Privacy Policy - Errunned

ERRUNNED PRIVACY POLICY

Effective Date: March 17, 2026

1. INTRODUCTION

Welcome to Errunned LTD. We value your privacy and are committed to protecting your personal data in accordance with the Constitution of Kenya, 2010, and the Data Protection Act, No. 24 of 2019 (DPA).

This Privacy Policy explains how Errunned LTD ("Errunned") collects, uses, discloses, and safeguards your information when you use our mobile application and services. By accessing or using the Errunned platform, you acknowledge that you have read, understood, and agreed to the practices described in this policy. If you do not agree with these terms, please discontinue the use of our services immediately.

2. DEFINITIONS

To ensure absolute clarity, the following terms are defined as per the Kenya Data Protection Act (DPA), 2019:

Data Subject: An identifiable natural person to whom personal data relates. In this context, this refers to you (the Client or the Runner).
Personal Data: Any information relating to an identified or identifiable natural person (e.g., name, phone number, location data).
Sensitive Personal Data: Data revealing a person’s race, health status, ethnic social origin, conscience, belief, genetic data, biometric data, property details, marital status, family details including names of the person’s children, parents, spouse or spouses, sex or the sexual orientation of data subject. For Errunned, this specifically includes your National ID details, biometric verification photos, and criminal record history (Certificate of Good Conduct).
Data Controller: A natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purpose and means of processing of personal data.
Processing: Any operation or set of operations performed on personal data, such as collection, recording, organization, storage, or alteration.

3. IDENTIFICATION OF THE DATA CONTROLLER

Errunned acts as the Data Controller for all personal data collected through the application. This means we are the primary entity responsible for deciding why and how your data is processed.

Entity Name: Errunned
Physical Address: 00100, Nairobi, Kenya.
Data Protection Contact: Designated Privacy Lead
Email: [email protected]
Role: As the Controller, we ensure that all third-party "Data Processors" (such as cloud hosting and payment services) adhere to the strict security standards mandated by Kenyan law.

4. SCOPE OF THE POLICY

This Privacy Policy applies to:

All Users: Anyone who downloads, installs, or uses the Errunned mobile application, or interacts with the associated digital platforms, including the website.
Clients (Task Creators): Users who post tasks and engage Runners.
Runners (Service Providers): Users who fulfill tasks and undergo the verification process.
Interactions: All data generated through the app, including in-app chats, location tracking, payment metadata, and media uploads (evidence photos and gallery profile pictures).

This policy does not apply to the practices of third-party services we do not own or control (e.g., your mobile network provider), although we disclose our data-sharing relationships with them in Section 13.

5. TYPES OF DATA COLLECTED

To facilitate the Errunned marketplace and ensure community safety, we collect several categories of data. In accordance with the DPA, we distinguish between standard personal data and sensitive personal data.

5.1 Personal Data (Standard):

Identity Information: Full name and gender.
Contact Information: Phone number (specifically your M-PESA registered number) and email address.
Profile Data: Username, password (encrypted), self-proclaimed skills, and profile photos. This includes photos uploaded from your device’s gallery or taken directly via the app.
Transaction Data: Details of tasks posted or accepted, product budget and/or service fees paid, and commission deductions.
Technical Data: IP address, device type, operating system, and app usage statistics.

5.2 Sensitive Personal Data: Given the high-trust nature of physical errands, we collect and process sensitive data to verify the integrity of our Runners:

Government Identifiers: National ID number and high-resolution images of the National ID card.
Biometric Verification: Photographs of the Runner holding their National ID to verify facial identity against the document.
Criminal Records: Digital copies of the Certificate of Good Conduct.
Real-Time Geolocation: Precise GPS data (longitude and latitude) captured during active tasks.

5.3 Task-Specific Media and Evidence:

In-App Evidence: Photos or videos taken within the app specifically for task verification, proof of delivery, or to document damaged goods for dispute resolution.
Product Reference Photos: Photos uploaded from the client’s gallery or camera, during task creation, as reference for the runner.
Communication Data: Logs of all messages, instructions, and media exchanged via the in-app chat.

