privacy.

who we are.

Duara is a mobile application that helps groups — chamas, family investment clubs, estate associations, and savings circles — coordinate their shared finances, governance, and communication.

Duara is built and operated by Pluribus Tech Limited, based in Kenya. Our mission is to provide secure, resilient infrastructure for community-led financial growth.

When we say "Duara," "we," "us," or "our" in this policy, we mean Pluribus Tech Limited, the team behind the app. When we say "you," we mean you as an individual user. When we say "your group," we mean the savings circle or community you belong to on Duara. We take your privacy seriously.

our principles.

Everything in this policy is built around the core principles set out in Kenya's Data Protection Act:

01.

Lawfulness, fairness and transparency — we tell you what we do with your data and why.

02.

Purpose limitation — we only use your data for the purposes described in this policy.

03.

Data minimisation — we only collect what we actually need to run Duara.

04.

Accuracy — we keep your data accurate and let you correct it at any time.

05.

Storage limitation — we don't keep your data longer than necessary (see Data Retention below).

06.

Integrity and confidentiality — we protect your data with the security measures described below.

07.

Accountability — we take responsibility for demonstrating our compliance with these principles.

data collection.

personal identification

When you register, we collect your phone number, email and name. This is essential to authenticate your identity and facilitate trust within your private circles.

financial data

We track group contributions, withdrawals, and balances. This data is only visible to authorized members of your specific group. This includes contribution amounts, loan requests, loan repayments, withdrawal requests, fine records, and pool balances.

group content

Chat messages, votes, proposals, meeting agendas, announcements and their attached images, and any documents your group generates — constitutions, loan agreements, financial reports, meeting minutes — are stored securely and visible only within your group. Financial reports are only visible to the user that created them.

device & usage data

We collect device type, operating system version, app version, a unique device identifier, and a push notification token so we can deliver notifications to your device. We also keep records of which screens and features are used, and how often, to help us improve the app. This is processed through the analytics and error-reporting providers named under "Data Sharing" below.

We do not collect your IP address. The only identifier attached to analytics and error-reporting data is an internal account ID — never your name, phone number or email address (see "Analytics & Crash Reporting" below).

account settings & history

We also store your notification preferences, referral records, onboarding progress, and a record of the consents you have given — such as your acceptance of this policy and our Terms, and the date of each. If you subscribe to Duara Records, we store your subscription and billing history and your entitlement records — which paid features your account is entitled to.

what we do not collect

We do not collect your M-Pesa PIN, bank account credentials, or any payment authentication secrets. We do not run advertising on Duara and we do not build advertising profiles on our users. We do not sell your data to third parties.

if you don't provide this data

Some data is required for Duara to function — without it, we cannot deliver the corresponding part of the service:

01.

Phone number, email and name at registration — without these, we cannot create or verify your account.

02.

Financial data tied to a specific action (a contribution, loan request, or fine payment) — without it, that transaction cannot be recorded in your group's official records.

03.

Device information — this is optional; declining device permissions only means you won't receive push notifications, and doesn't affect any other feature.

how we use it.

We use your data only to deliver and improve the service you signed up for. We do not use your data to serve you advertisements. We do not use your data to train AI models. For each purpose below, we rely on a specific legal basis recognised under the Data Protection Act.

Purpose	Data used	Legal basis
Creating and managing your account	Name, phone number, email	Performance of a contract
Delivering group chat and financial coordination	Messages, votes, transaction records	Performance of a contract
Sending you group notifications	Device push token, group activity	Performance of a contract
Generating tamper-proof group documents	All group financial and governance records	Performance of a contract
Processing Duara Records subscriptions	Payment details, account identity	Performance of a contract; legal obligation (financial record-keeping)
Improving and debugging the app	Usage data, device information	Legitimate interest
Complying with applicable law	Any data required by Kenyan law	Legal obligation

governance.

We believe in "privacy by design." Your data is not our product.

