Privacy Policy: Nairobi
1. Who we are
Escape the GrindLife ("GrindLife", "the game") in Nairobi is run by PolicyMatch ("we", "us", "our"). We are the data controller for the personal data described here, under the Data Protection Act, 2019 and its regulations. This policy explains what personal data we collect when you use the Nairobi game, our websites and related services (the "Service"), how we use it, and the choices you have. It is part of our Terms of Service for Nairobi.
2. What we collect
Information you give us
| What | Details |
|---|---|
| Email address | To sign you in (we email you a one-time link and code) and to contact you about your account. |
| Handle and display name | The @handle and name you choose. Other players see them. |
| Birth year | You enter your full date of birth when you sign up. We use it once to check that you are 18 or older, then keep only the year and the time of the check. If you are under 18, we keep nothing about you: the date is checked on your device and is not sent or stored, and any email address you signed in with is deleted at once. The only thing we keep is a scrambled marker for your browser (section 9). |
| Career choice | The career you pick for your life in the game. |
| Agreement records | Which version of the Terms and this policy you accepted, and when. |
| Messages to us | If you write to us or send a report, we keep what you send and our reply. |
Giving us this is up to you. Without an email address and a date of birth showing you are 18 or older, you cannot make an account, and you can play only the single-player parts as a guest (section 9). An agent who does not give a KRA PIN and an M-Pesa number cannot be paid, because Kenyan tax law requires them.
Information from playing
| What | Details |
|---|---|
| Your saved game | Your character's progress: career, pay, money, home, belongings, choices and the game's calendar. Stored on our servers so you can play on any device, and on your device so you can play offline. |
| What you share | Posts, replies, likes and reposts in the game's feed, which other players see. |
| Messages | Messages you send to other players, with who they went to, when, edits, reactions, and whether they were delivered and read. Stored on our servers so they reach the people you sent them to. Before a message is sent, its text is checked automatically (see Moderation, below). Nobody at GrindLife reads your messages unless one is reported or an automatic check finds a problem. One more case: when you file a claim in the game's court, or one is filed against you, the court reviews the deal, the payments and your messages with the other player about it. Only the chat between the two of you, from the deal's first offer to the claim, never your other chats. |
| Moderation | To enforce our Terms, what players type to each other (messages, street chat and other posts) is checked automatically before it goes out, by our own rules and by OpenAI's moderation service. A second automatic review, by an OpenAI model working for us, reads: messages the first check was unsure about or stopped, every report, signs that a player may be under 18, and a small random share (about 2%) of direct messages between people who do not both follow each other, each with a few messages around it. The review sees no names or handles. A randomly checked message is not stored for review: if nothing is wrong, no record of it is kept, and nobody at GrindLife sees it. When something is wrong, we keep the message, the messages around it, the decision and what we did (a removal, a warning, a pause, a suspension, a lock or an age check). OpenAI processes this only to give us the result and does not use it to train its models. If you are asked to confirm your age, we keep your answer and the outcome. |
| Texts with characters | When you text one of the game's characters (Akinyi, Wambui, Mum, or someone you are dating in the game), what you write is checked the same way as messages (see Moderation), then sent with a few facts about your life in the game (your job, how stressed you are, whether rent is due) and your last few texts with that character to OpenAI, which writes the character's reply for us. OpenAI processes this only to give us the reply and does not use it to train its models. If you have an account or play as a guest, we keep your texts with characters so the conversation carries on, for 90 days; you can delete them in the game at any time, and they are deleted with your account. If you play without an account or guest identity (including anyone under 18), we keep none of it: the conversation stays on your device. Nobody at GrindLife reads these texts unless an automatic check flags one. |
