Legal

PRIVACY POLICY

Last Updated:18 June 2026.

Published 17 June 2026Updated 25 July 2026

PRIVACY POLICY

1. Introduction

Kozi Sports ("Kozi Sports," "we," "us," or "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our AI-powered sports prediction platform.

This Privacy Policy is developed in compliance with the Kenya Data Protection Act, 2019 (DPA) and the EU General Data Protection Regulation (GDPR), where applicable. By using the Platform, you consent to the data practices described in this policy.

2. Data Controller and Data Protection Officer

Data Controller: Kozi Sports is the data controller responsible for your personal data. As a data controller, we determine the purpose and means of processing your personal data.

Data Protection Officer (DPO): We have appointed a Data Protection Officer to oversee compliance with this Privacy Policy and applicable data protection laws. You can contact our DPO at: dpo@kozisports.link

Registration: Kozi Sports is registered as a Data Controller with the Office of the Data Protection Commissioner (ODPC) in Kenya.

3. Information We Collect

3.1. Information You Provide

  • Registration Information: Name, email address, phone number, and password.
  • Payment Information: Processed by Paystack. We do not store full payment card details.
  • Account Preferences: Your selected leagues, teams, and prediction preferences.
  • Communications: Information you provide when contacting our support team.

3.2. Information Collected Automatically

  • Usage Data: IP address, browser type, device information, pages visited, and time spent on the Platform.
  • Transaction Data: Token purchases, subscription details, and prediction history stored in our Ledger-1st DB.
  • Cookies and Similar Technologies: We use cookies to enhance your experience.

3.3. Information We Do NOT Collect

We do not collect sensitive personal data as defined under the Kenya Data Protection Act (race, health status, ethnic origin, beliefs, biometric data, etc.).

4. How We Use Your Information

We process your personal data for the following purposes:

  • To register and manage your Account – Performance of a contract
  • To process payments (via Paystack) – Performance of a contract
  • To provide predictions and AI Insights – Performance of a contract
  • To maintain our internal ledger (Ledger-1st DB) – Performance of a contract / Legal obligation
  • To send service-related communications – Legitimate interests
  • To improve the Platform – Legitimate interests
  • To comply with legal obligations – Legal obligation
  • To enforce our Terms and Conditions – Legitimate interests

5. AI and Third-Party Data Processing

5.1. Prediction Generation

When you request a prediction, we send match data (obtained from third-party API providers) to our pre-trained Machine Learning models. This process does not involve your personal data.

5.2. AI Insights (LLM)

If you select a model that supports AI Insights:

  1. We generate prediction data.
  2. We strip all user-identifying information (user IDs, emails, names) from the prediction data before sending it to AI models.
  3. The anonymized prediction data is sent to:
    • Internally hosted AI models; or
    • External API providers (e.g., OpenRouter).
  4. Results are returned and displayed to you.

Important: We never send your User ID, email, or any personally identifiable information to external AI providers.

5.3. Third-Party Service Providers

We use the following third-party services:

  • Paystack – Payment processing – Payment information (processed securely)
  • API Providers – Match data and statistics – Match-related data (non-personal)
  • OpenRouter – AI Insights – Anonymized prediction data only

6. Data Storage and Security

6.1. Storage Location

Your personal data is stored on servers located in Germany.

6.2. Data Localization

Under the Kenya Data Protection Act, personal data collected in Kenya must be processed in accordance with Kenyan law. We ensure that our servers in Germany provide adequate data protection safeguards, and we have obtained the necessary consent for cross-border data transfers where required.

6.3. Security Measures

We implement appropriate technical and organizational measures to protect your personal data, including:

  • Encryption of data in transit and at rest.
  • Access controls and authentication mechanisms.
  • Regular security audits.
  • Anonymization of data before external processing.

7. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy or to comply with legal obligations.

  • Account Data: Retained while your Account is active.
  • Transaction Data: Retained for accounting and legal compliance for the period required by Kenyan law.
  • Prediction History: Retained for service improvement and analytics.
  • Upon Request: You may request deletion of your data at any time (see Section 10).

8. Your Rights

Under the Kenya Data Protection Act, 2019 and the GDPR, you have the following rights:

  • Right to be Informed – To know how your data is collected and used
  • Right of Access – To request a copy of your personal data
  • Right to Rectification – To correct inaccurate or incomplete data
  • Right to Erasure ("Right to be Forgotten") – To request deletion of your data
  • Right to Object – To object to processing of your data
  • Right to Withdraw Consent – To withdraw consent at any time
  • Right to Data Portability – To receive your data in a structured format
  • Right to Restrict Processing – To limit how your data is processed

To exercise any of these rights, contact us at privacy@kozisports.link.

9. Data Deletion, Suspension, and Termination

9.1. Requesting Data Deletion

You may request deletion of your personal data at any time by contacting us. We will process your request within thirty (30) days.

9.2. Account Suspension

We may suspend your Account if we suspect a violation of our Terms or illegal activity.

9.3. Account Termination

You may terminate your Account at any time. Upon termination, we will delete your personal data in accordance with Section 9.1 above.

10. Cross-Border Data Transfers

We transfer anonymized prediction data to external AI providers (e.g., OpenRouter) located outside Kenya. We ensure that:

  1. No personally identifiable information is included in these transfers.
  2. Appropriate safeguards are in place for any data transfers.
  3. We comply with the Kenya Data Protection Act's requirements for cross-border data transfers.

For any transfer of personal data outside Kenya, we obtain your consent and ensure adequate data protection safeguards.

11. Data Protection by Design and Default

We implement data protection by design and by default, meaning that we:

  • Minimize data collection to what is necessary.
  • Anonymize data before external processing.
  • Implement privacy safeguards at the system design stage.

12. Children's Privacy

The Platform is not intended for individuals under the age of 18. We do not knowingly collect personal data from minors. If we become aware that we have collected personal data from a minor, we will delete it promptly.

13. Cookies

We use cookies to:

  • Maintain your session and preferences.
  • Analyze Platform usage and improve services.
  • Provide a personalized experience.

You may disable cookies in your browser settings, but this may affect Platform functionality.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Changes will be posted on the Platform with an updated "Last Updated" date. We encourage you to review this Privacy Policy periodically.

15. Complaints

If you believe we have not complied with this Privacy Policy or applicable data protection laws, you have the right to lodge a complaint with:

Office of the Data Protection Commissioner (ODPC)
Website: www.odpc.go.ke
Address: Nairobi, Kenya

16. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us:

Kozi Sports
Email: privacy@kozisports.link
DPO Email: dpo@kozisports.link
Address: Nairobi, Kenya

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