Your data is stored on Supabase infrastructure with servers located in secure, access-controlled data centres. All data in transit is encrypted using TLS. Sensitive records are stored encrypted at rest. Group financial documents generated by Duara are cryptographically hashed at the time of creation — this hash serves as a tamper-proof fingerprint, allowing any party to verify a document has not been altered, directly in the app.

encryption

All data transmissions are secured with TLS (Transport Layer Security). Sensitive records are stored encrypted at rest.

zero-access

Only authorized users can access data in the system, by utilizing our Role Based Security system.

cryptographic proof

Documents generated by Duara are hashed at creation. Any alteration is mathematically detectable.

no data selling

We do not grant third parties access to your personal data except as strictly described in this policy. Ever.

data sharing.

within your group

The nature of Duara is that your group members can see shared financial records, votes, documents and governance decisions that belong to the group. Your name, contributions, and group activity are visible to other members of the same group. You agree to this when you join a group.

service providers

We use a small number of trusted third-party services to run Duara. Here is every one of them, what it does for us, and where it processes your data:

Provider	What we use it for	Where
Supabase	Database, file storage and authentication	Ireland
Expo and Google Firebase Cloud Messaging	Push notification delivery. Your notification token and the text of each notification pass through Expo before reaching Google.	Expo: United States. Google: processed globally.
RevenueCat	Subscription and purchase records for Duara Records	United States
PostHog	Product analytics — which screens and features are used, and how often	PostHog's European servers
Sentry	Crash and error reporting — technical diagnostic information about faults	Sentry's German servers
Resend	Sending email. Holds a name and email address for anyone opted in to product updates.	United States

Each of these providers accesses only the data it needs to perform its specific function, operates under a written data processing agreement with us, and is contractually prohibited from using your data for its own purposes. What we send to PostHog and Sentry, and what happens to it when you delete your account, is set out under "Analytics & Crash Reporting" below.

legal requirements

We may disclose your information if required to do so by a court order, government authority, or applicable Kenyan law. We will notify you of such a request where legally permitted to do so.

We do not sell your data.

analytics & crash reporting.

We use PostHog to understand how Duara is used — which screens and features are opened, and how often — and Sentry to catch and diagnose crashes and errors. Both are listed under "Data Sharing" above, and both operate under a data processing agreement that forbids them from using your data for their own purposes.

The only identifier we attach to this data is an internal account ID. We never send your name, phone number or email address to either service, and we do not collect your IP address.

When you delete your Duara account, we instruct our analytics, error-reporting and email providers to erase the data they hold about you. This normally completes within 30 days. Crash and error reports are deleted automatically after 90 days in any case.

There is one exception. Purchase records held by RevenueCat are kept for five years after your last transaction, because Kenyan tax law requires financial records to be kept for that period — an obligation that overrides the right to erasure. Those records contain your purchase history and subscription dates. They do not contain your name, your phone number, or any of your group activity.

cross-border transfers.

Every provider listed under "Data Sharing" above stores or processes your data on servers outside Kenya. Sections 48 and 49 of the Data Protection Act permit this where the destination offers protection essentially equivalent to Kenyan law, or where appropriate contractual safeguards are in place. Both grounds apply here:

01.

Ireland and Germany — Supabase, PostHog and Sentry. These countries are recognised as offering data protection safeguards essentially equivalent to those required under Kenyan law.

02.

United States — RevenueCat, Resend, Expo and Google. These transfers are covered by standard contractual clauses in our agreement with each provider, which bind them to protect your data to the standard Kenyan law requires.

03.

In every case, the transfer is necessary to deliver the service you signed up for.

Where sensitive personal data is involved, we will additionally seek your express consent before any such transfer. If you want the details of the safeguards covering a specific transfer, email info@duara-app.com with "Privacy" in the subject line and we will provide them.

data retention.

We retain your personal data for as long as your account is active.

deleting your account

You can delete your account at any time — in the app (Profile → Manage Account → Delete Account) or by emailing info@duara-app.com with "Privacy" in the subject line. Deletion is not immediate. It starts a 14-day grace period, during which your account stays fully intact and you can cancel the deletion by signing back in. This grace period is distinct from the response times given under "Your Rights" below.

Once the grace period elapses — roughly 14 to 15 days after your request — we permanently remove the identifying information from your profile: your name, phone number, bio, profile photo and login credentials. From that point your display name is shown as "Former member" wherever it previously appeared.

what we keep after deletion

We do not delete the underlying profile record. An anonymized version of it — one that can no longer be used to identify you — is retained indefinitely, along with the group financial history connected to your activity, as part of each group's audit trail, which the other members have a legitimate interest in preserving.

