Privacy Statement

1. Who is responsible for your information

Lease Platform is operated by CN Holdings Ltd, located at P.O. Box 28995-00100, Nairobi, Kenya. Contact properties@cnholdings.co.ke for privacy questions and requests.

Our responsibilities depend on the information involved. We determine how account-registration, platform-subscription, support and service-security information is used. A landlord or property manager normally determines why tenant and rental records are collected and how they are used to manage a tenancy; we process those records to provide the service on that customer's instructions. A landlord may have its own privacy notice and legal obligations. A payment provider has its own responsibilities for payment information it handles.

This statement covers our website, platform accounts, property-management service and related support. It does not make your landlord's decisions our decisions, or replace a landlord's obligation to give you an appropriate notice.

2. Information we handle

Depending on the features used, we handle:

• Account and contact details, such as names, email addresses, telephone numbers, organisation details, account roles and invitation history.
• Property, unit and tenancy information supplied by an authorised landlord or manager, including rental locations, tenancy dates, tenant contact details and agreements.
• Rental administration records, including invoices, recorded payments, receipts, utilities and readings, deposits, deductions, refunds, penalties, statements and settlement history.
• Repair requests, follow-up messages, vacating notices and review decisions. Some staff notes are restricted and are not shared in the tenant portal.
• Agreement and acceptance evidence, such as a typed signing name, declarations, document version, signing date/time and a drawn signature where that signing process uses one.
• Platform-subscription information, such as the selected currency, unit quantity, quoted amount, provider reference and verified payment status.
• Support messages and technical information needed to operate and protect the service, which may include IP addresses, browser/device information, session records, security events and application logs.

Passwords are stored using password hashing. Do not put card numbers, payment PINs, one-time codes, account passwords, unnecessary identity documents or sensitive family/health details in free-text fields or support messages. We do not need your payment-provider password to support your account.

3. Where information comes from

You provide information when you contact us, register, accept an invitation, use your account, sign an agreement or make a request. Landlords and managers provide rental records, including through authorised CSV imports. We receive relevant transaction confirmations from payment providers. Our systems also produce essential session, delivery, audit and security records.

Receiving an invitation or having an email address in a tenant record does not, by itself, give another person access to your account. Portal access is based on explicit invitations and active account links.

4. Why we use information

We use information to provide and support the platform; authenticate users; manage invitations and permissions; maintain property and tenancy records; calculate and record configured charges; provide documents and reports; process platform-subscription payments; send requested or enabled service communications; investigate errors, disputes and misuse; meet applicable obligations; and establish or defend legal claims.

The relevant basis may be performing a contract, steps requested before a contract, compliance with a legal obligation, a legitimate interest balanced against individual rights, or consent where consent is required. Landlords must establish an appropriate basis for their own tenant-data processing. Agreeing to the platform's terms or acknowledging this statement is not blanket consent to every use of personal data.

Optional marketing, if offered, requires a separate choice. It must not be preselected or made a condition of accessing essential rental information. We do not sell tenant records or make them a public property listing.

5. Access within the platform

Landlord accounts have separate records and role-based permissions. A tenant sees records available through their explicitly linked, active tenant accounts. A shared login can have links to more than one landlord; that does not merge the landlords' accounts or expose unrelated records.

Authorised owners and managers can access information necessary for their property-management roles. Suspension of one landlord membership or tenant link does not automatically remove access granted independently by a different landlord. Platform operators may need restricted access for support, security, backup or recovery responsibilities; that access must be limited to its purpose and authorised personnel.

6. Payments: Paystack and PayPal

The selected platform-subscription payment routes are Paystack for KES and PayPal for USD, once checkout is configured and enabled. Subscription payments are separate from rent, utility payments and tenant deposits recorded by a landlord.

Checkout may disclose the payer's contact details, an order/reference, currency and amount to the selected provider. The provider processes payment credentials through its own checkout. We use the transaction identifiers and verified status needed to reconcile the subscription and handle support; we do not ask you to enter card PINs or provider-account passwords into Lease Platform.

Payment providers may process information in other countries and retain records under their own obligations. Read the Paystack Kenya privacy and terms information or PayPal Kenya Privacy Statement before paying. Provider policies do not replace this statement for information we control.

7. Communications and cookies

Essential cookies support sign-in, sessions, request security and platform operation. This release does not include advertising trackers or third-party marketing analytics. If optional analytics or advertising are introduced, we will describe them and provide any choice required before they operate. Payment providers may use their own cookies in their checkout environment.

Rental notifications depend on the landlord's settings and the active tenant account's preferences. Security and account-recovery communications are separate from optional rental notifications. Invoice, receipt, settlement and refund notices use authenticated portal links. Signed tenancy-agreement delivery can include the locked signed PDF for the eligible parties. Review mailbox access and device security before requesting emailed documents.

