Section 1
Introduction
Pwani Luxury (“Pwani Luxury”, “we”, “us” or “our”) is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, disclose, store and protect personal data obtained through our website, direct bookings, third‑party booking platforms and related communications.
This Privacy Policy is prepared in accordance with the Kenya Data Protection Act, 2019 and the Data Protection (General) Regulations, 2021.
Section 2
Sources of Personal Data
Direct Bookings
Where you make a booking directly through our website, WhatsApp, email or other direct channels, we collect personal data directly from you. In these cases, Pwani Luxury acts as the primary Data Controller.
Third‑Party Booking Platforms (e.g. Airbnb)
Where you book accommodation through third‑party platforms such as Airbnb:
- 2.2.1The platform may act as an independent or joint data controller for data collected through its systems.
- 2.2.2Pwani Luxury receives limited personal data necessary to manage your stay.
- 2.2.3Processing of personal data by the platform is governed by its own privacy policy.
Section 3
Categories of Personal Data
We may collect:
- 3.1.1Identification details
- 3.1.2Contact information
- 3.1.3Booking and stay information
- 3.1.4Payment confirmations
- 3.1.5Website usage data
- 3.1.6Communications with us
Section 4
Lawful Basis for Processing
We process personal data based on consent, contractual necessity, legal obligation and legitimate interests.
Section 5
Purposes of Processing
Personal data is processed to:
- 5.1.1Manage bookings and guest stays
- 5.1.2Communicate with guests
- 5.1.3Process payments
- 5.1.4Provide customer support
- 5.1.5Improve services
- 5.1.6Comply with legal obligations
- 5.1.7Ensure safety and security
- 5.1.8Conduct permitted marketing activities
Section 6
Payments
Direct Bookings
Payments made through direct bookings are processed through secure third‑party payment providers. Pwani Luxury does not store full card details.
Third‑Party Platforms
Payments made through platforms such as Airbnb are processed entirely by those platforms in accordance with their terms and privacy policies.
Section 7
Sharing of Personal Data
Personal data may be shared with:
- 7.1.1Booking platforms
- 7.1.2Payment processors
- 7.1.3Property management, cleaning and maintenance teams
- 7.1.4IT and hosting providers
- 7.1.5Government authorities where required by law
All recipients are required to process data securely and lawfully.
Section 8
Cross‑Border Data Transfers
Some service providers or booking platforms may process data outside Kenya. Where this occurs, appropriate safeguards are implemented in accordance with the Data Protection Act.
Section 9
Data Retention
Personal data is retained only for as long as necessary to fulfil booking, legal and regulatory requirements.
Section 10
Data Security
We implement appropriate technical and organisational measures to protect personal data.
Section 11
Cookies and Website Analytics
Our website uses cookies and analytics tools to improve functionality and user experience. You may manage cookies through your browser settings.
Section 12
Data Subject Rights
You have the right to:
- 12.1.1Be informed
- 12.1.2Access your data
- 12.1.3Object to processing
- 12.1.4Request correction or deletion
- 12.1.5Withdraw consent
Requests may be made via the contact details above.
Section 13
Marketing Communications
Marketing communications are sent only where consent has been provided or where permitted by law. You may opt out at any time.
Section 14
Children’s Data
Our services are not directed at children. We do not knowingly process personal data of persons under 18 without parental consent.
Section 15
Changes to this Policy
We may update this Privacy Policy from time to time. Updates will be published on our website.
Section 16
Contact
For questions regarding this Privacy Policy, contact:
- 16.1.1Pwani Luxury
- 16.1.2Email: info@pwaniluxury.com