| Dating | If you turn dating on: your settings (open or not, who can ask you, whether your partner shows on your profile) and when you confirmed your age again (only that you did, not your date of birth). For each person you date: the stage you are at, a closeness score, when it started and ended, and a timeline of asks, answers and dates. Dates you plan: the place, the time and who paid what in game money. Closeness comes only from time the server saw you spend together in the same place, never from your messages. We do not ask for or keep your gender, orientation or who you are interested in. |
| Invites | If you sign up through a friend's link: who invited you, and, to stop fake accounts claiming bonuses, a scrambled code made from your browser's random id and your IP address (not the address itself). |
| Presence | While you play online, where your character is in the game world, how they look and what they are doing, so other players nearby can see them. This is passed along live and not stored. |
| Open mic voice | When you take the mic at an open mic, your voice goes live to the players listening in that room and is not recorded or stored. If someone reports a set, we keep the report: who was on stage, when the set started, how many were listening, and the reporter's reason and note. If a set breaks our rules, we keep the mic pause we put on the account. To keep players' IP addresses private, voice can pass through our own relay server. |
| Usage stats | Counted by our own server, never by another company: which pages are opened, how long each stays on screen and whether it was used at all (not what was tapped), which sign-up steps are finished, and what you do in the game, like which apps you open, which kinds of places you go into and which activities you start. We never record what you write or your exact location, and we look at it only to understand how the game is played and make it better. Also counted: the site or campaign that sent the visit, browser and device type, your country, region and city (from our network provider, not your device), and which days your account played. Visits carry random ids, and the per-browser one is not used at all if your browser sends Do Not Track or Global Privacy Control. No IP address is kept with any of it. We mostly look at it as totals, like "how many played today", some of which we publish at grindlife.app/stats. To fix problems and see how the game is used, our admins can also see recent visits one by one (the pages, how long, the city and the device), and the visits from one browser, or from one account across the browsers it signs in on, together under a random label, never with your name, email or IP address. Deleting your account unlinks its visits. It is never used for advertising. |
| Device and connection | Your IP address, browser type and version (the "user agent"), and when you signed in and were last active. We use these to keep accounts safe, stop abuse and fix problems. |
What we do not collect
We do not collect your real-world location, your contacts, photos from your device (other than photos you choose to upload for a shop stall), your M-Pesa PIN or payment card details. We do not use advertising or analytics trackers from other companies.
If you book a billboard
When a business books billboard days we collect the name of the person booking, the business or brand name, an email address if one is given, the link given (if any), the artwork uploaded, the spots and dates booked, the M-Pesa number that pays, and Paystack's reference for the payment. The payment prompt goes to that number through Paystack, and the mobile money provider (Safaricom, for M-Pesa) processes it. We never receive the M-Pesa PIN. We use this to run, review and report on the ad, to send receipts and updates, to refund a payment when we must, and to keep the business records Kenyan law requires. If an agent booked for the business, the agent sees the business's name, the booking and its status, and receives the receipt when the business gave no email.
Advertisers get counts only: how many times their ad was on screen and how many players saw it. We never give advertisers anything that identifies a player.
If you work as an ad agent
When you join as an agent (Terms, section 5B) we keep your agent code, the name you go by, when you accepted the agent terms, when you were approved, and the bookings credited to you. Before your first payout we collect your KRA PIN, the M-Pesa number you want to be paid on, and whether you live in Kenya (which sets the tax withheld). Your KRA PIN and payout number are stored encrypted. We also keep a scrambled (keyed hash) form of your payout number, so we can check that a business did not pay from it, and the last digits of both, so you can recognise them. We keep every share earned, cancelled or taken back, every payout (what you earned, the tax withheld, what was sent, and Paystack's reference for the transfer) and its status.
We use this to pay you, to withhold and pay tax to the Kenya Revenue Authority (KRA) and file the returns that go with it, to stop fraud, and to keep the records Kenyan tax law requires. Paystack receives your payout number and name to send the transfer. KRA receives what the law requires for the tax withheld, including your KRA PIN.
