Effective Date: 2 Feb 2026
SUN Swap Mobility (Kenya) Limited (the “Company”, “we”, “us” or “our”) is committed to protecting the privacy and security of personal data in accordance with the Constitution of Kenya, 2010, the Data Protection Act, 2019 and the attendant Regulations (together, the “Data Protection Laws”).
In the course of providing battery swapping and mobility services to motorcycle riders, vehicle drivers and fleet operators, we collect, use, store, share and otherwise process personal data. This Data Privacy Statement explains how we handle personal data when you interact with our systems and services in Kenya.
This Statement should be read together with our Terms and Conditions governing use of our systems and services.
In this Statement, unless the context otherwise requires:
“You” or “User” means any motorcycle rider, motor vehicle driver, motorcycle owner, vehicle owner, fleet operator, customer, agent, merchant or any other natural person who subscribes to, accesses or uses the App or our services.
“Company”, “we”, “us”, “our” or “ours” means SUN Swap Mobility (Kenya) Limited.
“Data Protection Laws” means Article 31 of the Constitution of Kenya, 2010, the Data Protection Act, 2019 and all regulations, guidelines and directives issued thereunder.
“Consent” means an express, informed and voluntary indication of the data subject’s agreement to the processing of personal data.
“Processing” means any operation performed on personal data, whether or not by automated means, including collection, recording, organisation, storage, adaptation, retrieval, consultation, transmission, disclosure, erasure or destruction.
“Data Subject” means an identified or identifiable natural person whose personal data is processed.
“Data Controller” means a natural or legal person who determines the purpose and means of processing personal data.
“Data Processor” means a natural or legal person who processes personal data on behalf of the Data Controller.
“Personal Data” means information relating to an identified or identifiable natural person
“Sensitive Personal Data” means personal data revealing health information, biometric data, financial information or any other data classified as sensitive under the Data Protection Laws.
"App" means any application and related digital platforms operated by the Company such as applications or sites for riders, agents, service providers, partners etc.
We collect personal data that you voluntarily provide to us when you register with us as a rider, driver, operator or service provider, either in writing or via an App including:
When you access or use the App, we may automatically collect certain information, including:
We may receive information from:
Personal data may be collected directly from you or automatically through your use of the App, including through cookies and similar tracking technologies. Such data may include device identifiers, IP address, location data, payment and transaction data, battery swap and energy consumption information.
Cookies are small files placed on your device to improve user experience and analyse usage patterns. You may manage cookie preferences through your device or browser settings; however, disabling cookies may affect certain App functionalities.
The App may display advertisements or content from third parties who may use their own tracking technologies. We do not control such third-party practices and are not responsible for their data processing activities.
Any information you choose to share with other users or third parties through the App is shared at your own risk. We do not collect or retain any Sensitive Personal Data.
We use personal data for the following purposes:
We may disclose personal data under the following circumstances:
All disclosures are carried out in accordance with applicable Data Protection Law.
The App is only intended for users who are of 18 years of age or older and otherwise competent to enter into binding contracts. If You are not of the requisite age or otherwise unable to enter into binding contracts, You are not to provide any user information or other information. If it comes to the Company's attention that any information pertains to an individual under the age of 18 years or otherwise not eligible to enter into binding contracts, such information will be deleted without notice to You.
We process personal data based on one or more of the following lawful bases:
We retain personal data only for as long as reasonably necessary to fulfil the purposes for which it was collected, comply with legal and regulatory obligations, or resolve disputes. Anonymised data may be retained indefinitely.
The App may contain links to third-party websites. We are not responsible for the privacy practices or content of such external sites.
You may access, review and update your personal data through your App account or by contacting us. Verification of identity may be required before processing such requests.
We have implemented appropriate technical and organisational measures to safeguard personal data against unauthorised access, loss, misuse, alteration or disclosure. These measures include access controls, encryption, secure systems, incident response procedures and staff training.
The personal data that you provide, subject to disclosure in accordance with this Data Privacy Statement, shall be maintained in a safe and secure manner. We have adopted reasonable and appropriate security standards to protect the confidentiality and integrity of personal data.
As a user of the App, you are responsible for maintaining the confidentiality of your login credentials. You must use the App responsibly and must not share your username, identification number or password with any other person. You are solely responsible for all activities carried out under your registered account.
Given the nature of internet-based transactions and digital platforms, transmission of information over the internet is not completely secure. To the extent permitted by applicable law, any transmission of personal data through the App is done at your own risk.
While we take reasonable steps to safeguard personal data, we do not guarantee that our security measures are fool-proof, impenetrable or completely immune from circumvention by third parties.
From time to time, we may transfer personal data outside the Republic of Kenya, including to cloud service providers, technology partners or affiliated entities, for purposes of system hosting, service delivery, technical support, analytics or business continuity.
Where personal data is transferred outside Kenya, we ensure that such transfers are carried out in accordance with Section 48 of the Data Protection Act, 2019 and that appropriate safeguards are in place. These safeguards may include one or more of the following:
We take reasonable steps to ensure that personal data transferred outside Kenya continues to be protected in a manner consistent with the Data Protection Laws.
Subject to applicable law, you have the right to:
If you have any questions, concerns or requests relating to this Data Privacy Statement or the processing of personal data, you may contact the Company or its designated Data Protection Officer using the details below:
Data Controller:
SUN Swap Mobility (Kenya) Limited
Data Protection Officer:
Name: Gaurav Anand
Email: Gaurav.Anand@sunmobility.com
Telephone: +254 736 777 250
If you are dissatisfied with how we process personal data, you may lodge a complaint with the Office of the Data Protection Commissioner. We encourage you to contact us first to allow us to address your concerns.
We reserve the right to suspend or terminate access to the App where there is material non-compliance with this Statement or applicable law.
We may amend this Data Privacy Statement from time to time. The updated version will be made available on the App and will take effect upon publication.
This Privacy Policy is governed by the laws of Kenya, and disputes shall be subject to the exclusive jurisdiction of the courts of Kenya.