Privacy Policy
VUNABET PRIVACY POLICY
Last Updated: 30 August 2026
Effective Date: 30 August 2026
VunaBet is committed to protecting the privacy and personal information of its players. This Privacy Policy explains how VunaBet collects, uses, stores, protects and shares personal information when you use the VunaBet website, Progressive Web Application, games, wallet, payment services and related services.
This Privacy Policy should be read together with the VunaBet Terms and Conditions and Responsible Gambling Policy.
By registering for or using VunaBet, you acknowledge that you have read and understood this Privacy Policy.
1. ABOUT VUNABET
VunaBet is a real-money gaming platform operating in Kenya and subject to applicable Kenyan laws and regulatory requirements.
For purposes of applicable data protection legislation, VunaBet or its operating company shall act as the data controller in respect of personal information it determines the purposes and means of processing.
Where VunaBet engages third parties to process personal information on its behalf, such parties may act as data processors.
Company Name: [INSERT LEGAL COMPANY NAME]
Website: [https://vunabet.co.ke](https://vunabet.co.ke)
Email: [INSERT PRIVACY EMAIL]
Telephone: [INSERT PHONE NUMBER]
Registered Office: [INSERT ADDRESS]
Data Protection Officer / Privacy Contact: [INSERT NAME OR PRIVACY CONTACT]
2. APPLICABLE DATA PROTECTION LAW
VunaBet processes personal information in accordance with applicable Kenyan data protection legislation, including:
1. The Constitution of Kenya, 2010;
2. The Data Protection Act, 2019;
3. The Data Protection (General) Regulations, 2021;
4. The Data Protection (Registration of Data Controllers and Data Processors) Regulations, 2021;
5. Other applicable regulations, guidelines and directives issued by the Office of the Data Protection Commissioner; and
6. Other applicable Kenyan laws and regulatory requirements.
The Data Protection Act, 2019 requires personal data to be processed in accordance with the right to privacy and according to principles including lawfulness, fairness, transparency, purpose limitation, data minimisation, accuracy and appropriate retention. ([Kenya Law][1])
3. WHAT PERSONAL INFORMATION WE COLLECT
Depending on how you use VunaBet, we may collect the following categories of personal information.
3.1 Registration Information
When you create a VunaBet account, we may collect:
1. Full name;
2. Mobile telephone number;
3. Date of birth;
4. Email address, where provided;
5. Account username or identifier;
6. Four-digit PIN/password;
7. Registration date and time; and
8. Terms and Conditions acceptance records.
3.2 Age and Identity Information
Because VunaBet is restricted to persons aged 18 years and above, we may collect or verify information necessary to establish:
1. Your age;
2. Your identity;
3. Your account ownership; and
4. Your eligibility to use VunaBet.
Where required by law, regulation or our compliance procedures, we may request additional identification information or documents.
3.3 Payment Information
When you deposit, stake or withdraw money, we may process information relating to the transaction, including:
1. M-Pesa transaction reference;
2. Mobile number used for payment;
3. Payment amount;
4. Transaction date and time;
5. Payment status;
6. Wallet balance;
7. Withdrawal amount;
8. Withdrawal status;
9. Pesapal transaction reference;
10. Other payment-provider transaction identifiers; and
11. Information necessary to reconcile payments.
VunaBet does not need to store your M-Pesa PIN.
You should never provide your M-Pesa PIN, bank PIN or other confidential payment password to VunaBet.
3.4 Game Information
We may record information concerning your use of VunaBet, including:
1. Games played;
2. Box selected;
3. Stake amount;
4. Game outcome;
5. Prize amount;
6. Date and time of play;
7. Transaction reference;
8. Wallet transaction;
9. Deposits;
10. Withdrawals;
11. Wins; and
12. Losses.
This information may be required for transaction reconciliation, auditing, dispute resolution, fraud prevention, responsible gambling and regulatory compliance.
