacy decisions where required.

6. Retention

Chat transcripts and booking data are kept for 12 months after check-out, then deleted or anonymised unless we must keep them longer to resolve disputes or comply with the law.

7. Your rights

EU/UK residents (GDPR)

You may access, correct, erase, restrict, object, or request portability of your data, or lodge a complaint with your supervisory authority.

California residents (CCPA/CPRA)

You have the right to know, delete, correct, and opt-out of "sharing" for cross-context advertising. We will not discriminate against you for exercising CCPA rights.

To exercise any right, email nj@marahilltop.com or write to our postal address.

8. Security

We employ TLS encryption in transit, role-based access controls, and annual penetration testing. No method is 100% secure, but we take commercially reasonable measures to protect your data.

9. Changes

We may update this Policy from time to time. Material changes will be posted 14 days before they take effect.

10. Contact

Questions? Email nj@marahilltop.com or call +254 713 290 093 (Kenya).