5.4 Explicit Consent for Sensitive Personal Data

By providing sensitive personal data, including National ID documentation, biometric verification images, and criminal record certificates, you expressly and explicitly consent to the collection, use, and processing of such data for identity verification, fraud prevention, and platform safety purposes.

You acknowledge that failure to provide this data may limit or prevent access to certain features of the platform, especially for Runners.

6. HOW DATA IS COLLECTED

We collect data through three primary methods to ensure the "Middleman" model functions securely and transparently.

6.1 Direct Collection (User-Provided):

Registration: Data provided when you create an account, such as your phone number and name.
Verification Flow: Documents and photos uploaded by Runners during the vetting process.
Task Creation & Acceptance: Information provided by Clients when posting a task and by Runners when accepting.
Gallery Access: When you choose to upload a profile/item photo from your gallery, the app accesses only the specific file selected.

6.2 Automated Collection (System-Generated):

Location Tracking: Real-time location tracking is activated when a Runner is actively engaged in a task. This tracking enables Clients to monitor task progress and ensures platform safety. Users retain full control over location permissions and may disable location access at any time through their device settings. Disabling location services may limit or prevent certain core functionalities of the platform.
Check-in Logs: Automated system "pings" that record the Runner’s status and presence during a task window.
App Logs: Automated recording of interactions, errors, and performance metrics to improve app stability.

6.3 Third-Party Collection:

Payment Metadata: We receive transaction confirmation and status updates from Safaricom (M-PESA) when payments are initiated or released from escrow.
Map Interactions: Data generated through interactions with the Google Maps API used for task visualization.
AI Processing Metadata: When creating and classifying tasks our integrated models receive metadata regarding policy violations or content flags

7. PURPOSE OF DATA PROCESSING

We process your data to ensure the marketplace is safe, efficient, and transparent. The specific purposes include:

Facilitating the Marketplace: To connect Clients with suitable Runners based on proximity, availability, and self-proclaimed skills.
Identity Verification: To verify that Runners are who they claim to be, preventing fraud and ensuring community safety and trust through the review of National IDs and Certificates of Good Conduct.
Real-Time Safety & Monitoring: To provide Clients with the live location of their Runner during a task and to trigger the "Flagging" and "Reallocation" protocols if a Runner deviates from the task.
Financial Integrity: To manage the escrow model, process service fee commissions, and manage the Courier Security Bond via M-PESA integration.
Dispute Resolution: To provide an evidence-based resolution process using task creation records, chat logs, GPS history, and in-app media uploads in the event of theft, damage, or "no-shows."
Service Improvement: To analyze app performance and user behavior to refine the UI/UX and optimize the task-matching algorithm.
Security & Fraud Prevention: To detect and prevent "off-platform" transactions, fake accounts, or the use of forged documents.

We are committed to ensuring that user data collection is proportionate, limited to what is strictly necessary, and processed with the highest level of security.

8. LEGAL BASIS FOR PROCESSING DATA

In accordance with Section 30 of the Data Protection Act, 2019, Errunned processes personal data only where a lawful basis exists. Depending on the nature of the data and the purpose of processing, we rely on the following grounds:

8.1 Contractual Necessity

We process personal data where it is necessary to perform our contractual obligations to you. This includes:

Account registration and management
Task creation, matching, and execution
Payment processing and escrow management

8.2 Consent

We rely on your explicit and informed consent for certain processing activities, including:

Accessing your device gallery or camera
Enabling real-time location tracking
Processing sensitive personal data such as biometric verification photos and criminal record documentation

You may withdraw your consent at any time through your device settings or by contacting us, subject to limitations where such data is necessary to provide the service.