3.5 Device and Technical Information
When you access VunaBet, we may automatically collect certain technical information, including:
1. IP address;
2. Device type;
3. Operating system;
4. Browser type;
5. Browser version;
6. Device identifiers where legally permitted;
7. Approximate location derived from technical information where necessary;
8. Language and regional settings;
9. Date and time of access;
10. Pages or features accessed;
11. Error logs; and
12. Security and authentication information.
3.6 Customer Support Information
If you contact VunaBet, we may collect information contained in your communication, including:
1. Name;
2. Phone number;
3. Email address;
4. Account information;
5. Transaction references;
6. Complaint details;
7. Screenshots or documents you voluntarily provide; and
8. Other information necessary to resolve your request.
9. HOW WE COLLECT PERSONAL INFORMATION
We may collect personal information through:
1. Account registration;
2. Login;
3. Password/PIN reset;
4. Wallet deposits;
5. Game participation;
6. Withdrawals;
7. M-Pesa transactions;
8. Pesapal transactions;
9. Customer support;
10. Self-exclusion requests;
11. Identity verification;
12. Fraud and security monitoring;
13. Cookies and similar technologies;
14. Your device or browser; and
15. Information provided directly by you.
16. WHY WE COLLECT YOUR INFORMATION
VunaBet may process your personal information for the following purposes:
1. Creating and managing your account;
2. Verifying that you are at least 18 years old;
3. Verifying your identity;
4. Processing deposits;
5. Processing stakes;
6. Processing winnings;
7. Processing withdrawals;
8. Maintaining your wallet;
9. Resetting your PIN;
10. Sending SMS notifications;
11. Sending transaction confirmations;
12. Providing customer support;
13. Preventing fraud;
14. Detecting suspicious transactions;
15. Preventing money laundering;
16. Preventing unauthorised account access;
17. Maintaining Platform security;
18. Implementing responsible gambling measures;
19. Implementing self-exclusion;
20. Maintaining game records;
21. Resolving disputes;
22. Meeting regulatory requirements;
23. Meeting tax and accounting obligations;
24. Improving the Platform;
25. Monitoring technical performance;
26. Communicating important service information; and
27. Protecting the legal rights and interests of VunaBet and its users.
28. LEGAL BASIS FOR PROCESSING
Depending on the circumstances, VunaBet may process personal information based on:
1. Your consent;
2. Performance of a contract with you;
3. Compliance with a legal obligation;
4. Protection of your vital interests where applicable;
5. Performance of a task carried out in the public interest where applicable; or
6. A legitimate interest recognised under applicable law, provided that such processing does not unlawfully override your rights and interests.
The Data Protection Act, 2019 establishes requirements concerning lawful processing and provides data subjects with specific rights. ([Kenya Law][1])
Where processing is based on consent, the Data Protection (General) Regulations, 2021 require information concerning the identity of the controller or processor, purposes of processing, categories of personal data, relevant automated decision-making, third-party sharing, withdrawal of consent and implications of providing or withdrawing consent to be communicated appropriately. ([Kenya Law][2])
7. AGE VERIFICATION
VunaBet is strictly restricted to persons aged 18 years and above.
We may process your date of birth and other relevant information to verify your age.
We may conduct additional verification if we reasonably suspect that an account holder is under 18.
If we determine that an underage person has created or used an account, we may suspend or terminate the account and take other action required by law.
8. M-PESA INFORMATION
When you use M-Pesa to deposit funds, pay a stake or receive a withdrawal, VunaBet may receive transaction information from the applicable payment system.
This may include:
1. Mobile number;
2. Transaction amount;
3. Transaction reference;
4. Transaction status;
5. Transaction date and time; and
6. Other information necessary to verify the transaction.
VunaBet does not request or require your M-Pesa PIN.
M-Pesa transactions may also be subject to Safaricom's applicable privacy and data-processing practices.
9. PESA PAL INFORMATION
Where Pesapal is used to process a payment, certain payment and transaction information may be processed by Pesapal.
This may include:
1. Transaction reference;
2. Payment amount;
3. Payment status;
4. Account information;
5. Contact information; and
6. Other information required to process and reconcile the transaction.
Pesapal's own privacy policy and terms may also apply to information processed directly by Pesapal.