If you write books
When you write in the Library app we keep your drafts (title, description, chapters) on your account, any private sharing link you make, the copy you send for publishing, our review of it and the reasons we gave, your price, your sales and earnings in game money, and reports other players make about your book. A published book is public, in the game and on its own page on grindlife.app, with your handle and display name. Before a book goes public, its text is checked against our rules by our content-checking provider (OpenAI), which processes it for us only to give us the result and does not use it to train its models. If you pay to publish or to feature a book, Paystack handles the payment, in Kenya shillings: by an M-Pesa prompt to the number you give, or by card on Paystack's payment page. We get your email address, the amount and Paystack's reference for the payment, never your M-Pesa PIN or card details. The M-Pesa number goes to Paystack to send the prompt; we do not keep it.
If you sell from a shop stall
When you apply to sell (Terms, section 5C) we keep your trading name, what you write about your stall, the phone number you give, when you accepted the stall terms, and our decision. The phone number is stored encrypted, beside a scrambled (keyed hash) form of it and its last digits. A person on our team calls it once to confirm it is yours, or, where we offer it, we send it a one-time code on WhatsApp. We keep your stall's details, items, prices, opening hours, links and photos, and our review of each. Photos are re-saved by our server before anyone sees them, which removes their hidden data (camera details and any location). What we approve is public, in the game and on the stall's own page, with your trading name. We count visits to your stall and taps on its links, one per viewer a day, and show only the totals to you. If you rent a pitch, Paystack handles the payment as for books, and we keep the order and Paystack's reference. If players report your stall, we keep the reports and what we decided. We use this to run the stalls, to keep them safe and honest, and to keep the records Kenyan law requires. Chats with buyers inside GrindLife are messages like any other between players: kept the same way, read by a person only when one is reported, and a report about your stall carries the chat it came from. Whether you show as away, and when buyers started chats, is kept to run the chat. Buyers who contact you through a stall's links do so outside GrindLife: we never see those conversations.
If you sell or buy books for real money
If you buy a copy of a player's book, we keep the order (the book, the price, the currency, when it was paid or refunded), Paystack's reference for the payment and your email address, and we record that the copy is yours. The M-Pesa number that pays goes to Paystack to send the prompt; we do not keep it. When you read a paid book, your handle is printed faintly on its pages, and we count how many pages you open in an hour to stop copying. If you sell books (Terms, section 7A), we keep every sale, your share of it, every payout (what you earned, the tax withheld, what was sent, and Paystack's reference for the transfer) and its status. Before your first payout we collect your KRA PIN, the M-Pesa number you want to be paid on, the name you go by and whether you live in Kenya (which sets the tax withheld). Your KRA PIN and payout number are stored encrypted, beside a scrambled (keyed hash) form of the number and the last digits of both, so you can recognise them. Paystack receives your payout number and name to send each payout. We pass the tax withheld and your KRA PIN to the Kenya Revenue Authority, as the law requires. Authors see how many copies sold, never who bought them.
3. Why we use it, and on what basis
- To run the game: sign you in, save and sync your game, and show your handle, name, character and posts to other players. Basis: performing our contract with you (the Terms).
- To keep it for adults: check that everyone with an account is 18 or older. Basis: our legal obligations, including the Act's rules on children's data, and our contract with you.
- To keep players and the Service safe: stop spam, cheating and abuse, limit repeated sign-in attempts, review reports and enforce our Terms. Basis: our contract with you and our legitimate interest in a safe game, balanced against your rights.
- To take payments and pay agents and authors: process billboard bookings, book fees, copies of books, agent and author payouts, and withhold tax. Basis: performing the contract, and our legal obligations under Kenyan tax law.
- To talk to you: send sign-in emails, answer your messages, and tell you about important changes to the Service, the Terms or this policy. We will not send you marketing messages unless you ask for them.
- To improve the game: understand, in aggregate, how the game is played and where it breaks. Basis: our legitimate interests.
- To meet legal duties: keep records the law requires and respond to lawful requests. Basis: legal obligation.
Where we rely on your consent, you can withdraw it at any time. That does not affect what we did before.
4. Who can see it
- Other players see your handle, display name, character, posts and replies, and where your character is when you are online in a shared place. They never see your email address, birth year, M-Pesa number or KRA PIN.