8.3 Legal Obligation

We may process your data where required to comply with Kenyan law, including:

Financial record-keeping for tax and audit purposes
Responding to lawful requests by regulatory authorities or law enforcement

8.4 Legitimate Interests

We process certain data where it is necessary for our legitimate business interests, provided such interests do not override your rights and freedoms. These include:

Fraud detection and prevention
Platform security and abuse monitoring
Service improvement and analytics

8.5 Processing of Sensitive Personal Data

Sensitive personal data (including National ID details, biometric verification images, and criminal record information) is processed strictly on the basis of explicit consent and for purposes of identity verification, fraud prevention, and ensuring the safety of users on the platform.

9. DATA SHARING AND DISCLOSURE

Errunned operates as a "matchmaker," which necessitates the sharing of specific information between users to ensure tasks are completed safely and efficiently. We do not sell your data; we only disclose it under the following circumstances:

User-to-User Sharing (The Errand Connection):
- Phone Number Visibility: Once a Runner accepts a task, both the Client and the Runner will be able to see and call each other’s registered phone numbers. This is to facilitate real-time coordination and clarity during the execution of a task. Users agree to use shared contact information solely for purposes related to task execution. Any misuse, including harassment, unsolicited communication, or attempts to conduct transactions outside the platform, is strictly prohibited and may result in account suspension or termination.
- Runner Visibility: Clients will see the Runner’s name, profile photo, self-proclaimed skills, posted reference images, and live GPS location from the moment the task is accepted until completion.
- Client Visibility: Runners will see the Client’s name, task details, posted reference images, and the physical location of the errand or delivery.
Third-Party Service Providers (Data Processors): We engage specialized partners to provide essential technical functions. Each partner is contractually bound to protect your data:
- Authentication & OTP: We use third-party SMS gateways to provide One-Time Passwords (OTPs) for secure account access.
- Financial Services: Transaction metadata is shared with Safaricom (M-PESA) to manage the escrow account and process payouts.
- Infrastructure & Database: Your data is stored on secure, encrypted cloud servers and real-time database providers located in Frankfurt, Germany.
- Media Hosting: All images, including profile photos and evidence uploads, hosted on specialized third-party content delivery networks (CDNs).
- AI & Content Safety: In-app task definitions processed to detect violations of community standards and ensure user safety.
- Mapping: Real-time location and routing are facilitated through industry standard mapping APIs.
Legal Disclosures: We may disclose your data to Kenyan law enforcement or the Office of the Data Protection Commissioner (ODPC) if we believe it is necessary to investigate illegal acts, fraud, or threats to public safety.

10. DATA STORAGE AND RETENTION

We adhere to the principle of "Storage Limitation" under the DPA, ensuring your data is only kept for as long as it serves a valid purpose.

Cross-Border Data Transfers: Errunned utilizes secure cloud infrastructure located outside Kenya, including in jurisdictions such as Frankfurt, Germany. Where personal data is transferred outside Kenya, we ensure that such transfers comply with the Data Protection Act, 2019 by implementing appropriate safeguards. These safeguards include:
- Use of reputable service providers with internationally recognized data protection standards (ISO 27001 / SOC 2 Type II)
- Contractual agreements ensuring adequate protection of personal data
- Ensuring that recipient jurisdictions provide an adequate level of data protection

By using our services, you acknowledge that your data may be transferred to and processed in jurisdictions outside Kenya under these safeguards.

