Data Protection and Privacy Policy

Data Protection and Privacy Policy

Effective date: 4 July 2025
Last updated: 3 July 2026

1. Introduction

This Data Protection and Privacy Policy explains how Top Nairobi Escorts collects, uses, stores, shares and protects personal information when you access the website, create an account, submit a profile, purchase a listing, contact support or otherwise use our services.

We process personal data in accordance with applicable Kenyan data-protection requirements, including the Data Protection Act, 2019 and relevant regulations.

2. Who Controls Your Information

For information processed through this website, the data controller is:

Top Nairobi Escorts
Website: topnairobiescorts.com
Email: [PRIVACY EMAIL]
Location: Nairobi, Kenya

For privacy requests, use the subject line: Data Protection Request.

3. Information We Collect

3.1 Account Information

• Username.
• Email address.
• Password in encrypted or hashed form.
• Account type.
• Registration date.
• Account status.
• Login information.

3.2 Profile Information

• Public name.
• Age or date of birth.
• Gender.
• County, city and location.
• Phone number.
• WhatsApp or Telegram availability.
• Website and social-media usernames.
• Profile description.
• Languages.
• Physical characteristics.
• Availability.
• Rates.
• Services.
• Photographs and videos.
• Verification information.

3.3 Payment Information

We may collect:

• Transaction reference.
• Payment status.
• Package purchased.
• Amount and currency.
• Billing contact details.
• Payment-provider response information.

Complete card, mobile-money or banking credentials may be processed directly by the payment provider rather than stored by us.

3.4 Technical Information

We may automatically receive:

• IP address.
• Device type.
• Browser type.
• Operating system.
• Referring page.
• Pages viewed.
• Approximate location.
• Login history.
• Cookies and identifiers.
• Error logs.
• Security activity.

3.5 Communications

We may retain:

• Support requests.
• Reports and complaints.
• Verification correspondence.
• Refund requests.
• Emails.
• Other communications sent to us.

4. Sensitive Personal Data

Some profile information may be sensitive or highly personal, including photographs, identification information, age, gender, sexual-orientation information or other details voluntarily submitted for publication.

We process such information only where necessary and where an appropriate lawful basis exists.

Do not upload another person’s sensitive information unless you have clear authority and lawful permission to do so.

5. How We Collect Information

We collect information:

• Directly from you.
• When an authorized agency creates a profile.
• When you use the website.
• From payment providers.
• From security and fraud-prevention systems.
• From communications sent to us.
• From reports submitted by other users.

6. Why We Process Personal Information

We may process personal information to:

• Create and administer accounts.
• Publish and manage profile listings.
• Provide paid upgrades.
• Process and verify payments.
• Communicate about an account.
• Provide support.
• Verify age, identity or content ownership.
• Moderate profiles, photographs and reviews.
• Prevent fraud, trafficking, impersonation and misuse.
• Secure the website.
• Investigate complaints.
• Maintain records.
• Comply with legal obligations.
• Establish, exercise or defend legal claims.

7. Legal Bases for Processing

Depending on the circumstances, we process information because:

• It is necessary to provide a requested service or fulfil a contract.
• You have given consent.
• Processing is required to comply with a legal obligation.
• Processing is necessary for legitimate operational, security or fraud-prevention interests.
• Processing is necessary to protect vital interests.
• Processing is necessary for the establishment, exercise or defence of legal claims.

Where processing is based on consent, you may withdraw that consent. Withdrawal does not invalidate processing that occurred before consent was withdrawn.

8. Public Profile Information

Profile listings are intended to be publicly visible.

Information you place on a published profile may be:

• Viewed by website visitors.
• Indexed by search engines.
• Shared through profile links.
• Cached by browsers or search engines.
• Copied or captured by third parties outside our control.

You should not publish information you do not want publicly accessible.

Removing a profile from our website may not immediately remove copies already cached or independently stored by third parties.

9. Cookies and Similar Technologies

We may use cookies and related technologies to:

• Keep users signed in.
• Remember preferences.
• Support account security.
• Measure website traffic.
• Prevent abuse.
• Process referrals.
• Maintain sessions.
• Improve performance.

You can restrict cookies through your browser, but some website functions may stop working properly.

