Privacy Policy

1. Introduction

Vote Smart KE is committed to respecting privacy and handling personal information responsibly.

This Privacy Policy explains how Vote Smart KE may collect, use, store, protect, share, and retain personal information when individuals:

• Visit the Vote Smart KE website
• Use the candidate directory
• Use the candidate comparison tool
• Complete a candidate registration form
• Submit candidate information
• Contact Vote Smart KE
• Subscribe to updates or communications
• Apply for a partnership, collaboration, grant or other opportunity
• Make a donation or provide support
• Participate in surveys, research or public-engagement activities

Vote Smart KE seeks to process personal information in a lawful, fair, transparent and responsible manner.

This policy is intended to support compliance with applicable Kenyan data-protection requirements, including the Data Protection Act, 2019, and relevant regulations. Kenya’s data-protection framework is administered by the Office of the Data Protection Commissioner (ODPC)(Kenya Law).

This policy should be read together with the Vote Smart KE:

• Candidate Verification & Publication Policy
• Editorial Policy
• Terms of Use
• Cookie Policy, where applicable
• Corrections and Complaints Policy
• Funding and Donor Transparency Policy

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Platform name: Vote Smart KE
Website: Vote Smart KE
Founder: Kennedy Isiaho
Country of operation: Kenya

For purposes of this policy, “Vote Smart KE,” “we,” “us” and “our” refer to the organisation, initiative or entity responsible for operating the Vote Smart KE platform.

As Vote Smart KE develops, its legal and organisational structure may change. This policy may be updated to reflect that structure.

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The information collected depends on how an individual interacts with Vote Smart KE.

When a person visits the website, we may collect limited technical or usage information, including:

• Internet Protocol (IP) address
• Browser type
• Device type
• Operating system
• Pages visited
• Date and time of access
• Referring website or source
• General interaction with website features
• Website-performance information

This information may be collected through website logs, analytics tools, cookies or similar technologies.

Vote Smart KE will seek to use website analytics in a way that supports platform improvement while respecting user privacy.

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Candidates or authorised representatives may provide information such as:

• Full name
• Preferred public name
• Electoral position
• County
• Constituency
• Ward
• Political party or affiliation
• Candidate photograph
• Date of birth or age information, where requested
• Academic qualifications
• Professional background
• Leadership experience
• Public-service experience
• Electoral experience
• Candidate vision
• Key priorities
• Proposed approaches to public issues
• Campaign website
• Official social-media or public communication links
• Public contact information
• Private contact information
• Supporting information or documents
• Declarations and confirmations

Some information is intended for public publication, while other information may be collected only for communication, administration or verification.

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Where a candidate authorises a representative to submit information, we may collect:

• Representative’s name
• Role or relationship to the candidate
• Organisation or campaign name
• Email address
• Telephone number
• Communication records
• Evidence of authority where reasonably required

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Individuals or organisations seeking to partner or collaborate with Vote Smart KE may provide:

• Name
• Organisation
• Job title or role
• Email address
• Telephone number
• Organisation website
• Area of interest
• Proposed partnership details
• Relevant documents or communications

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Where donations or other support are accepted, we may collect information reasonably necessary to:

• Receive or acknowledge support
• Communicate with the donor
• Maintain appropriate records
• Meet applicable accountability requirements
• Prevent fraud or misuse

Depending on the payment method, information may include:

• Name
• Email address
• Telephone number
• Donation amount
• Date of donation
• Transaction reference
• Communication preferences

Vote Smart KE should avoid storing full payment card information unless it is handled through an appropriately secure payment provider.

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When an individual contacts Vote Smart KE, we may collect:

• Name
• Email address
• Telephone number
• Message content
• Attachments
• Relevant communication history

This information may be used to respond, investigate concerns, or maintain an appropriate record of the communication.

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Vote Smart KE distinguishes between information intended for public display and information collected for private administrative purposes.

Subject to review and approval, a candidate profile may publicly display:

• Candidate name
• Candidate photograph
• Electoral position
• Electoral area
• Political affiliation
• Academic qualifications
• Professional background
• Leadership experience
• Candidate vision
• Key priorities
• Proposed approaches
• Official campaign website
• Official public communication channels
• Other information submitted or obtained for the public candidate profile

Publication may occur through:

• Candidate profiles
• Candidate directory pages
• Candidate comparison tools
• Voter-information materials
• Official Vote Smart KE communications

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The following information should generally remain private unless publication is required by law, clearly authorised or otherwise justified:

• Private email addresses
• Private telephone numbers
• Identification documents
• Verification documents
• Private residential addresses
• Internal review notes
• Private correspondence
• Account or administrative information
• Internal verification records
• Sensitive personal information not relevant to public voter information

Submitting information to Vote Smart KE does not automatically mean that every submitted item will be published.

