Gundua Info Mobile App Privacy Policy

Last Updated: 13th June 2025

1. Introduction

Gundua Info is a digital democracy mobile application that re-imagines civic engagement. It brings innovation to the democratic space, giving users real-time access to civic education and budget content right from their phones

This Privacy Policy describes how The Center for Transformational Leadership collects, uses, and shares information when you use the mobile application, Gundua Info. We are committed to protecting your privacy and ensuring the security of your personal information.

DISCLAIMER: Gundua Info is an independent initiative by the Center for Transformational Leadership that re-imagines civic engagement. It is not an official government application and does not represent any government entity. The information provided is compiled from four sources:

1. Kenyan Laws
2. County Government Budgets

• Nakuru County Government 

1. User Generated Information
2. Verified Data Collected by Center for Transformational Leadership

2. Information We Collect

We may collect the following types of information:

• Personally Identifiable Information (PII):
  • Email address, Collected to create a unique user identifier, enabling personalized budget information delivery and account management.
  • Gender (Male, Female): Collected for demographic analysis, allowing us to understand the user base and tailor our services effectively.
  • Age bracket (18-35 years, Above 35 years) for demographic analysis.
  • User-provided location data corresponding to Kenyan electoral boundaries (County, Sub-County, and Ward) to enable delivery of relevant budget information.
  • User Comments (Anonymous): Content you submit through the app’s commenting feature. These comments are collected to facilitate public discourse on democratic topics but will not be publicly linked to your identity or any personal information
• Non-Personally Identifiable Information (Non-PII):
  • Usage data (e.g., app interactions, features used): Collected to analyze how users interact with the app and identify areas for improvement
  • Device type and operating system: Collected to optimize the app’s performance across different devices
  • Crash logs: Collected to identify and fix technical issues and improve app stability
  • Aggregated and anonymized data: Used for statistical analysis and reporting, with individual users not being identifiable.
  • Timestamp: The date and time when certain actions occur within the app (e.g., when a comment is posted) to help with record-keeping, moderation, and understanding usage patterns.

NB: Gundua Info is intended for adult citizens of Kenya. We do not knowingly collect personal information from children

3. How We Collect Information

We collect information:

• Directly from You: When you create an account, utilize features that require user input (such as searching budget information or selecting your electoral boundary), and when you submit anonymous comments or other content within the app 
• Automatically Through App Usage: We collect data on how you interact with the app, including the features you use, the time spent on different screens, and your navigation patterns. This helps us understand user behavior and improve the app’s design and functionality.
• Automatically Through Device Information: We collect non-identifying device information, such as your device type, operating system version, and screen resolution, to ensure the app functions correctly on various devices and to optimize performance. 
• Automatically Through Error Logs: We collect error logs and crash reports to identify and fix technical issues, ensuring a stable and reliable app experience.

4. Use of Information

We use the information we collect to:

• Provide and improve the App’s functionality: We use usage data, device information, and crash logs to understand how the app is performing, identify areas for improvement, and ensure optimal functionality across different devices
• Personalize your experience: We use your user-provided location data to deliver budget information tailored to your selected electoral boundary location
• Send push notifications about public participation events in your area: We use your user-provided location data to send you relevant notifications (based on your consent)
• Analyze user demographics to improve the service: We use your gender and age bracket for aggregated demographic analysis to understand our user base and tailor our services effectively (Legal Basis: Legitimate interest)
• Manage user accounts and deliver personalized budget information: We use your email address as a unique identifier to manage your account and associate it with your selected preferences for personalized budget information delivery
• Conduct analytics and research: We use aggregated and anonymized usage data and demographic information for statistical analysis and reporting to improve our understanding of user trends
• Facilitate Public Discourse: We use anonymous user comments to enable public discussion and feedback on democratic topics within the app
• Content Moderation: User comments are reviewed and moderated to ensure compliance with our terms of service and community guidelines, and to prevent abusive or inappropriate content. While comments are displayed anonymously to other users, we may internally link them to your account for moderation, account management, or in response to legal requests

5. Sharing of Information

We may share your information with:

• We may share your information with third-party service providers who assist us in operating the App. This may include sharing aggregated and anonymized usage data with providers for performance monitoring and stability
• Google Analytics for Firebase: We use Google Analytics for Firebase to analyze app usage and improve our services. We share anonymized usage data, device information, and app interaction data.
• Public Display of User Comments: Please be aware that any comments or content you submit through the app’s commenting feature will be visible to other users of the app, but they will be displayed anonymously and will not be linked to your personal identity.

• Law enforcement or government authorities in accordance with Kenyan law

6. Community Guidelines/Terms of Service

The App’s commenting feature allows users to submit content anonymously. By using this feature, you agree to abide by our Community Guidelines/Terms of Service. We reserve the right to moderate, remove, or edit comments that violate these guidelines or applicable laws.

6. Data Security

We take reasonable measures to protect your information from unauthorized access, use, or disclosure. These measures include encryption of data in transit when sending or receiving information. Access to raw user data is limited to authorized Gundua Team/CTL personnel on a need-to-know basis. Any data shared with third parties for analytics purposes (such as age groups or gender) is generalized and anonymized to prevent identification of individual users. We do not share raw, identifiable user data with any third party

7. Data Retention

We retain account information for as long as your account is active to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.  

8. Data Breach Notification 

In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the Office of the Data Protection Commissioner (ODPC) in accordance with the requirements of the Data Protection Act, 2019. We will take reasonable steps to mitigate the impact of the breach and provide you with information about the nature of the breach, the potential consequences, and the measures we have taken to address it.

9. Your Rights

You may have the following rights:

• Access and correct your personal information.
• Right to object to processing. 
• Right to data portability
• Request the edit or deletion of your personal information.

To exercise these rights, please contact us at info@ctl-kenya.org

10. Third-Party Links and Services

The App may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties.  

11. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. Your continued use of the App after any changes constitutes your acceptance of the new Privacy Policy.  

12. Contact Us

If you have any questions or concerns about this Privacy Policy, please contact us at:

• Email: admin@gunduainfo.com
• Physical Address: 

Jenner Heights Apartments, 3rd Floor

Off Nakuru-Nairobi Highway

P.O. Box 15206 Nakuru, 20100

• Tel: 0786 988 484 | 0727 920 220