SOKI ("we", "us", or "our") operates a venue-based anonymous social chat platform accessible via the SOKI mobile application and related services (collectively, the "Service"). This Privacy Policy explains how we collect, use, disclose, retain, and protect your personal information when you use our Service, and describes the rights available to you under applicable law.

This Policy applies to all users globally, with specific provisions for users in the Republic of Kenya (Kenya Data Protection Act, 2019), the European Economic Area and United Kingdom (General Data Protection Regulation — GDPR / UK GDPR), and the United States (including the California Consumer Privacy Act — CCPA/CPRA, and the Children's Online Privacy Protection Act — COPPA).

By using the Service you confirm that you have read, understood, and agree to this Privacy Policy. If you do not agree, please discontinue use of the Service.

1. Data Controller & Contact Details

SOKI is the data controller responsible for your personal information.

• Company: SOKI
• Registered Address: Nairobi, Kenya
• Privacy Enquiries: privacy@soki.co.ke
• Legal / Data Protection: legal@soki.co.ke
• General Support: support@soki.co.ke

For EEA/UK users: if you are dissatisfied with our response to a privacy complaint, you have the right to lodge a complaint with your local supervisory authority. For Kenyan users, complaints may be directed to the Office of the Data Protection Commissioner (ODPC).

2. Information We Collect

2.1 Information You Provide Directly

• Account credentials: Email address and password when you choose to secure your account. Anonymous accounts may be created without an email address.
• Profile information: Username, profile emoji, profile photograph, bio, and interests.
• User-generated content: Text messages, images, videos, audio messages, documents, GIFs, stickers, location shares, and RealMoments (dual-camera photo/video posts) that you post through the Service.
• Referral information: Username of any person who referred you to the Service.
• Communications: Any correspondence you send to us, including support requests and appeals against moderation decisions.

2.2 Information Collected Automatically

• Device identifiers: Firebase Anonymous User ID (UID), device type, operating system version, and app version.
• Push notification tokens: Expo push token and platform-specific tokens used to deliver notifications.
• Location data: Approximate location derived from venue QR code scanning to place you in the correct venue context. We do not continuously track or permanently store precise GPS coordinates.
• Usage data: Features accessed, messages sent, moments posted, reactions given, timestamps of activity, and presence/online status within venues.
• Log data: Error logs and diagnostic information to maintain service quality.

2.3 Content Moderation Data

To enforce our Community Guidelines, we collect and process:

• Moderation records: Strike counts (soft and hard), violation categories, timestamps, and enforcement actions applied to your account.
• Flagged content references: References (not the full content) to messages, images, or videos that were flagged by our automated systems or reported by other users.
• Email ban history: Where your account has been subject to significant enforcement action, a record linked to your email address may be retained to prevent evasion of bans on re-registration.
• Report data: Reports you submit about other users, and reports submitted about you by other users.

2.4 Information from Third Parties

• Firebase (Google LLC): Authentication, real-time database, cloud storage, and push messaging services.
• OpenAI: Text content submitted for moderation is processed by OpenAI's Moderation API. We do not send identifying information alongside content to OpenAI.
• Google Cloud Vision: Images and video frames submitted for moderation are processed by Google Cloud Vision SafeSearch.
• Paystack: Payment information for venue operators. End-user payment data is processed directly by Paystack and not stored on our servers.
• Resend: Email delivery service used to send transactional emails.

3. Legal Basis for Processing (EEA / UK / Kenya)

We process your personal data on the following legal bases:

For Kenyan users: processing is conducted in accordance with the Kenya Data Protection Act, 2019 (DPA 2019) and associated regulations. For EEA/UK users: processing is conducted under GDPR Article 6 and, where applicable, Article 9.

4. How We Use Your Information

• Service delivery: Creating and managing your account, facilitating messaging, displaying your profile to other users in your venue, and enabling RealMoments.
• Content moderation: Automatically scanning messages, images, videos, bios, and usernames using AI systems to detect policy violations before or immediately after content is published. See Section 7 for full details.
• Safety and security: Detecting fraud, preventing abuse, enforcing bans, and maintaining platform integrity.
• Notifications: Delivering push notifications about messages, reactions, RealMoments, and venue updates.
• Communications: Sending account-related emails including email verification, moderation notices, and support responses.
• Legal compliance: Responding to lawful requests from law enforcement, court orders, or regulatory authorities, and fulfilling mandatory reporting obligations including CSAM reports to relevant national authorities.
• Service improvement: Analysing usage patterns to improve features, fix bugs, and optimise performance.
• Dispute resolution: Reviewing moderation appeals and resolving disputes between users.