10. Sharing Personal Information

We may share information with:

• Website-hosting providers.
• Payment processors.
• Email-delivery providers.
• Security and anti-fraud providers.
• Analytics and technical service providers.
• Professional advisers.
• Contractors acting under our instructions.
• Law-enforcement or regulatory authorities where legally required.
• Another party involved in a business restructuring, acquisition or transfer.

Service providers should receive only the information reasonably necessary to perform their contracted functions.

We do not sell personal information to advertisers.

11. International Transfers

Some service providers may process or store information outside Kenya.

Where personal information is transferred internationally, we will take reasonable steps to use appropriate safeguards and ensure the transfer is permitted under applicable data-protection requirements.

12. Data Retention

We retain information only for as long as reasonably necessary for:

• Operating the account.
• Maintaining published listings.
• Completing transactions.
• Resolving disputes.
• Preventing fraud.
• Complying with financial and legal obligations.
• Enforcing agreements.
• Maintaining security records.

Retention periods may differ depending on the category of information.

When information is no longer required, we may delete, anonymize or securely archive it, subject to backup cycles and legal obligations.

13. Security

We use reasonable administrative, technical and organizational safeguards intended to protect personal information against:

• Unauthorized access.
• Accidental loss.
• Improper alteration.
• Disclosure.
• Misuse.
• Destruction.

However, no website, internet transmission or electronic-storage system can be guaranteed to be completely secure.

You are responsible for keeping your password confidential and using a secure email account and device.

14. Your Data-Protection Rights

Subject to applicable law and any lawful limitations, you may have the right to:

• Be informed how your personal data is used.
• Request access to your personal data.
• Object to certain processing.
• Request correction of inaccurate or misleading information.
• Request deletion of qualifying information.
• Withdraw consent where processing relies on consent.
• Request restriction of certain processing.
• Request transfer of eligible data.
• Complain about unlawful processing.

15. Exercising Your Rights

Send your request to [PRIVACY EMAIL].

Include:

• Your name.
• Account username.
• Email address associated with the account.
• The right you wish to exercise.
• The information concerned.
• Sufficient detail for us to understand the request.

We may request reasonable identity verification before releasing, correcting or deleting account information.

We may decline or limit a request where permitted by law, including where information must be retained for fraud prevention, legal compliance, dispute resolution or the protection of another person’s rights.

16. Profile Deletion

Account or profile deletion can be requested by contacting [PRIVACY EMAIL].

Before processing deletion, we may require account verification.

Deletion may not remove:

• Transaction records that must be retained.
• Security and fraud-prevention records.
• Records connected to an active dispute.
• Legally required records.
• Temporary backup copies.
• Content independently copied or cached by third parties.

17. Accuracy of Information

You should keep your account and profile information accurate and current.

You can update available fields through your account dashboard or contact us where a field cannot be edited directly.

We may request updated verification where information appears inconsistent, outdated or misleading.

18. Children

This website is not intended for anyone below 18 years old.

We do not knowingly permit minors to create accounts or appear in profiles.

Where we reasonably believe information concerns a minor, we may immediately:

• Remove the content.
• Suspend the account.
• Preserve relevant evidence.
• Investigate the matter.
• Report it to an appropriate authority where required.

19. Marketing Communications

We may send operational communications relating to:

• Registration.
• Payments.
• Renewals.
• Account security.
• Moderation.
• Profile status.
• Changes to the service.

Promotional messages may be sent where permitted.

You may unsubscribe from promotional communications, but essential account or transaction messages may still be sent.

20. Third-Party Websites

The website may contain links to WhatsApp, Telegram, Instagram, payment services and other third-party websites.

Their collection and processing of information are governed by their own privacy policies.

We are not responsible for the privacy or security practices of third-party platforms.

21. Complaints

First submit a privacy complaint to [PRIVACY EMAIL].

We will review the complaint and respond based on the available information.

You may also have the right to lodge a complaint with Kenya’s Office of the Data Protection Commissioner.

22. Changes to This Policy

We may update this policy when our services, systems, legal obligations or processing practices change.

The current version will be published on the website with its updated effective date.

23. Contact

Top Nairobi Escorts
Privacy email: [PRIVACY EMAIL]
Support email: [SUPPORT EMAIL]
Website: topnairobiescorts.com