GNA Real Estate Privacy Policy

Effective Date: 26 March 2024 Last Updated: 27th December 2025

Welcome to the website (“Site”) of GNA Real Estate (“GNA,” “we,” “us,” or “our”). This Site is operated by GNA Real Estate to provide information and services, including real estate brokerage, investment facilitation, property management, furnished stays, serviced accommodation, advisory services, digital tools, and related online services (collectively, the “Services”).

GNA Real Estate serves both local Kenyan clients and international or diaspora clients who invest in, lease, or stay in properties within Kenya. This Privacy Policy explains how we collect, use, disclose, store, transfer, and protect personal data (“Personal Data”) obtained through our Services.

By accessing or using our Services, you consent to the practices described in this Privacy Policy. This Policy forms part of GNA’s Terms of Service.

1. Data Controller & Contact Information

Data Controller: GNA Real Estate

Data Protection Officer (DPO):
📧 support@gna.co.ke 📧 gna.co.ke@gmail.com

You may contact us regarding any questions, concerns, or requests relating to this Privacy Policy or your rights under the Kenya Data Protection Act, 2019, or other applicable data protection laws.

2. Information We Collect

2.1 Personal Data You Provide

We collect Personal Data when you voluntarily provide it through inquiries, booking forms, reservation systems, investment consultations, contracts, registrations, or other interactions with our Services. This may include:

• Full name

• Email address

• Telephone number (local or international)

• Date of birth

• Residential or postal address

• National ID, passport number, or other government-issued identification

• Proof of identity or address (where legally or operationally required)

• Booking and reservation details (dates of stay, property preferences, occupancy details)

This information is used to:

• Provide real estate brokerage, advisory, and investment services

• Facilitate property purchases, sales, leasing, or management

• Process and manage furnished apartment, serviced stay, and accommodation reservations, including bookings, check-ins, guest communication, and support services

• Comply with legal, regulatory, and anti-fraud requirements

• Communicate with you regarding services, transactions, or reservations

• Personalize your experience and provide relevant offerings

You confirm that all Personal Data provided is accurate, current, complete, and lawfully provided.

2.2 Non-Personal & Technical Data

We may automatically collect technical and usage information that does not directly identify you, including:

• IP address (local or international)

• Device identifiers

• Browser type and operating system

• Pages visited, time spent, and usage patterns

We use cookies, web beacons, and similar technologies to improve functionality, analyze traffic, and enhance user experience. You may manage cookies through your browser settings, though disabling them may limit certain features.

2.3 Aggregated & Anonymized Data

We may aggregate or anonymize data for analytics, reporting, market research, or business planning purposes. Such data does not identify individual users and may be shared with consultants, partners, or service providers for lawful purposes.

3. Lawful Basis for Processing

We process Personal Data only where lawful, including when:

• It is necessary to provide Services or fulfill contractual obligations

• You have provided consent

• Processing is required to comply with legal or regulatory obligations

• Processing is necessary for legitimate business interests, such as service improvement, risk management, and fraud prevention

4. Use of Personal Data

We may use Personal Data to:

• Respond to inquiries and provide requested Services

• Facilitate real estate transactions and investment activities in Kenya

• Manage furnished stays, serviced apartment bookings, guest communication, access arrangements, and stay-related support

• Verify identity and conduct compliance checks

• Send service-related notices, confirmations, and updates

• Improve our Services, systems, and customer experience

4.1 Marketing Communications

We will only send marketing or promotional communications where you have provided consent. All marketing messages include clear instructions on how to opt out at any time.

5. Disclosure of Personal Data

We do not sell Personal Data. We may share Personal Data with:

• Business Partners & Professional Advisors: Lawyers, valuers, financial institutions, agents, or consultants involved in your transaction or reservation

• Service Providers: IT providers, cloud hosting services, booking systems, analytics providers, and administrative support providers

• Property & Hospitality Service Providers: Property managers, caretakers, housekeeping teams, security providers, and payment processors involved in furnished stays

• Related Companies: GNA-affiliated entities for consistent service delivery

• Legal & Regulatory Authorities: Where required by law or to protect legal rights

• Business Transfers: In the event of a merger, acquisition, restructuring, or sale of assets

All third parties are required to process Personal Data securely and in accordance with applicable data protection laws.

6. International & Cross-Border Data Transfers

As GNA Real Estate serves international and diaspora clients, your Personal Data may be:

• Transferred to

• Stored in

• Accessed from

locations outside Kenya for legitimate business, communication, or transaction-related purposes.

We take reasonable steps to ensure that cross-border transfers are protected through appropriate safeguards consistent with applicable data protection laws. By using our Services, you consent to the cross-border processing of your Personal Data.

7. Data Retention

We retain Personal Data only for as long as necessary to:

• Provide Services and manage reservations or transactions

• Meet legal, tax, accounting, and regulatory requirements

• Resolve disputes and enforce agreements

Once no longer required, Personal Data is securely deleted, anonymized, or archived.

8. Your Rights (Data Subject Rights)

Subject to applicable law, you have the right to:

• Access your Personal Data

• Request correction of inaccurate or incomplete data

• Request deletion of Personal Data where legally permitted

• Object to processing for direct marketing purposes

• Withdraw consent at any time

• Lodge a complaint with the Office of the Data Protection Commissioner (Kenya) or a relevant authority in your jurisdiction

Requests may be sent to:
📧 support@gna.co.ke

9. Security Measures

We implement reasonable administrative, technical, and physical safeguards to protect Personal Data against unauthorized access, loss, misuse, alteration, or disclosure.

However, no online system is completely secure, and users are encouraged to take care when transmitting sensitive information electronically.

10. Children’s Privacy

Our Services are not intended for individuals under the age of 18. We do not knowingly collect Personal Data from minors. If such data is identified, it will be deleted promptly.

11. Third-Party Websites

Our Services may contain links to third-party websites not controlled by GNA. This Privacy Policy does not apply to those websites, and users should review their respective privacy policies.

12. Data Breach Notification

In the event of a data breach affecting Personal Data, we may notify affected users electronically or via email, in accordance with applicable legal requirements.

13. Policy Updates

We may update this Privacy Policy from time to time. Any material changes will be posted on the Site with an updated effective date. Continued use of the Services constitutes acceptance of the revised policy.

Summary

GNA Real Estate is committed to protecting the privacy of local, diaspora, and international clients while delivering transparent, secure, and professional real estate, investment, and furnished accommodation services in Kenya.

Contact: 📧 support@gna.co.ke