5. RealMoments and Venue Access

RealMoments are dual-camera photo and video posts that you submit in response to venue-triggered moments. By posting a RealMoment, you acknowledge and agree to the following:

• Venue visibility: RealMoments are visible to other users within the same venue and are accessible to the venue operator through the SOKI venue dashboard.
• Venue download and marketing use: Venue operators may view, download, and use your RealMoments for legitimate marketing and promotional purposes, including but not limited to social media posts, website content, and printed materials, provided such use does not violate your dignity, constitute harassment, or be used for purposes that would shame, defame, or discriminate against you. Venue operators are contractually prohibited from using RealMoments in any manner that constitutes a privacy violation, public shaming, non-consensual intimate imagery, or any other unlawful use.
• Anonymity: RealMoments are associated with your anonymous username within the app. Venue operators can see the content but cannot access your email address or other personally identifying account information through the dashboard.
• Content moderation: All RealMoments are automatically scanned by our AI moderation systems before being made visible. RealMoments containing prohibited content are rejected and never displayed to other users or venue operators.
• Withdrawal: You may delete your RealMoments from the app at any time. Deletion removes the content from our servers and the venue dashboard. We cannot guarantee retrieval of any copies already downloaded by a venue operator prior to deletion.
• Consent: By submitting a RealMoment, you grant SOKI and the relevant venue operator a non-exclusive, royalty-free licence to use that content for the purposes described above. This licence terminates upon deletion of the content, subject to the caveat above regarding already- downloaded copies.

Important: If you believe a venue operator has used your RealMoment content unlawfully or in violation of these terms, please contact us immediately at privacy@soki.co.ke. We will investigate and, where appropriate, take action against the venue's access to our platform.

6. How We Share Your Information

We do not sell your personal information. We share information only in the following circumstances:

6.1 With Other Users

Your username, profile emoji or photo, bio, interests, and messages are visible to other users within the same venue. Your email address is never visible to other users.

6.2 With Venue Operators

Venue operators can view RealMoments, chat activity (in aggregate), and moderation-related information relevant to their venue. They cannot access your email address, device identifiers, or payment information.

6.3 With Service Providers

We share data with third-party processors who assist us in operating the Service, including:

• Google LLC (Firebase, Google Cloud): Infrastructure, authentication, storage, and moderation.
• OpenAI: Text moderation. Content is processed under OpenAI's API terms; we do not share identifying account information with OpenAI alongside content submissions.
• Paystack: Payment processing for venue operators.
• Resend: Transactional email delivery.

All processors are bound by data processing agreements requiring them to handle your data only as directed by us and in accordance with applicable law.

6.4 For Legal Reasons

We may disclose your information where required by law, court order, or governmental authority, or where we believe disclosure is necessary to:

• Comply with a legal obligation;
• Protect the rights, property, or safety of SOKI, our users, or the public;
• Report child sexual abuse material (CSAM) to the National Centre for Missing and Exploited Children (NCMEC), the Kenya National Police Service, or other competent national authorities as required by applicable law.

6.5 Business Transfers

In the event of a merger, acquisition, reorganisation, or sale of assets, your information may be transferred as part of that transaction. We will notify you via email or prominent in-app notice before your information is transferred and becomes subject to a different privacy policy.

7. Automated Content Moderation and AI Processing

SOKI operates a multi-layer automated content moderation system to protect users from harmful, illegal, and policy-violating content. You acknowledge and agree that:

7.1 What Is Scanned

• Text messages: All text messages in group and private chats are scanned server-side by OpenAI's Moderation API after delivery (post-screening).
• Images: All images uploaded to chats, RealMoments, and profile photos are scanned by Google Cloud Vision SafeSearch before being made visible (pre-screening).
• Videos: Video content is processed by extracting representative frames which are then scanned by Google Cloud Vision SafeSearch before the video is made visible (pre-screening).
• Usernames and bios: Usernames and bios are scanned by our keyword filter and OpenAI's Moderation API before being saved to your profile.

7.2 How Decisions Are Made

Our automated systems classify content into severity tiers and apply proportionate enforcement actions including content removal, account muting, temporary suspension, and permanent account termination. All automated decisions are subject to appeal (see Section 10.6). We maintain human oversight at the account level — individual content decisions are automated, but account-level enforcement actions that result in muting or banning are reviewed by our moderation team.

7.3 CSAM Detection and Mandatory Reporting

Any content detected as child sexual abuse material (CSAM) is immediately removed, the associated account is permanently suspended, and the content and account information are reported to the relevant national authority and/or NCMEC as required by applicable law. We do not delete CSAM evidence — it is preserved for law enforcement purposes. This obligation overrides any contractual or privacy considerations.

7.4 No Guarantee of Detection

While we invest significantly in content moderation, no automated system is perfect. We do not guarantee that all harmful content will be detected or removed. Users are encouraged to use the in-app report feature to flag content that our systems may have missed.

8. Data Retention

When you delete your account, your personal information is immediately stripped from your profile, your Firebase Authentication account is permanently deleted, and your username is released. A soft-deleted shell of your profile is retained for 30 days (without any personal data) to maintain chat history integrity for other users, after which it is archived.

9. International Data Transfers

SOKI is based in Kenya and uses infrastructure providers (Google Firebase, OpenAI) whose servers are located primarily in the United States. By using our Service, you acknowledge that your data may be transferred to, stored in, and processed in countries outside your country of residence, including countries that may not have the same level of data protection as your home country.

