Last updated 4 July 2026
Meclon Tax and Consultancy Ltd is the Data Controller responsible for processing personal information collected through the CiviFact Platform (the "Platform"), operating under the laws of the Republic of Kenya. This Privacy Policy explains what personal information we collect, why we collect it, how we use it, and the rights you have over it. This Policy should be read together with our Terms and Conditions and our Cookie Policy.
We apply this Policy identically to every user. No account, including those belonging to government officials, public figures, organizations, or Meclon employees, receives different data-handling treatment, additional data suppression, or special deletion rights beyond what is described here for all users.
When you create an account, we collect your email address, a securely hashed password, your display name, handle, and country (which you select, it is not detected automatically). If you sign up using Google Sign-In, we instead receive your Google account identifier, email, name, and profile picture; we do not request any additional Google permissions.
You may choose to add a bio, avatar and banner images, your city, job title, organization, website, and language and notification preferences. Country and city fields are always entered by you, we do not use device location, IP-based geolocation, or reverse geocoding to determine or verify them. If you apply for identity verification, you may submit identity documents for review; verification eligibility and review are based on the same criteria for every applicant (see our Terms, Section 7).
You must already be a registered CiviFact user to apply for the Tally Agent role, your identity for this purpose is established through your existing CiviFact account, not through a separate ID document. If you opt in to become a Tally Agent, we additionally collect your phone number, a selfie photograph, your assigned station, and, on each result submission or confirmation you make, the precise GPS location and accuracy of your device at that moment. We do not separately collect or hash a voter-card number for this purpose, since account-based identity already fulfills the purpose of knowing exactly who the agent is.
Before accepting a submission, we validate that it originates from within a predefined geofenced radius of your assigned polling station. We also record technical metadata associated with each submission, including a cryptographic hash of the uploaded result-form image (for example, SHA-256), to support integrity verification, fraud prevention, auditing, and quality assurance. This hash lets us demonstrate that an image has not been altered after upload; it is derived from the image itself and is not, on its own, personal information about you, but we disclose it here because it is generated and retained as part of your submission record.
This is the only feature on the Platform that collects precise device location, and it is collected only because you have actively chosen to take on the Tally Agent role; the location permission is requested specifically at that point in the app, not on general Platform use. Because this data relates to political participation and election observation, it is treated as sensitive personal data under the Kenya Data Protection Act, 2019 (the selfie photograph in particular is biometric data, a recognized sensitive category), and is processed only for the stated purposes of election result verification, integrity checking, fraud prevention, auditing, and quality assurance, based on your explicit consent given during Tally Agent registration. This applies equally to every Tally Agent regardless of which candidate, party, or station they are assigned to.
The results CiviFact's Tally feature displays, including candidate/aspirant names and the votes recorded against each of them at a given polling station, come from official result forms (e.g., Form 34A) that are already publicly posted at each polling station. This information relates to candidates and aspirants, not to CiviFact users, and is not collected from them directly, we source it from the same publicly posted forms any member of the public can view at the station. Because it identifies individuals (the candidates/aspirants) alongside their results, it is personal data about those individuals, processed on the basis of our legitimate interest in election transparency and verification of information that is, by its nature, already part of the public record. If a candidate or aspirant has a concern about how their publicly posted result is displayed on CiviFact, they may contact us using the details in Section 16.
We have designed the Platform to avoid collecting personal information we do not need:
Analytics exception: on our web (browser-based) application only, we may use Firebase / Google Analytics for basic usage analytics if enabled for that build. This is currently our only analytics or measurement integration. We do not use it in our mobile apps.
We use your information to:
Certain features, including CiviScore, consensus verdict calculation, and the Master Assertion Score, involve automated, algorithmic scoring of users and content. These scores inform what you see and what actions are available to you (for example, some actions require a minimum reputation level), but no solely automated process results in a final account suspension, ban, or other legal-effect decision about you, such actions involve human moderator review. No account receives manual adjustment to these scores outside the standard algorithmic process.
If you are shown sponsored content on CiviFact, it is targeted using general topic interest and location only, never using cross-site tracking, browsing history from other sites or apps, or device fingerprinting, consistent with Section 4. Sponsored content and advertising data are kept architecturally separate from CiviScore, MAS, and Community Verification systems, advertising has no influence on and no access to those scoring systems. If you run a CiviAds campaign, we process the targeting and budget information you provide solely to deliver and bill for that campaign; see our Terms, Section 12, for advertising content rules, including our policy against political and election-related advertising.
Depending on the processing activity and applicable law, we rely on: your consent (for example, Tally Agent registration and optional profile fields), performance of our contract with you (operating the account and core features you use), our legitimate interests (platform safety, security, and improvement), and compliance with legal obligations.
Some of our processors (including Cloudinary, Google, and Expo-related services) operate infrastructure outside Kenya, including in the United States. Where personal information is transferred internationally, we take reasonable steps to ensure it continues to receive an appropriate level of protection, consistent with the requirements of the Kenya Data Protection Act, 2019.
We apply a range of technical and organizational measures to protect your information, including: securely hashed passwords, two-factor authentication for administrative accounts, encrypted connections to our database in production, strict access controls and rate limiting, security headers and a content security policy, input validation and sanitization, signed and time-limited upload URLs, and secure on-device storage of authentication tokens in our mobile app. No system can be guaranteed completely secure, and we continue to improve these measures over time.
We retain personal information for as long as your account is active and as needed to provide the Platform, comply with our legal obligations, resolve disputes, and enforce our agreements.
Some records, including search history, login history, email logs, and Tally-agent submission data, do not currently have an automated deletion schedule; we are working to introduce defined retention periods for these categories and will update this Policy when they are in place. In the meantime, you can delete your own search history at any time via your account settings, and you may request deletion of your account as described below.
You may request deletion of your account at any time. Please note that account deletion anonymizes your public profile (your display name, handle, and email are scrambled and your account is marked deleted) rather than erasing all associated data. Content you posted, direct messages, Tally-agent records (including phone number, hashed voter-card data, and submission history), and your search and login history may be retained in de-identified or aggregated form for safety, audit, legal, or record-keeping purposes, consistent with this Policy. This process is identical for every account. We are working toward more complete deletion capabilities and will update this Policy as they are implemented.
Subject to applicable law, including the Kenya Data Protection Act, 2019, you have the right to:
These rights are available to every user on the same terms. To exercise them, contact us using the details in Section 16. We may need to verify your identity before acting on a request.
CiviFact does not knowingly collect personal information from persons under the age of 18, other than through approved school or classroom organization arrangements with appropriate safeguards. If we become aware that personal information belonging to a person under 18 has been collected outside such an arrangement, we will take reasonable steps to delete the information and terminate the associated account.
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will post the updated Policy on the Platform and update the "Last updated" date above. Material changes may also be communicated by email or in-app notice.
If you have questions about this Privacy Policy or wish to exercise your data protection rights, please contact Meclon Tax and Consultancy Ltd through the contact details published on the Platform.
