Legal/Privacy Protocol

Data
Governance.

Effective as of April 7, 2026. This protocol outlines how Welsh Motors Ltd manages, encrypts, and secures your digital assets and identity.

Executive Summary

Encryption at rest and in transit.

Zero third-party monetization.

Authorized peer-to-peer data flow.

User-governed data deletion.

Verified dealer access control.

Asset Classification

Account Data

  • Name
  • Email
  • Phone
  • Password (hashed)

Profile Data

  • Avatar
  • Business Name
  • Location
  • Verification Status

Inventory Data

  • Vehicle Details
  • Photos
  • Availability
  • Pricing

Activity Data

  • Enquiries Made
  • Lead Interactions
  • Login History
  • Device Info

Authorized Sub-Processors

EntityProtocol PurposeData Variable
PostgreSQL DatabaseData storage and retrievalAll encrypted data
AWS / Cloud ProviderInfrastructure and backupsEncrypted backups, activity logs
SendGridEmail deliveryEmail, name, transaction data
M-Pesa APIPayment processingPhone, amount, transaction ID
PesapalCard paymentsCard tokens (never raw cards)
CloudflareSecurity and CDNIP address, page requests (anonymized)

1. Who We Are

Welsh Motors ("we", "us", "our") is operated by Welsh Motors Ltd, a Kenyan automotive marketplace. This Privacy Policy describes how we collect, use, protect, and share your personal data when you use our platform at welsh-motors.com ("Platform").

2. What Data We Collect

2.1 Account Information

Name
Email address
Phone number
Password (hashed, never stored plaintext)
Date of birth (for age verification)

2.2 Dealer Profile Data

Business name and registration number
KRA PIN
Physical address and county
Logo or avatars
Business description
Verification documents

2.3 Inventory & Listing Data

Vehicle specifications (make, model, year)
Pricing, mileage, condition
Photos and videos you upload
Contact information in listings

2.4 Interaction & Activity Data

Enquiries sent by buyers
Lead interactions and responses
Search queries
Pages visited and time spent
Device information (browser, OS, IP address)
Cookies and tracking pixels

2.5 Payment Data

M-Pesa phone number
Transaction IDs and amounts
Payment status and timestamps
Invoice records

3. How We Collect Data

3.1 Direct Collection

Data you provide when creating accounts, updating profiles, uploading listings, sending enquiries, or subscribing to plans.

3.2 Automatic Collection

IP addresses, browser cookies, device identifiers, and page click tracking via server logs and analytics tools.

3.3 Third-Party Sources

M-Pesa verification for phone numbers, KRA records for dealer validation, and analytics partners for aggregated usage data.

4. How We Use Your Data

4.1 Core Service Operations

Authenticating your account and managing login
Connecting buyer enquiries to dealer listings
Delivering lead notifications via email/SMS
Processing payments for subscriptions

4.2 Platform Improvement

Analyzing usage patterns to optimize UX
Identifying bugs and performance issues
A/B testing new features
Aggregating anonymized data for market research

4.3 Security & Compliance

Detecting fraudulent activity and abuse
Protecting against unauthorized access
Maintaining audit logs for disputes
Complying with KRA tax and legal obligations

4.4 Communication

Sending transactional emails (verification, reset codes, receipts)
Notifying about account activity and security alerts
Promotional emails (opt-out available)
Support responses and account recovery

5. Who We Share Data With

5.1 The Core Rule

We never sell, rent, or trade your personal data to third parties for marketing purposes. Full stop.

5.2 Service Providers (Data Processors)

We share limited data with essential service providers who are contractually bound to protect it and use it only for specified purposes (see list below).

5.3 Legal Requirements

We may disclose data if required by Kenyan law, court order, or government agency request. We will notify you unless legally prohibited.

5.4 Business Transfers

If Welsh Motors is acquired or merged, your data may transfer to the successor company under the same privacy obligations.

6. Buyer-to-Dealer Data Sharing

6.1 What Dealers See

When you (as a buyer) send an enquiry, the dealer receives your name, phone number, email, and enquiry message. This is necessary to facilitate the transaction.

6.2 Your Control

You can opt out of receiving dealer contact via your account settings. Dealers will still see your enquiry but will not be able to call/message you directly.