For EEA/UK users: transfers to the United States are made pursuant to appropriate safeguards including Standard Contractual Clauses (SCCs) as provided by our infrastructure partners. For Kenyan users: transfers are conducted in accordance with the requirements of the Kenya Data Protection Act, 2019, and applicable regulations on cross-border data transfers.

10. Your Privacy Rights

10.1 Rights Available to All Users

• Access: Request a copy of the personal data we hold about you.
• Correction: Request correction of inaccurate or incomplete data.
• Deletion: Request deletion of your account and associated personal data via the Privacy Settings screen in the app, or by emailing privacy@soki.co.ke.
• Objection: Object to processing of your data for legitimate interest purposes.
• Withdrawal of consent: Where processing is based on consent (e.g., push notifications), withdraw consent at any time through device settings.

10.2 Additional Rights for EEA / UK Users (GDPR)

• Portability: Receive your data in a structured, machine-readable format.
• Restriction: Request restriction of processing in certain circumstances.
• Automated decision-making: Request human review of automated moderation decisions that significantly affect you.
• Supervisory authority: Lodge a complaint with your national data protection authority.

10.3 Additional Rights for California Users (CCPA/CPRA)

• Right to know what personal information is collected, used, shared, or sold.
• Right to delete personal information (subject to exceptions).
• Right to opt out of sale or sharing of personal information. We do not sell your personal information.
• Right to non-discrimination for exercising CCPA rights.
• Right to correct inaccurate personal information.
• Right to limit use of sensitive personal information.

10.4 Rights for Kenyan Users (DPA 2019)

• Right to be informed of processing activities.
• Right to access your personal data.
• Right to correct false or misleading data.
• Right to object to processing.
• Right to deletion (subject to legal obligations).
• Right to lodge a complaint with the Office of the Data Protection Commissioner (ODPC).

10.5 Exercising Your Rights

To exercise any of the above rights, contact us at privacy@soki.co.ke. We will respond within 30 days (or within any shorter period required by applicable law). We may require identity verification before processing your request. Requests are free of charge; we reserve the right to charge a reasonable fee for manifestly unfounded or excessive requests.

10.6 Moderation Appeals

If your content was removed or your account was actioned by our automated moderation system and you believe this was in error, you may submit an appeal using the in-app "Appeal" button on the flagged content, or by contacting support@soki.co.ke. Appeals are reviewed by our human moderation team. Decisions on appeals are final.

11. Children's Privacy

The Service is intended for users aged 16 and over (or such higher age as required by applicable law in your jurisdiction). We do not knowingly collect personal information from children under 16. If you are under 16, please do not use the Service or provide any personal information.

For US users: the Service is not directed to children under 13 within the meaning of COPPA. If we become aware that we have collected personal information from a child under 13, we will delete it immediately.

If you believe a child under the applicable minimum age has created an account, please contact us at privacy@soki.co.ke with the subject line "Minor Account".

12. Data Security

We implement appropriate technical and organisational measures to protect your personal information including:

• Encryption of data in transit (TLS) and at rest (Firebase encryption).
• Authentication token verification on all server-side API endpoints.
• Firebase Security Rules restricting database read/write access to authenticated users.
• Server-side enforcement of account bans preventing write operations even from modified clients.
• Separation of user-facing data from moderation/administrative data.
• Regular review of access controls and security configurations.

No method of transmission or storage is 100% secure. While we strive to protect your data, we cannot guarantee absolute security. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and relevant authorities as required by applicable law (within 72 hours for EEA/UK users under GDPR; within the timeframes required under Kenyan law).

13. Cookies and Similar Technologies

The SOKI mobile application does not use browser cookies. We use device-local storage (MMKV) to cache certain preferences and session data on your device. This data does not leave your device except as part of normal Service operation. Our website (soki.co.ke) may use cookies for analytics and functionality; a separate cookie notice is provided on the website.

14. Do Not Track

Some browsers offer a "Do Not Track" (DNT) feature. Our mobile application does not respond to DNT signals, as there is no industry-standard interpretation of DNT for mobile apps.

15. Third-Party Links and Services

The Service may contain links to third-party websites or services. This Privacy Policy does not apply to those third parties. We encourage you to review the privacy policies of any third-party services you access through our Service.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. We will notify you of material changes by:

• Posting the updated Policy with a new "Last Updated" date;
• Displaying a prominent in-app notice; and/or
• Sending an email notification to registered email addresses where the change is material.

Your continued use of the Service after the effective date of the updated Policy constitutes your acceptance of the changes. If you do not agree to the updated Policy, you must discontinue use of the Service and may delete your account.

17. Contact Us

For any privacy-related enquiries, requests, or complaints:

• Privacy: privacy@soki.co.ke
• Legal: legal@soki.co.ke
• Support: support@soki.co.ke
• Address: Nairobi, Kenya

EEA/UK users may also contact our EU/UK representative at legal@soki.co.ke. Kenyan users may contact the Office of the Data Protection Commissioner (ODPC) at www.odpc.go.ke.