The following also remain, with your name shown as "Former member" where it appeared: the content of messages you sent in group chats (the message text is kept exactly as written); your votes on group decisions; your consent history — records of the policies you accepted and when; your subscription, billing and entitlement records where you used Duara Records; referral records, notification preferences, push notification tokens and onboarding progress; and any images you added to group announcements or meetings.

Documents generated in your groups before your deletion — constitutions, financial reports, loan agreements, meeting minutes — have your name written into the document itself, and each is fixed by a cryptographic hash taken at creation, so any later change to the file is detectable. Editing your name out of an already-generated document would invalidate it, so these retain your name. Documents generated after your deletion show "Former member".

Cryptographic hash records for generated documents are retained indefinitely as they contain no personal information — they are fingerprints, not content.

Once the deletion becomes permanent, we also instruct our analytics, error-reporting and email providers to erase the data they hold about you. That step is not instant — it normally completes within 30 days of the deletion, which is longer than the 14 to 15 days it takes us to remove the data we hold ourselves. Purchase records held by RevenueCat are the exception: Kenyan tax law requires financial records to be kept for five years after your last transaction. See "Analytics & Crash Reporting" above for the detail.

For a full walkthrough of what is removed and what is kept, see our Account Deletion page.

breach notification.

If a personal data breach occurs that is likely to result in a risk to your rights, we will notify the Office of the Data Protection Commissioner within 72 hours of becoming aware of it, as required by law. Where the breach poses a significant risk to you personally, we will also notify you directly and share steps you can take to protect yourself.

your rights.

Under the Data Protection Act, you have the following rights over your data. Unless noted otherwise, you can exercise any of them by emailing info@duara-app.com with "Privacy" in the subject line, or using the contact form in "Contact Us" below.

01.

Right to be informed — clear information about how we collect, use, and protect your data — that's what this policy is for. Always available in the app and on our website · Ongoing

02.

Right of access — ask for confirmation of what personal data we hold about you and a copy of it. Contact us · 7 days

03.

Right to rectification — ask us to correct inaccurate or incomplete data in your profile. You may edit your personal details within the app at any time · 14 days

04.

Right to erasure — ask us to remove your personal information. We permanently remove your identifying details (name, phone number, bio, photo and login credentials); an anonymized record and the group's financial history are kept as part of the group's audit trail. Our Account Deletion page explains exactly what is removed and what is kept. Start it yourself in the app, or email info@duara-app.com — identifiers are removed once the 14-day grace period ends, roughly 14–15 days after the request; data held on our behalf by service providers is erased within 30 days

05.

Right to restriction — ask us to pause processing of your data while a dispute about its accuracy or lawfulness is resolved. Contact us specifying the grounds · 14 days

06.

Right to data portability — receive your personal data in a structured, commonly used format to transfer elsewhere. Available through the app's report-creation feature · 30 days

07.

Right to object — object to processing that isn't required to deliver the service, including any direct marketing. Contact us, or use the unsubscribe link on marketing messages · 7 days for marketing, 14 days otherwise

08.

Rights around automated decision-making — request human review of any decision made about you based solely on automated processing. (We don't currently use automated decision-making — see below.) Contact us · Promptly

You may also withdraw consent to any non-essential processing at any time, without affecting the lawfulness of processing carried out before withdrawal.

automated decisions.

We do not currently use your personal data to make decisions about you based solely on automated processing that would produce legal or similarly significant effects — for example, loan requests on Duara are decided by your group's own members through voting, not by an algorithm. If this changes in future, we will update this policy, notify you, and give you a way to request human review of any such decision.

complaints.

If you're unhappy with how we've handled your personal data, contact us first at the details below and we'll investigate and respond within 14 days.

If you remain dissatisfied with our response — or you'd prefer to go directly to the regulator — you have the right to lodge a complaint with the Office of the Data Protection Commissioner (ODPC):

01.

Online — www.odpc.go.ke or odpc.go.ke/file-a-complaint

02.

Email — complaint@odpc.go.ke

03.

Address — Britam Towers, 12th Floor, Hospital Road, Upper Hill, Nairobi, Kenya

children.

Duara is not intended for use by anyone under the age of 18. We do not knowingly collect personal information from minors. If you believe a minor has created an account, please contact us and we will delete the account promptly.

changes.

We may update this policy from time to time as the app evolves. When we make material changes, we will notify you in the app, ask you to review and accept the revised policy before you continue using Duara, and update the "Last updated" date on this page.

Last updated: 9 September 2026 · Effective date: 9 September 2026