Dealer Privacy Notice

This Dealer Privacy Notice explains how Francton Limited, operating as Garisea (“Garisea”, “we”, “us”), handles personal data on the dealer console at dealer.garisea.com and on the dealer side of the Garisea app for iOS and Android. It covers you, the people on your team, and the buyer data you receive.

It adds to the Garisea Privacy Policy. Where the two overlap on dealer-account data, this Notice applies. If your dealership has signed a Data Processing Agreement with us, that agreement sets out where we act as your processor.

We wrote this Notice to meet the Kenya Data Protection Act, 2019 (“the Act”). It also follows the EU General Data Protection Regulation (GDPR) where that law applies.

Francton Limited, operating as Garisea, is the data controller for:

• Your account data — you and your staff seats: names, contact details, verification documents, sign-in activity, billing history and settings.
• Buyer data on the platform — enquiries, messages and searches that buyers make on Garisea.

When a lead delivers a buyer's details to your dealership, your dealership becomes an independent data controller for them under the Act, with its own duties (Section 12 and Dealer Terms §21).

Our data protection contact is [email protected].

3.1 Data you give us

• Account — name, email, phone and password. We store the password only as a salted bcrypt hash.
• Dealership details — business name, address, contact phone and email, social links and opening hours.
• Verification documents — KRA PIN, business registration and identity documents. Only the founding account and Garisea staff can read the business certificate and KRA PIN.
• Staff seats and branches — for each person you invite: name, email, phone, role, branch, and whether they take leads. We store only a scrambled (hashed) form of each invitation link, which works for 7 days.
• Listings — vehicle details (including VIN), photos, videos, viewing location, price and the payment methods you accept. If you paste text to fill a listing, we process that text.
• Sales you record — when you mark a car sold or reserved: who the buyer is (one of the people who enquired on Garisea, or someone else, with their name if you type one) and the sale price.
• Lead handling — your replies, internal notes and follow-ups.
• Review replies — your public replies to reviews.
• Payments — top-ups and orders you start. Card and M-Pesa details are entered on our payment provider's checkout; we never see them and receive only the result (success or failure, amount, reference). For a bank transfer, we record the payer name, reference, amount and date.
• Garisea Assistant — what you and your staff type to the Garisea Assistant, in the console or the app, and its replies. Each person's chats are stored as their own, under your dealership's account (Section 4.1).
• Support tickets — anything you send us, including reports of fake or spam enquiries.

3.2 Data we collect automatically

• Device and browser — IP address, browser, operating system, device model, language and time zone.
• Sign-in activity — including the last time each staff seat signed in, and which seat each lead was assigned to.
• Analytics — the pages you visit and actions you take, through Google Analytics, which receives your dealer account ID after you sign in. It is on by default and you can switch it off (Cookie Policy, Section 5).
• Activity on your account — when you see an upgrade prompt, open a pack page, start a checkout, or view or use a feature. We keep this for 400 days.
• Audit log — account status changes, listing status changes, data exports, deletions and changes to billing or contact settings.
• Error data — when a page fails, the error, the page, your browser and your account ID; for errors on our servers this can include your email address. The console also keeps a short replay of the screen before the error, with all text masked and images blocked.
• App identifiers — on the dealer side of the app, an install ID, a push token and, on iPhone only if you allow tracking, the Advertising Identifier.
• Cookies and similar storage — see our Cookie Policy.

3.3 Data from others

• Sign in with Google or Apple — your name, email and an account ID. Never your password. We keep an Apple token, encrypted with AES-256-GCM, so we can revoke your Apple sign-in if you delete your account.
• Payment provider — the result of each payment.

• Run the console — sign you in, publish listings, deliver leads, assign them to your staff (automatically, if you turn that on), show your performance and send notifications.
• Verify your dealership — check your documents to approve listings and award badges.
• Bill you — charge your wallet for renewals and purchases, and issue invoices and receipts.
• Use AI to help you — fill a listing from pasted text, write descriptions, draft replies to leads, and answer questions in the Garisea Assistant (Section 4.1).
• Keep Garisea safe — detect fraud, fake listings, impersonation, ad fraud and breaches of our Acceptable Use Policy.
• Keep in touch — send lead alerts, billing notices, account and security messages and, if you agree, product news. Turn marketing off in Settings → Notifications.
• Improve Garisea — use analytics to see which features dealers use and where they get stuck.
• Meet legal duties — answer lawful requests, keep transaction records for 7 years and keep audit logs.