10. SMS AND COMMUNICATIONS
VunaBet may send SMS messages to your registered mobile number for purposes including:
1. PIN reset;
2. Account verification;
3. Deposit confirmation;
4. Stake confirmation;
5. Winning notifications;
6. Withdrawal notifications;
7. Security alerts;
8. Responsible gambling notifications;
9. Self-exclusion information; and
10. Important service announcements.
Certain transactional and security communications cannot necessarily be disabled because they are necessary to operate your account securely.
11. MARKETING COMMUNICATIONS
Where legally permitted and where appropriate consent has been obtained, VunaBet may send promotional communications concerning:
1. New games;
2. Promotions;
3. Bonuses;
4. Competitions;
5. Platform updates; and
6. Other VunaBet services.
You may opt out of promotional communications where applicable.
Opting out of marketing communications will not necessarily stop essential transactional, security, regulatory or account-related communications.
12. COOKIES
VunaBet may use cookies and similar technologies.
Cookies may be used to:
1. Keep you logged into your account;
2. Maintain session security;
3. Remember preferences;
4. Improve Platform performance;
5. Analyse usage;
6. Prevent fraud;
7. Maintain security; and
8. Improve the user experience.
Where required by law, VunaBet will obtain appropriate consent before using non-essential cookies.
Disabling certain cookies may affect the functionality of the Platform.
13. ACCOUNT LOGIN AND SESSION INFORMATION
VunaBet may use secure authentication mechanisms to keep your account logged in between sessions where you have chosen to remain logged in.
Authentication information may be stored using security mechanisms designed to prevent unauthorised access.
You should log out of your account when using a shared or public device.
14. PIN AND PASSWORD SECURITY
VunaBet may store your PIN/password in a protected form rather than storing it as readable plain text.
You are responsible for protecting your PIN.
VunaBet will not intentionally disclose your PIN to another user.
If you believe your PIN has been compromised, you should reset it immediately and contact VunaBet.
15. DATA SHARING
VunaBet may share personal information with third parties where necessary and lawful.
These may include:
1. M-Pesa/Safaricom;
2. Pesapal;
3. SMS service providers;
4. Hosting providers;
5. Cloud infrastructure providers;
6. Identity verification providers;
7. Fraud prevention providers;
8. Professional advisers;
9. Auditors;
10. Legal advisers;
11. Regulatory authorities;
12. Government agencies;
13. Law enforcement authorities;
14. Courts and tribunals; and
15. Other service providers necessary to operate VunaBet.
We do not sell your personal information as a commercial product.
16. REGULATORY AND LAW ENFORCEMENT DISCLOSURES
VunaBet may disclose personal information where required or permitted by law.
This may include disclosures to:
1. The Gambling Regulatory Authority of Kenya;
2. The Office of the Data Protection Commissioner;
3. Kenya Revenue Authority;
4. Financial or anti-money-laundering authorities;
5. Law enforcement agencies;
6. Courts;
7. Government agencies; or
8. Other competent authorities.
VunaBet may also preserve or disclose information where necessary to investigate fraud, unlawful activity, security threats or violations of the law.
17. ANTI-MONEY-LAUNDERING AND FRAUD PREVENTION
VunaBet may process personal information to detect and prevent:
1. Fraud;
2. Money laundering;
3. Terrorist financing;
4. Identity theft;
5. Payment fraud;
6. Account takeover;
7. Multiple-account abuse;
8. Game manipulation; and
9. Other unlawful activities.
This may include analysing account activity, transaction patterns and other information reasonably necessary for compliance and security.
18. RESPONSIBLE GAMBLING DATA
VunaBet may process information relating to gambling behaviour for responsible-gambling purposes, including:
1. Frequency of play;
2. Stake amounts;
3. Deposit activity;
4. Withdrawal activity;
5. Self-exclusion requests;
6. Account restrictions;
7. Responsible-gambling limits; and
8. Other information necessary to identify potentially harmful gambling patterns where permitted by law.
The purpose is to support responsible gambling and regulatory compliance, not to unfairly discriminate against players.