Retention of Sensitive Identity Data: For the safety of our community, National IDs and Certificates of Good Conduct are retained for the entire duration of a Runner’s account life. This ensures we have a permanent record of who has been vetted to perform physical tasks. Upon account deletion, these sensitive identity documents will be permanently deleted within 14 days, unless retention is required by applicable law or an active dispute or legal hold.
Media and Evidence Retention: * In-App Evidence: Photos and videos taken as "Proof of Task" or "Damage Evidence" are generally retained for 30 days. This aligns with the window for resolving most marketplace disputes.
- Monthly Clearing: To optimize storage and respect data minimization, non-disputed media files, and chat records, are automatically cleared every 30 days.
- Dispute Exceptions: If a task is subject to an active dispute or legal investigation, the associated media, location and chat logs will be retained until the matter is finalized.
Location Data logs: Detailed GPS logs are kept for 30 days to provide evidence in the event of a "no-show" or "theft" claim, after which they are anonymized or deleted.
Chat logs: Chat records between the runner and client are kept for 30 days to provide evidence in the event of a dispute claim, after which they are deleted.
Account Termination: Upon the permanent deletion of an account, we will scrub your personal data within 14 days, except for transactional records we are legally required to keep for tax and audit purposes under Kenyan law.
Data Minimization Commitment: Errunned adheres to the principle of data minimization. We only collect personal data that is necessary, relevant, and proportionate to the purposes outlined in this policy. We continuously review our data collection practices to ensure that no excessive or unnecessary data is processed.

11. DATA SECURITY MEASURES

We implement a multi-layered security framework designed to protect your personal and sensitive data against unauthorized access, loss, or alteration. Our security posture includes:

Encryption Protocols: * In Transit: All data moving between the Errunned App and our cloud infrastructure is encrypted using Industry-Standard TLS (Transport Layer Security).
- At Rest: Sensitive information, including National ID numbers, Certificates of Good Conduct, and personal identifiers, are stored using Advanced Encryption Standard (AES-256) on our secure database servers.
Access Controls: Access to user data is strictly limited to authorized members of the Errunned Privacy Team. We utilize "Role-Based Access Control" (RBAC), ensuring that staff only see the data necessary for their specific role (e.g., verifying a Runner’s ID).
Cloud Infrastructure Security: Our cloud servers are hosted by providers who maintain top-tier international security certifications, including ISO 27001 and SOC 2 Type II. These facilities include 24/7 physical monitoring and advanced firewalls.
Data Breach Protocol: In compliance with Section 43 of the DPA, Errunned maintains a robust incident response plan. In the event of a data breach that poses a high risk to your rights and freedoms, we will communicate the breach directly to affected users via in-app notification or email within 72 hours of becoming aware of the breach.

12. USER RIGHTS UNDER KENYAN LAW

As a Data Subject in Kenya, you have significant rights regarding your personal information. Errunned is committed to facilitating these rights through our "Privacy Team."

Right to be Informed: You have the right to be told exactly what data we collect, why we collect it, and who we share it with (as detailed in this policy).
Right of Access: You may request a copy of the personal data we hold about you. We will respond to your access request within 21 days of receipt, providing the information in a clear, understandable format.
Right to Correction (Rectification): If any of your information is inaccurate, outdated, or incomplete (such as a changed phone number), you have the right to request an immediate update.
Right to Deletion (Erasure): You may request that we delete your personal data.
- Note: This right is subject to our legal obligations to retain certain records (e.g., for tax purposes or active dispute resolution).
Right to Object & Withdraw Consent: You may object to the processing of your data for marketing purposes or withdraw your consent for location tracking at any time by adjusting your device settings.
Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format to transfer it to another service provider.
Rights Related to Automated Decision-Making: Errunned uses automated logic to "flag" or "drop" Runners based on GPS activity.
- Your Protection: You have the right not to be subject to a decision based solely on automated processing. We facilitate this by providing a 20-minute confirmation window (Reallocation Probation) before a Runner is dropped, and you may request a manual review of any automated penalty by contacting our Privacy Team within 7 days of the decision. All appeals are reviewed by authorized personnel, and outcomes will be communicated within a reasonable timeframe.
Right to Lodge a Complaint: If you believe that your data protection rights have been violated, you have the right to lodge a complaint with the Office of the Data Protection Commissioner (ODPC) in Kenya. We encourage you to contact us first so we can address your concerns promptly.