4.1 The Garisea Assistant

• Whose chats they are — each person's chats are their own. You and each staff seat see only the chats you started yourselves; colleagues can't open them, and that includes the account owner. If a seat is removed, its chats are not passed to anyone else. Authorised Garisea staff can read chats to help you, check the quality of answers and act on abuse.
• Who processes your messages — an AI service provider processes them for us, on our instructions (Section 6.3), and an automated safety check reads each message to keep abuse out. To answer, the assistant reads your account with the same access as the person signed in.
• Nothing is sent for you — replies to leads, descriptions and listing details the assistant writes are drafts, shown for you to copy. The assistant never sends a message to a buyer and never changes your listings, leads or ads.
• How long we keep chats — 12 months after their last message, unless you delete them sooner (Section 7).

• Contract — most processing is needed to provide the console under our Dealer Terms: listings, leads, billing and the analytics you signed up for.
• Legitimate interests — fraud prevention, security, analytics and measurement of our own dealer-recruitment ads (both on by default, with an opt-out), and understanding how the console is used. We weigh these against your rights.
• Consent — marketing messages and tracking on iPhone. Withdraw it at any time.
• Legal obligation — tax records, regulator requests, audit trails and breach notification.

We share your data only to provide the service, with your consent, or when the law requires it. We don't sell it.

6.1 Buyers and the public

Your dealership's public profile (name, location, ratings, badges, opening hours and active listings) appears on garisea.com and in the Garisea app. Your phone number and email are not public, and we never show the email and password you sign in with. When a signed-in buyer taps Call or WhatsApp, we send you their enquiry and show that buyer your business number only if your plan covers that enquiry. Partners handling the buyer's finance or insurance see your dealership's public profile, never your contact details.

6.2 Your own team

Owners and managers see every staff seat. A branch manager sees the names, roles and open leads of the staff in their branch, but not their phone numbers or sign-in times. Each seat hears only about the leads assigned to it. Garisea Assistant chats are not shared: each person sees only their own, and owners and managers can't open a staff seat's chats (Section 4.1).

6.3 Service providers

Our service providers act on our instructions and may use your data only to provide their service to us. The kinds of provider we use are:

• Payments — to take top-ups and payments.
• Email, SMS and WhatsApp delivery — for alerts, billing notices, one-time codes and, with consent, marketing.
• Hosting, database and caching — encrypted in transit and at rest.
• Image and video hosting — for photos, logos and verification documents.
• Push notifications — to your browser or phone.
• Analytics and error monitoring — Section 3.2.
• Maps — for the location picker and dealership maps.
• Bot protection — on sign-in and sign-up.
• Background jobs and internal alerts — for reminders, renewals and alerting our team.
• AI — an AI provider processes listing text you paste, vehicle details for descriptions, your messages to the Garisea Assistant with what it needs to answer you (such as names, plan, counts, wallet balance, and your listings, leads and ad results), and, when you ask for a draft reply to a lead, the buyer's name and the enquiry's messages with your dealership's name. It doesn't receive the buyer's email address or phone number.

A full list of our service providers is available from [email protected].

6.4 Advertising and measurement partners

To run and measure Garisea's own dealer-recruitment ads, and to learn which campaign brought you to Garisea, we share limited data with Meta (Facebook, Instagram) and Google:

• What we share — when you sign up: your email address and phone number in scrambled (hashed) form, your IP address, browser details and the IDs in Meta's cookies. In the app: installs and sign-ups, and your device's advertising ID (on iPhone only if you allow tracking). We never send your email address or phone number unscrambled.
• When — on the website, by default, until you switch Advertising off in the cookie banner. In the app, subject to your tracking and advertising-ID settings.
• Why — to measure whether our ads work, reach dealers like you, and attribute sign-ups and installs. Not to let Meta or Google advertise other companies' products to you.
• Your control — turn off Advertising in the cookie banner; on iPhone, don't allow tracking; on Android, reset or limit your advertising ID. You can also manage ads with Meta and Google.

Meta and Google are independent controllers of what they receive and follow their own privacy policies.

6.5 Authorities

We may disclose your data when Kenyan law requires it, for example under a court order, a regulator's formal request, a criminal investigation by the Directorate of Criminal Investigations (DCI), or a binding KRA request. We will tell you about the request unless the law forbids it.

6.6 Business transfers

If Garisea is sold, merged or restructured, your data may pass to the new owner under the same privacy commitments. Where we reasonably can, we will email you at least 30 days beforehand.

We keep personal data only as long as we need it for the purposes in this Notice. Then we delete it or anonymise it.