19. AUTOMATED DECISION-MAKING
VunaBet may use automated systems for purposes such as:
1. Fraud detection;
2. Security monitoring;
3. Payment verification;
4. Account security;
5. Risk monitoring; and
6. Regulatory compliance.
Where applicable law provides you with rights concerning automated decision-making or profiling, VunaBet will comply with those requirements.
20. DATA RETENTION
VunaBet will retain personal information only for as long as reasonably necessary for the purposes for which it was collected, unless a longer period is required or permitted by law.
We may retain information after account closure where necessary for:
1. Legal compliance;
2. Regulatory requirements;
3. Tax requirements;
4. Accounting;
5. Fraud prevention;
6. Dispute resolution;
7. Legal claims;
8. Financial reconciliation;
9. Responsible gambling obligations; or
10. Other legitimate legal purposes.
The Data Protection Act, 2019 provides that personal data should not be kept in an identifiable form for longer than necessary for the purposes for which it was collected, subject to applicable legal requirements. ([Kenya Law][1])
21. DATA SECURITY
VunaBet takes reasonable technical and organisational measures to protect personal information against:
1. Unauthorised access;
2. Accidental loss;
3. Destruction;
4. Alteration;
5. Unauthorised disclosure;
6. Fraud; and
7. Other unlawful processing.
Security measures may include:
1. HTTPS/TLS encryption;
2. Password/PIN protection;
3. Access controls;
4. Authentication controls;
5. Database security;
6. Server security;
7. Security monitoring;
8. Backups;
9. Audit logs; and
10. Security updates.
However, no internet-based system can be guaranteed to be completely secure.
22. DATA BREACHES
If VunaBet becomes aware of a personal-data breach, we will take reasonable steps to investigate, contain and remediate the breach.
Where notification is legally required, VunaBet will notify the relevant authority and affected data subjects in accordance with applicable law.
The Data Protection Act, 2019 contains requirements concerning notification and handling of personal-data breaches. ([Kenya Law][1])
23. INTERNATIONAL DATA TRANSFERS
Some VunaBet service providers may process personal information outside Kenya.
Where personal information is transferred outside Kenya, VunaBet will apply the safeguards required by applicable Kenyan data protection law.
The Data Protection Act, 2019 places conditions on transfers of personal data outside Kenya, including requirements concerning appropriate safeguards or consent in applicable circumstances. ([Kenya Law][1])
24. YOUR DATA PROTECTION RIGHTS
Subject to applicable Kenyan law, you may have the right to:
1. Be informed about the use of your personal data;
2. Request access to personal data held about you;
3. Request correction of inaccurate or misleading personal data;
4. Object to certain processing;
5. Request restriction of processing where applicable;
6. Request deletion or erasure where legally applicable;
7. Withdraw consent where processing is based on consent;
8. Request information concerning certain processing activities; and
9. Lodge a complaint with the Office of the Data Protection Commissioner.
The Data Protection Act, 2019 expressly provides data subjects with rights including the right to be informed, access personal data, object to processing and request correction of false or misleading data. ([Kenya Law][1])
25. HOW TO EXERCISE YOUR RIGHTS
To exercise your privacy rights, contact:
Email: [INSERT PRIVACY EMAIL]
Telephone: [INSERT PHONE NUMBER]
Subject: DATA PROTECTION REQUEST
Your request should include sufficient information to allow VunaBet to identify your account and understand the request.
VunaBet may request additional information to verify your identity before releasing, changing or deleting personal information.
This is intended to prevent unauthorised persons from accessing or changing your personal information.
26. RESPONSE TO DATA REQUESTS
VunaBet will process valid data-protection requests within the timelines required by applicable Kenyan law.
Some requests may be refused, restricted or delayed where permitted or required by law.
For example, information may need to be retained where necessary for:
1. Legal proceedings;
2. Regulatory compliance;
3. Fraud investigations;
4. Financial records;
5. Anti-money-laundering obligations; or
6. Other legal requirements.
7. CHILDREN'S PRIVACY
VunaBet is strictly intended for persons aged 18 years and above.