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Vote Smart KE may use personal information for the following purposes.

We may use information to:

• Maintain the website
• Operate the candidate directory
• Operate the comparison tool
• Improve website performance
• Fix technical problems
• Protect website security
• Understand how users interact with the platform

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5.2 To Process Candidate Submissions

We may use candidate information to:

• Receive and review candidate submissions
• Confirm candidate identity
• Review profile completeness
• Verify relevant information
• Request clarification
• Prepare candidate profiles
• Publish approved candidate information
• Update or correct profiles
• Manage candidate-directory and comparison-tool information

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We may use contact information to:

• Respond to enquiries
• Provide updates
• Request clarification
• Respond to correction requests
• Communicate about candidate-profile reviews
• Discuss partnerships or collaborations
• Respond to complaints

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5.4 To Improve Vote Smart KE

We may use aggregated or de-identified information to:

• Understand platform use
• Improve content
• Improve accessibility
• Improve website performance
• Identify common information gaps
• Improve candidate onboarding

Where practical, information used for analysis should be aggregated or de-identified.

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We may process information to:

• Prevent fraud
• Detect misuse
• Protect website systems
• Investigate suspicious activity
• Enforce platform policies
• Respond to security concerns
• Protect users and the platform

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We may process or retain information where reasonably necessary to:

• Comply with applicable law
• Respond to lawful requests
• Maintain required records
• Protect legal rights
• Address disputes or complaints

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Vote Smart KE will seek to process personal information only where there is an appropriate legal basis under applicable law.

Depending on the circumstances, processing may be based on:

• Consent
• The individual’s request for a service or action
• A legal obligation
• A legitimate and lawful organisational purpose
• The public interest
• Protection of rights, safety or security
• Another lawful basis recognised by applicable law

Where consent is relied upon, individuals may have the right to withdraw consent, subject to lawful limitations and the effect of withdrawal on services or published information.

Consent may not be the only basis for processing information.

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Candidate registration may include clear declarations confirming that:

• Information submitted is accurate to the best of the candidate’s knowledge
• The candidate or authorised representative has authority to submit the information
• Vote Smart KE may review and edit information for clarity and consistency
• Approved public-profile information may be published
• Private verification information will not automatically be published
• Publication does not constitute endorsement
• Candidate information may be displayed in the directory and comparison tool

Where a representative submits information, Vote Smart KE may request confirmation that the candidate has authorised the submission.

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Vote Smart KE may use cookies or similar technologies to:

• Keep the website functioning properly
• Remember user preferences
• Improve website performance
• Understand website usage
• Improve security
• Measure website traffic

Users may manage or disable cookies through browser settings.

Disabling certain cookies may affect website functionality.

If Vote Smart KE introduces non-essential cookies requiring additional notice or consent, the platform may provide a cookie notice or consent mechanism.

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Vote Smart KE does not sell personal information to advertisers.

We may share information only where reasonably necessary, including with:

• Website-hosting providers
• Form-service providers
• Email-service providers
• Website-security providers
• Analytics providers
• Technology and technical-support providers
• Payment-service providers
• Professional advisers
• Government or regulatory authorities where legally required

Service providers may process information on behalf of Vote Smart KE only for authorised purposes and subject to appropriate safeguards.

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Information approved for public candidate profiles may be visible to:

• Website visitors
• Search engines
• Media organisations
• Researchers
• Civil-society organisations
• Voters
• Other members of the public

Public information may be copied, shared, indexed or archived by third parties.

Vote Smart KE may not be able to control information copied or republished by third parties after publication.

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Some technology or service providers may store or process information outside Kenya.

Where cross-border processing occurs, Vote Smart KE will seek to use appropriate safeguards and comply with applicable legal requirements.

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Vote Smart KE will take reasonable technical and organisational measures to protect personal information against:

• Unauthorised access
• Unauthorised disclosure
• Loss
• Misuse
• Alteration
• Destruction

Security measures may include:

• Password protection
• Access controls
• Secure website connections
• Limited access to private information
• Regular software updates
• Backups
• Security monitoring
• Appropriate use of trusted service providers

No internet-based system can guarantee absolute security.