8. Service providers, hosting and disclosure

Lease Platform is hosted by Truehost Cloud. We use necessary hosting, database, email, payment and backup/recovery services. Access must be limited to the relevant task and appropriate contractual, confidentiality and security arrangements. Encrypted backups are currently held privately on the application server, with recovery keys preserved separately. Automated off-site backup storage has not been connected. For information about hosting regions, provider processing locations or a specific data-residency requirement, contact properties@cnholdings.co.ke before uploading information subject to that requirement. Provider access is subject to appropriate confidentiality and data-processing safeguards.

We may disclose relevant information when legally required, to respond to a lawful request, protect rights or security, investigate suspected fraud, or complete a business transfer subject to appropriate protections. We do not give other landlords unrestricted access to a customer's tenant records.

Where information is transferred outside Kenya, the responsible controller must identify and apply the safeguards or other lawful conditions required for that transfer. We do not treat acceptance of the usage agreement as a general waiver of transfer protections.

9. Retention, corrections and backups

We retain account information while needed to operate the relationship and for justified security, dispute-resolution and legal purposes. Rental and financial records may need to remain available to the responsible landlord to meet contractual, record-keeping or legal obligations. A correction, suspension or cancellation is not an instruction to silently rewrite or delete financial history.

Retention decisions consider the purpose of a record, applicable obligations, outstanding disputes, verified deletion requests and whether it can be securely deleted or anonymised. Our standard schedule is:

• Account and rental information: while the account is active and reasonably necessary for the service, subject to rights requests and periodic review.
• Required closed-tenancy financial records, agreements and acceptance evidence: a six-year review period after the relevant relationship closes, subject to applicable obligations, unresolved balances and documented legal holds. This is not a blanket permission to retain unrelated personal information.
• Rotating application/security logs: normally 90 days. Incident evidence may be retained longer under a documented hold.
• Unaccepted expired invitations: removed after 30 days. Import preview contents are cleared when the preview expires, which is normally earlier than 30 days; confirmation metadata may remain as audit evidence.
• Expired landlord subscriptions: seven days of grace, then read-only access through day 90 after the paid or evaluation period ends. Account closure starts a retention review; operational deletion is scheduled for day 120, subject to operator review and documented legal holds. Required financial/tenancy agreement evidence is moved into a restricted encrypted archive before operational records are removed. That archive is reviewed for disposal after six years; it has no landlord or tenant download route.
• Shared user accounts: closure of one landlord does not delete a login or independent records needed for another landlord. You may separately request closure of your own login.

The system prepares retention reviews daily for operator action. Overdue reviews are flagged; deletion is not an unchecked scheduled mass deletion. A hold delays disposal, not the normal expiry of customer access. We retain only justified evidence and review continuing need; a dispute or statutory requirement can change the normal disposal date.

The configured operator-backup design uses encrypted snapshots and keeps the latest successful daily snapshots for up to 30 days. Backups are private operator records covering the platform database and defined upload folders; they are not landlord or tenant downloads. Recovery keys are held separately. Off-site storage and restore procedures require operator configuration. Copies needed for a verified recovery are subject to restricted access and retention, and verified corrections/deletion instructions must be considered after a restore.

10. Your choices and rights

Subject to applicable conditions and lawful restrictions, you may ask to be informed about processing, access your information, correct inaccurate information, object to relevant processing, withdraw consent where consent is the basis, or request deletion or other remedies available under applicable law. Withdrawing consent does not undo processing that was lawful before withdrawal.

Contact properties@cnholdings.co.ke. We may verify your identity and authority and ask which account or landlord the request concerns. We will avoid requesting unnecessary information. For a landlord-controlled rental record, we may need to refer the request to that landlord and assist them; you can also contact the landlord directly. We will explain where a legal obligation or another person's rights limits what can be disclosed or erased.

You may complain to Kenya's Office of the Data Protection Commissioner where its jurisdiction applies. Further information about Kenyan data-subject rights is available from the ODPC.

11. Security, incidents and children

We use proportionate access, authentication, encryption and operational safeguards. No service can promise absolute security. Report suspected account compromise or unintended disclosure promptly to properties@cnholdings.co.ke. We will investigate and make notifications required by applicable law without promising a response or notification deadline that has not been assessed for the incident.

Public account registration is intended for adults able to enter the agreement. A landlord should not upload children's information unnecessarily and must meet the applicable requirements when a rental record legitimately involves a child. Do not create a child's platform login as a substitute for an appropriate authorised adult process.

12. Changes and contact

We identify the published document's version and date and keep the acceptance evidence associated with the version presented to a registering user. Material changes will be communicated through appropriate service channels; a new acknowledgement or agreement may be required where appropriate. Contact properties@cnholdings.co.ke or write to CN Holdings Ltd, P.O. Box 28995-00100, Nairobi, Kenya.