• Encryption — TLS 1.2 or higher on every connection, and encryption at rest on our production database. Apple sign-in tokens are also encrypted with AES-256-GCM.
• Passwords — stored only as salted bcrypt hashes.
• Sign-in — access tokens last 30 minutes and refresh tokens rotate on every use. On the web they sit in secure, httpOnly cookies.
• Signing out — Sign out ends the session on this device only. Sign out everywhere (Settings → Security) ends every session on your account, on other browsers and in the Garisea app. Changing your password does the same, except on the device you changed it from, and so does deleting your account. Those other sessions stop working within moments, not when their sign-in would otherwise expire.
• Account lockout — after 5 failed sign-in attempts in 30 minutes, we lock the account for a short time and email you.
• Staff seats — seats can't close the account or change its sign-in email or password. Invitation links are stored only in hashed form and expire after 7 days.
• CSRF protection and signed webhooks — we verify a CSRF token on changes, and the signature on incoming payment, email and media notifications.
• Access controls — our staff get access to personal data by role, and we log administrative actions.
• Secrets — rotated every 90 days and at once on a suspected compromise; automated scans block accidental commits of credentials.

No system is completely secure. If a personal data breach affects you, we will notify the Office of the Data Protection Commissioner within 72 hours of becoming aware of it, and tell you without undue delay where the breach puts you at real risk.

Under the Act (and GDPR Articles 15–21 where they apply) you have these rights:

• Access and portability — email [email protected] and we will send you a structured, machine-readable copy of your account data within 30 days. There is no self-service export for dealer accounts yet.
• Correction — edit most details in Settings → Profile. For anything you can't change yourself, email [email protected].
• Deletion — the account's own login (not a staff seat) can delete the account in Settings → Account Deletion. When you delete the account, we cancel your subscription and stop your ads. Within 30 days we remove your listings and store page, remove every staff seat on the account, and remove the name, email address, phone number, photo and address from the account. We keep tax records and the audit log as the law requires. If your wallet holds money when you delete your account, it isn't forfeited: we open a payout request and pay the balance back to you (or your business); we may contact you to confirm where to send it. We keep the contact and payment details needed for that payout until it is made.
• Objection — object to processing based on our legitimate interests, for example by switching off analytics (Cookie Policy, Section 5) or marketing (Settings → Notifications), or by emailing [email protected].
• Withdrawing consent — at any time, in your settings or the cookie banner. It doesn't affect what we did before.
• Restriction — ask us to pause processing while we look into a complaint.
• Complaint — complain to the Office of the Data Protection Commissioner (Kenya).

We respond to rights requests within the time the law requires.

Most of our servers and service providers are outside Kenya. Our main database is hosted in the United States, and most of our providers are based in the United States; our SMS and payment providers are in Kenya. When we transfer your data outside Kenya we do so under section 48 of the Act, relying on contracts that require the recipient to protect it, and on encryption in transit and at rest.

We use automated systems to:

• rank your listings in search results;
• score how likely a lead is to buy (Cold to Very Hot);
• assign leads to your staff and move an unanswered lead to the next seat, if you turn automatic assignment on;
• deactivate listings flagged as stale; and
• filter clearly fraudulent activity.

None of these decisions has a legal or similarly significant effect on you within section 35 of the Act. If you think one has harmed you, for example a listing was wrongly hidden, email [email protected] and a person will review it.

When a lead delivers a buyer's details (name, phone, email, message, trade-in details) to your dealership, your dealership becomes an independent data controller for them. Under the Act and the Dealer Terms you must: use the data only for the enquiry it relates to (no marketing lists, resale or passing it on); keep it secure (no unsecured WhatsApp groups beyond your staff, no buyer spreadsheets on unsecured devices); delete it when you no longer need it for the enquiry; answer requests that buyers make to you directly within the time the law requires; make sure everyone on your staff seats follows these rules; and tell Garisea promptly if you learn of a breach affecting buyer data you got through Garisea. See Dealer Terms §11 and §21.

We may update this Notice as the console changes, as our providers change, or as the law requires. We will email you about a material change at least 14 days before it takes effect, and show a notice in the console. The “Last updated” date at the top shows the latest version. If you keep using the console after the change takes effect, the updated Notice applies.

For privacy questions, complaints or to use your rights:

• Privacy questions, rights requests, complaints, and trust and safety: [email protected], our data protection contact.
• Dealer support: open a support ticket from your dashboard (Support), or email [email protected].
• Francton Limited, operating as Garisea.

To complain to the Kenyan regulator: Office of the Data Protection Commissioner — www.odpc.go.ke.