Individuals should avoid sending highly sensitive information through unsecured communication channels unless specifically requested through an appropriate secure process.

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Vote Smart KE will seek to retain personal information only for as long as reasonably necessary for:

• The purpose for which it was collected
• Candidate verification
• Profile administration
• Communication
• Platform operation
• Record keeping
• Legal compliance
• Dispute resolution
• Security and accountability

Retention periods may differ depending on the type of information.

Examples include:

Information	General Retention Approach
Published candidate-profile information	Retained while relevant to the platform and public-interest purpose
Candidate verification information	Retained only as reasonably necessary for verification, accountability or legal purposes
Contact enquiries	Retained for a reasonable period to manage communication and follow-up
Partnership information	Retained while discussions or the relationship remain active
Donation records	Retained as required for accountability, financial or legal purposes
Technical logs	Retained for a limited period based on security and operational needs

When information is no longer required, Vote Smart KE may delete, anonymise or securely archive it.

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Subject to applicable law and relevant limitations, individuals may have rights relating to their personal information, including the right to:

• Be informed about how information is collected and used
• Request access to personal information
• Request correction of inaccurate or incomplete information
• Request deletion of information in appropriate circumstances
• Object to certain processing
• Request restriction of certain processing
• Withdraw consent where consent is the applicable basis
• Request information about the use of personal data
• Raise a complaint with the relevant data-protection authority

The ODPC provides information on data-subject rights and mechanisms for submitting complaints.

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To make a privacy-related request, contact:

Email: contact@votesmartke.org
Website: Vote Smart KE
Subject line: Privacy Request – Access, Correction or Deletion

Please provide:

• Your full name
• Relevant contact information
• A clear description of the request
• The relevant profile or page, where applicable
• Information reasonably necessary to confirm identity

Vote Smart KE may request additional information before acting on a request to protect against unauthorised access or changes.

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A request to remove information from a candidate profile will be considered in accordance with:

• Applicable law
• The nature of the information
• The public-interest purpose of the platform
• The Candidate Verification & Publication Policy
• The Editorial Policy
• Any relevant legal or regulatory obligations

A deletion request does not automatically require removal of all information.

Vote Smart KE may retain information where reasonably necessary for:

• Legal compliance
• Public-interest purposes
• Editorial records
• Verification
• Fraud prevention
• Dispute resolution
• Historical or accountability purposes

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Vote Smart KE is primarily intended to provide voter and civic information.

We do not knowingly seek to collect unnecessary personal information from children.

If Vote Smart KE introduces educational activities involving minors, additional privacy safeguards and appropriate consent procedures may be applied.

Parents, guardians, teachers or institutions may contact Vote Smart KE if they believe a child’s personal information has been collected inappropriately.

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Vote Smart KE may link to:

• Candidate websites
• Political-party websites
• Government websites
• Public institutions
• Social-media platforms
• Other external resources

Vote Smart KE is not responsible for the privacy practices of external websites.

Users should review the privacy policies of third-party services before providing personal information.

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If Vote Smart KE becomes aware of a personal-data breach, it will assess the nature and potential impact of the incident.

Where required, Vote Smart KE may:

• Take steps to contain and investigate the incident
• Restore affected systems
• Notify relevant authorities
• Notify affected individuals where required
• Improve security controls

The ODPC provides official information and channels relating to data-protection compliance and breach reporting.

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Vote Smart KE may update this Privacy Policy when:

• Platform features change
• New forms or services are introduced
• Data-processing practices change
• New service providers are used
• Legal or regulatory requirements change
• Security practices are improved

The current version will display an effective date and version number.

Where a material change affects how personal information is handled, Vote Smart KE may provide additional notice where appropriate.

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For privacy questions, requests or concerns:

Vote Smart KE
Website: Vote Smart KE
Privacy email: contact@votesmartke.org

For concerns about Kenya’s data protection framework, individuals may consult the Office of the Data Protection Commissioner (ODPC).

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This Privacy Policy is an operational draft prepared for Vote Smart KE.

It is designed to establish transparent privacy practices while the platform continues to develop. It is not legal advice and should be reviewed by a qualified Kenyan data-protection or legal professional when resources become available.

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Approval

Approved by:

Name: Kennedy Isiaho

Role: Founder, Vote Smart KE

Date: August 2026

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Vote Smart KE — Know Your Leaders. Make an Informed Choice.