13. THIRD-PARTY SERVICES

To deliver a seamless marketplace experience, Errunned integrates with specialized service providers. In accordance with our security-first approach and Section 29 of the DPA, we disclose the categories of recipients who may process your data on our behalf:

Identity Verification & Communication Providers: We utilize third-party SMS and authentication gateways to deliver One-Time Passwords (OTPs) and critical task alerts. This ensures that only verified users can access their accounts.
Payment Gateway & Financial Service Providers: To manage the Escrow Model and the Courier Security Bond, transaction metadata is shared with licensed mobile money platforms (Safaricom) in Kenya. This allows for secure payments, commission deductions, and automated refunds.
Cloud Infrastructure & Database Providers: Your personal and sensitive data is stored on high-security, encrypted cloud servers and real-time database clusters located in Frankfurt, Germany. These providers adhere to international security standards (ISO 27001/SOC 2).
Media Hosting & Content Delivery Networks (CDNs): All images—including profile photos, National IDs, and task evidence—are hosted on specialized media servers to ensure fast loading times and encrypted storage.
AI Safety & Moderation Services: Task descriptions are analyzed by automated safety models to detect potential fraud, harassment, or illegal task solicitations, protecting the integrity of the community.
Mapping & Geolocation Services: Real-time tracking and task routing are facilitated via industry-standard mapping APIs. These services process Runner GPS data to provide live updates to Clients.

14. COOKIES AND TRACKING TECHNOLOGIES

Errunned uses cookies, mobile SDKs, and similar tracking technologies to enhance user experience, analyze platform performance, and improve service delivery. These technologies may collect technical information such as device identifiers, application usage data, and interaction patterns. Some tracking technologies are provided by third-party services integrated into the platform, including analytics, authentication, and performance monitoring tools.

Users may manage tracking preferences through their device settings.

15. MARKETING AND COMMUNICATIONS

Errunned may send users service-related communications, including task updates, security notifications, and account-related alerts necessary for the operation of the platform.

With user consent where required, we may also send promotional messages, offers, and updates about new features or services.

Users may opt out of receiving marketing communications at any time by adjusting their preferences within the application or by following unsubscribe instructions included in such messages.

We do not send marketing communications without a lawful basis, and we do not use sensitive personal data for marketing purposes.

16. CHILDREN’S POLICY

Errunned is not intended for use by individuals under the age of 18. We do not knowingly collect personal data from minors.

If we become aware that a minor has provided personal data without parental or guardian consent, we will take steps to delete such information promptly.

17. DATA DELETION AND ACCOUNT TERMINATION

We respect your "Right to be Forgotten" under Section 40 of the DPA. However, as a marketplace handling physical goods and financial transactions, deletion is subject to specific conditions:

Requesting Deletion: You may request the deletion of your account at any time through the App settings or by contacting our Privacy Team.
The 14-Day Erasure Rule: Once a valid request is received, we will initiate the deletion process. In line with Kenyan regulations, we aim to complete the erasure of your personal data within 14 days, provided there are no outstanding obligations.
Retention for Legal & Financial Compliance: We are legally required to retain certain data even after account closure:
- Financial Records: Transaction history and commission data are kept for up to 7 years to comply with Kenyan tax and audit laws.
- Dispute Records: If your account is associated with an active dispute or a "Security Bond" deduction, your data will be retained until the matter is fully resolved and the limitation period for legal claims has passed.
Courier Bond Settlement: For Runners, account deletion and the refund of the Courier Security Bond will only be finalized once all active tasks are completed.

18. POLICY UPDATES

Errunned is a dynamic platform, and we may update this Privacy Policy to reflect changes in our services or Kenyan law.

Notification: If we make significant changes to how we handle your data, we will notify you via an in-app "Pop-up" notification or an email to your registered address.
Acceptance: Continued use of the App after a policy update constitutes your acceptance of the revised terms. We encourage you to review the "Effective Date" at the top of this document periodically.

19. CONTACT INFORMATION

If you have questions regarding this policy, wish to exercise your data subject rights (such as a Data Access Request), or want to contest an automated decision, please reach out to us:

Privacy Team Office: Errunned Headquarters, 00100-Nairobi, Kenya.
Dedicated Email: [email protected]