We do not knowingly permit children to create or use VunaBet accounts.
We do not knowingly collect personal information from persons under 18 for the purpose of allowing them to participate in gambling.
If we discover that an account belongs to a person under 18, we may immediately suspend or close the account and take appropriate action.
28. THIRD-PARTY WEBSITES
VunaBet may contain links to third-party websites or services.
VunaBet is not responsible for the privacy practices of third-party websites.
You should review the privacy policy of any third-party service before providing personal information.
29. PAYMENT PROVIDERS
When using third-party payment providers such as M-Pesa or Pesapal, information may be processed according to the privacy policies and terms of those providers.
VunaBet only requests and processes information reasonably necessary to facilitate, verify and reconcile transactions.
30. ACCOUNT DELETION
You may request closure of your VunaBet account.
Closing your account does not necessarily result in immediate deletion of all personal information.
Certain information may need to be retained because of:
1. Gambling regulations;
2. Financial regulations;
3. Tax requirements;
4. Anti-money-laundering requirements;
5. Fraud prevention;
6. Dispute resolution;
7. Legal claims;
8. Regulatory investigations; or
9. Other legal obligations.
Where retention is no longer necessary, VunaBet will take reasonable steps to delete, anonymise or securely dispose of the relevant information in accordance with applicable law.
31. DATA ANONYMISATION
Where appropriate, VunaBet may anonymise or aggregate information so that it can no longer reasonably be associated with an identifiable individual.
Anonymised information may be used for purposes such as:
1. Statistics;
2. Business analysis;
3. Game-performance analysis;
4. Platform improvement;
5. Security analysis; and
6. Regulatory reporting.
7. BUSINESS TRANSFERS
If VunaBet undergoes a merger, acquisition, restructuring, sale of assets or other corporate transaction, personal information may be transferred as part of the transaction where legally permitted.
Any such transfer shall remain subject to applicable data protection requirements.
33. CHANGES TO THIS PRIVACY POLICY
VunaBet may update this Privacy Policy from time to time.
Changes may be made because of:
1. Changes in Kenyan law;
2. Regulatory requirements;
3. Changes in our services;
4. Changes in payment providers;
5. Changes in technology;
6. Security requirements; or
7. Changes in our data-processing practices.
Where material changes are made, VunaBet may provide notice through the Platform, website, SMS, email or other appropriate communication channel.
The updated Privacy Policy will display a new "Last Updated" date.
34. CONTACT US
For privacy-related questions, requests or complaints, contact:
VunaBet
Website: https://vunabet.co.ke
35. COMPLAINTS TO THE DATA PROTECTION COMMISSIONER
If you believe that VunaBet has unlawfully processed your personal information or has failed to address your data-protection concerns, you may have the right to lodge a complaint with the Office of the Data Protection Commissioner of Kenya.
VunaBet encourages players to contact us first so that we can investigate and attempt to resolve the matter promptly, without limiting any statutory rights you may have.
36. ACCEPTANCE
By creating a VunaBet account, you acknowledge that:
1. You have read this Privacy Policy;
2. You understand how VunaBet processes your personal information;
3. You understand that certain information is necessary to operate your account;
4. You understand that VunaBet may share information with payment providers, service providers and authorities where legally permitted or required;
5. You understand your rights under applicable Kenyan data protection law; and
6. You understand how to contact VunaBet regarding your personal information.
PLAYER PRIVACY ACKNOWLEDGEMENT
☐ I confirm that I have read and understood the VunaBet Privacy Policy.
☐ I understand that VunaBet will process my personal information to create and manage my account, process payments, operate games, maintain security and comply with applicable laws.
☐ I understand my rights under Kenyan data protection law.
OPTIONAL MARKETING CONSENT
☐ I agree to receive promotional and marketing communications from VunaBet by SMS, email or other available communication channels.
You may withdraw optional marketing consent at any time through the available account settings or by contacting VunaBet.