Linda Privacy Policy

1. Introduction

Linda is a technology platform operated by BuntuCart Limited, a company incorporated in Kenya ("BuntuCart", "Linda", "we", "us" or "our").

Linda helps workers, service providers, employers, households, recruiters and communities create and access structured information that may support worker discovery, referrals, verification, reputation building and hiring decisions.

This Privacy Policy explains how we collect, use, store, share and otherwise process personal data when you access or use Linda's websites, applications, communication channels, verification services and related services.

We process personal data in accordance with applicable Kenyan law, including the Constitution of Kenya, 2010, the Data Protection Act, 2019 and applicable regulations made under it.

2. Who This Policy Applies To

This Policy applies to individuals whose personal data is processed through Linda, including workers and service providers; job seekers and candidates; employers and household hirers; referees and recommenders; reviewers; recruiters and organisations; website visitors; platform account holders; and persons whose information is submitted for lawful verification purposes.

Where another organisation uses Linda to process information under its own instructions, the respective roles and responsibilities of Linda and that organisation may also be governed by contractual data-processing terms.

3. Personal Data We May Collect

Depending on the service being used, we may process identification and profile information such as name, telephone number, email address, photograph, age or date of birth where necessary, national identification information where lawfully required, nationality, general location and language preferences.

Specifically, when an employer or hirer searches for a worker, we collect and process that worker's National ID number to verify their identity through YouVerify, our independent third-party identity verification provider. Where a worker chooses to submit a Certificate of Good Conduct, we collect and store that document (and the text extracted from it) to support a human review of their background and safety history. Both are collected only for these verification purposes and are encrypted at rest.

We may also process professional information including occupation, skills, experience, employment history, certifications, licences, availability, work location preferences, references, portfolio information and employment-related documents.

Linda may process verification information received directly from users or, where lawful and appropriate, from verification providers, referees, employers, public authorities or other authorised sources.

We may process reputation and referral information including recommendations, ratings, structured feedback, work history confirmations, referral relationships, complaints, disputes and responses.

We also process technical information including IP address, browser and device information, login records, security events, approximate location where enabled, cookie identifiers and usage analytics.

We do not intentionally collect personal data that is irrelevant to the legitimate purpose of the service.

4. Information About Other People

If you provide information about another person — for example, when referring a worker or providing a reference — you must have a lawful and legitimate basis for doing so.

You must not knowingly submit false, malicious, discriminatory or misleading information.

Linda may contact the person concerned to notify them of the processing, verify information, request additional context or provide an opportunity to respond, correct or challenge information.

5. How We Use Personal Data

We may process personal data to create and maintain user profiles; facilitate worker discovery and referrals; verify identity and information submitted to the platform; enable employers and hirers to evaluate potential workers; facilitate references and recommendations; maintain platform integrity; detect fraud and misuse; investigate complaints and disputes; provide customer support; comply with legal obligations; improve Linda's products; communicate important service information; and send marketing communications where permitted by law.

We will not use personal data for purposes incompatible with the purpose for which it was collected unless permitted by law and accompanied by appropriate safeguards.

6. Lawful Basis for Processing

Depending on the circumstances, Linda may process personal data based on consent, performance of a contract, compliance with a legal obligation, protection of legitimate interests, or another lawful basis recognised under applicable law.

Where processing is based on consent, the individual may withdraw consent, although withdrawal does not invalidate processing lawfully carried out before withdrawal.

7. Verification and Third-Party Providers

Linda may use specialised service providers to perform identity, document, business, employment or other permitted verification services.

The use of a verification provider does not mean that Linda guarantees that a person is trustworthy, safe, suitable or qualified for a particular engagement.

Verification results represent information available and assessed at a particular point in time and may be incomplete, outdated or affected by errors in source information.

Where adverse information may materially affect a worker, Linda may implement proportionate review, correction, dispute and appeal mechanisms.

8. Reviews, References and Reputation Information

Linda is designed to improve accountability while protecting users against malicious or unreliable information.

Users submitting reviews, references or reports must provide information honestly and in good faith.

Linda may moderate, restrict, investigate, contextualise, suspend or remove content that appears fraudulent, retaliatory, discriminatory, abusive, irrelevant or unsupported.

A worker may request access to applicable personal information and may challenge information believed to be inaccurate or misleading, subject to lawful limitations.

9. Automated Tools and Trust Indicators

Linda may use automated systems to organise information, detect suspicious activity, identify inconsistencies, assist moderation or generate indicators from available information.

Where used, such indicators are intended to assist rather than replace appropriate human judgment.

Linda does not promise a universal "trust score." Instead, we use transparent badges and factual indicators — for example, Identity Verified, Reference Confirmed, Work History Confirmed and Repeat Hire — rather than a single number that could unfairly determine employment opportunities.

10. Sharing of Personal Data

We may share personal data with authorised service providers and technology vendors; identity and verification providers; employers or hirers where the individual has made information available for that purpose or another lawful basis applies; professional advisers; regulators and public authorities where legally required; and parties involved in a corporate restructuring subject to appropriate safeguards.

We do not sell personal data.

We do not permit employers or other users to access information merely because they are curious about a person.

11. International Transfers

Some service providers may process or store information outside Kenya.

Where personal data is transferred outside Kenya, Linda will apply measures required under applicable law, which may include assessing the legal basis for the transfer, contractual safeguards and appropriate technical and organisational measures.

12. Data Retention

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected and for applicable legal, regulatory, security, fraud prevention, dispute resolution and contractual purposes.

Different categories of data may have different retention periods.

When information is no longer required, we may securely delete, destroy or anonymise it.

13. Security

We implement proportionate administrative, organisational and technical safeguards designed to protect personal data against unauthorised access, alteration, disclosure, loss or destruction.

No digital system can guarantee absolute security, and users are responsible for maintaining the confidentiality of their login credentials and promptly reporting suspected unauthorised access.

14. Your Rights

Subject to applicable law, you may have rights to:

• Be informed about use of your personal data
• Access personal data held about you
• Object to certain processing
• Request correction of inaccurate or misleading data
• Request deletion of information in appropriate circumstances
• Request restriction of processing
• Withdraw consent where consent is the applicable basis

Requests may be submitted through Linda's designated privacy contact channel.

Linda may need to verify the identity of a requester before acting on a request.

15. Children

Linda is primarily intended for adults capable of entering employment or service relationships in accordance with applicable law.

The platform does not knowingly create public worker-reputation profiles for children without appropriate legal basis, safeguards and, where required, parental or guardian consent.

16. Changes to this Policy

We may update this Policy to reflect legal, regulatory, technological or operational changes. Material changes may be communicated through the platform or other appropriate channels.

17. Contact and Complaints

Privacy enquiries should be directed to:

Data Protection Lead
BuntuCart Limited
Pacific Court, Forest Line Road
Ngong, Kajiado County, Kenya
Email: privacy@lindake.com

Individuals may also have the right to lodge a complaint with the Office of the Data Protection Commissioner.