6.3 Dealer Responsibilities

Dealers are responsible for using your contact info only to respond to your enquiry. Welsh Motors is not liable for dealer misuse of your data. Report abuse to sec@welsh.co.ke.

7. Cookies and Tracking

7.1 Session Cookies

We use session cookies to keep you logged in and maintain security. These are deleted when you close your browser.

7.2 Analytics Cookies

Tools like Google Analytics track page views and user behavior to help us improve the platform. These data are anonymized and aggregated.

7.3 Opt-Out

Most browsers allow you to disable cookies via settings. Some platform features may not work without cookies (like login). You can also opt out of analytics tracking—contact sec@welsh.co.ke.

8. Data Security

8.1 Encryption

Data in transit is encrypted using HTTPS/TLS. Sensitive data at rest (passwords, payment info) is hashed or tokenized—we never store raw credit card or full M-Pesa data.

8.2 Access Controls

Only authorized employees with a business need can access personal data. Access is logged and monitored.

8.3 Limitations

While we implement industry-standard security, no system is 100% risk-free. Welsh Motors is not liable for breaches caused by factors beyond our reasonable control (e.g., zero-day exploits, stolen credentials shared with third parties).

8.4 Incident Response

If we discover a breach affecting your data, we will notify affected users within 30 days and describe the breach, data involved, and remediation steps.

9. Data Retention

9.1 Active Accounts

While your account is active, we retain account, profile, and activity data to provide services and maintain platform history.

9.2 After Deletion

If you delete your account, we retain core data (transactions, enquiries) for 90 days for dispute resolution, then archive or anonymize it. Backups may contain older copies for up to 12 months.

9.3 Legal Holds

If you are involved in a dispute or investigation, we retain all relevant data indefinitely until the matter is resolved.

9.4 Aggregated Data

We may retain anonymized, aggregated data ("5,000 dealers listed 100K cars") indefinitely for analytics and market research.

10. Your Rights (GDPR-Inspired)

10.1 Access

You can request a copy of all personal data we hold about you. Contact sec@welsh.co.ke with "Data Subject Access Request." We will respond within 30 days.

10.2 Correction

You can update your profile information directly in your account settings. Contact support if you need help correcting locked fields.

10.3 Deletion

You can request deletion of your account and associated data. Some data (transaction records) may be retained for legal/audit purposes but will be anonymized.

10.4 Portability

You can request your data in a portable format (CSV). We will provide it within 30 days.

10.5 Opt-Out of Marketing

Unsubscribe from promotional emails by clicking the link in any marketing email or updating your notification preferences.

11. International Data Transfers

11.1 Kenya-Based Operations

Welsh Motors primarily operates from Kenya and stores data in Kenyan and regional African data centers. Some backup copies may be stored in secure international locations for redundancy.

11.2 GDPR Compliance

If you are in the EU, we comply with GDPR requirements including data processing agreements and legitimate interest assessments.

12. Children's Privacy

12.1 Age Requirement

The Platform is not intended for users under 18 years old. We do not knowingly collect data from minors.

12.2 Parental Consent

If a minor has created an account, we will delete it upon request from a parent or guardian.

13. Third-Party Links and Services

13.1 External Links

The Platform may link to external websites (Google Maps, news sites, etc.). We are not responsible for their privacy practices. Review their privacy policies separately.

13.2 Embedded Content

Embedded maps, videos, or widgets from third parties may collect data independently. Refer to their privacy policies.

14. Policy Changes

14.1 Updates

We may update this Privacy Policy at any time. Changes are effective when posted. Your continued use of the Platform constitutes acceptance of updated policy.

14.2 Significant Changes

If changes materially affect how we use your data, we will email you at least 30 days before the effective date and allow you to opt-out by deleting your account.

15. Contact & Requests

15.1 Privacy Officer

Welsh Motors Ltd Privacy Officer: sec@welsh.co.ke

15.2 Support

General inquiries: sec@welsh.co.ke

15.3 Legal Requests

Formal data requests or legal matters: sec@welsh.co.ke

15.4 Response Time

We will respond to data requests within 30 days. Complex requests may require more time.

Privacy Terminal

sec@welsh.co.ke

Legal Hub

sec@welsh.co.ke

Station HQ

Nairobi Terminal, Kenya