Privacy Policy

1. Who this covers

This policy explains how Lucim Polls (“Lucim”, “we”) handles personal data when you vote, buy tickets, browse events, or run events as an organizer. Lucim Polls is operated by IMAKEL SYSTEMS, a business registered in Kenya, which is the data controller for your personal data. This policy is written to comply with the Kenya Data Protection Act, 2019.

2. What we collect

If you vote or buy tickets

• Your phone number and payment confirmation details (from M-Pesa, Airtel Money or your card provider), which we need to process your payment and deliver your ticket or record your vote.
• Your transaction history on the platform (what you paid for, when, and for which event).

If you are an organizer

• Your name, contact details and business information from onboarding.
• Your events, sales and payout records.

If you are a contestant

• Your name, photo and profile details are uploaded by the event's organizer, who confirms to us that you have consented. If you believe you appear on Lucim without consent, contact us and we will act promptly.

We do not collect data we do not need. There are no advertising trackers on the platform.

3. How we use it

• To process payments, record votes, issue tickets and admit you at the gate.
• To pay organizers and keep accurate financial records.
• To prevent fraud, for example detecting duplicate tickets or manipulated voting.
• To respond when you contact us, and to send service messages about transactions you have made.
• To meet legal obligations, such as tax and financial reporting.

We do not sell personal data, and we do not use it for third-party advertising.

4. Who we share it with

• Payment providers (such as Safaricom M-Pesa, Airtel Money and card processors) to complete transactions.
• Organizers see aggregated results and sales for their own events. They do not receive voters' phone numbers from us.
• Service providers that host our systems. Our database and image storage run on reputable cloud providers whose servers are outside Kenya (currently in the United States). This is a cross-border transfer under the Data Protection Act, made with appropriate safeguards.
• Authorities, where the law requires it.

5. How long we keep it

Transaction records are kept as long as needed for financial and legal record-keeping. Event content (posters, contestant profiles) stays up while the event and its results remain published, and is removed on justified request. Data that is no longer needed is deleted.

6. Your rights

Under the Data Protection Act, 2019 you have the right to:

• be told what data of yours we hold, and get a copy of it;
• have inaccurate data corrected;
• ask for deletion of data we no longer have a valid reason to keep;
• object to processing, where the law allows.

To use any of these rights, email info@lucimpolls.com. If you are unhappy with our response, you may complain to the Office of the Data Protection Commissioner (ODPC), Kenya.

7. Security

Traffic to the platform is encrypted, payment card handling is done by the payment providers rather than on our servers, and access to personal data is limited to what running the platform requires. No system is perfectly secure, but if a breach ever puts your data at real risk we will notify you and the ODPC as the law requires.

8. Cookies

We use only the cookies needed to keep organizers signed in. There are no advertising or cross-site tracking cookies.

9. Children

Voting and ticket purchases involve mobile-money payments and are intended for users old enough to hold a mobile money account. Events aimed at children are the organizer's responsibility, including any consents required.

10. Changes and contact

If this policy changes materially, we will highlight it on the platform and update the date above. Questions: info@lucimpolls.com · Nairobi, Kenya. See also our Terms of Service.