- Service providers who work for us under contract and only on our instructions: Hetzner, which runs our servers and database (section 10); our email delivery provider; Paystack, for payments for billboards, book fees and copies of books (by M-Pesa or card) and for agents' and authors' payouts; the Kenya Revenue Authority, for the tax we withhold from payouts; and OpenAI, for checking books before they are published, for checking messages and posts (section 2, Moderation), for the game's court when a claim you are part of is disputed (section 2, Messages), and for writing the replies of the game's characters when you text them (section 2, Texts with characters). They may use the information only to provide their service to us.
- The Kenya Revenue Authority, for tax withheld from agents' payouts, as the law requires.
- Authorities, when the law requires it, or when we believe in good faith that it is needed to protect someone's safety, to investigate abuse such as sexual content involving minors, or to protect our rights.
- A new owner, if the game is sold or merged, who must follow this policy for the information they receive. We will tell you before that happens.
We do not sell your personal information, and we do not share it for targeted advertising.
5. Cookies and storage on your device
We use one cookie, and it is needed for the game to work:
| Name | What it does | How long |
|---|---|---|
| gl_session | Keeps you signed in. It holds a random code that only works on our servers. Your browser cannot read it with scripts, and it is only sent to our own site. | 60 days, or until you sign out |
The game also keeps information in your browser's storage: your saved game, your settings, the city you play in, and a random id for this browser that keeps your posts linked to you when you play signed out in testing. This stays on your device. You can clear it in your browser's settings, which removes the offline copy of your game but not the copy on your account. If a birthday under 18 is entered, the browser also keeps a note of that for one year (section 9). A second random id, for usage stats, goes with each visit (section 2). It is never made if your browser sends Do Not Track or Global Privacy Control. An agent's link code, when a business opens it, is kept on the business's device for 30 days so the booking can be credited.
We do not use advertising cookies or third-party tracking cookies.
Podcasts: episode audio and show art load straight from each show's publisher, whose servers see your IP address like any website you visit. Our server fetches the show lists and feeds on your behalf. The shows you follow and where you left off are kept on your device and in your saved game.
6. How long we keep it
| What | How long |
|---|---|
| Your account, saved game and agreement records | While your account exists. Deleted at once when you delete your account. |
| Your handle after you delete your account | Held for 30 days so nobody can take it straight away and pretend to be you, then released. Nothing else is kept with it. |
| Sign-in links and codes | Expire after 15 minutes, can be used once, and are deleted within a day. |
| Sign-in sessions (with IP address and browser type) | Until you sign out, or 60 days. |
| Sign-ups that were never finished | Deleted after 7 days. |
| Under-18 browser marker (section 9) | One year, then deleted. |
| Server logs (with IP addresses) | Up to 30 days. |
| Usage stats | Visit records 13 months. Days your account played, 400 days, or until you delete your account. Daily totals with nothing about any one person in them are kept. |
| Backups | Deleted data leaves our backups within 30 days. |
| Billboard bookings and payments | Five years from the end of the tax year they relate to, as the Tax Procedures Act, 2015 requires, and longer only while a tax audit, a claim or a dispute about them is open. Kept for that purpose only. |
| Agent records (KRA PIN, payout number, shares, payouts, tax withheld) | Five years from the end of the tax year they relate to, as the Tax Procedures Act, 2015 requires, and longer only while a tax audit, a claim or a dispute about them is open. If you delete your account, these records are kept for that purpose only, no longer linked to an account. |
| Books you write | Until you delete them. Deleting your account deletes your books too, including from the shelves of players who bought them. Payment records are kept as long as tax law requires. |
| Book sales, author payouts and payout details | Five years from the end of the tax year they relate to, as the Tax Procedures Act, 2015 requires, and longer only while a tax audit, a claim or a dispute about them is open. Your KRA PIN and payout number are kept while you sell books and for that period after. Kept for that purpose only. |
| Messages | Up to 12 months, then deleted. A message you unsend is wiped at once. Deleting your account deletes the messages you sent. A reported message and the ones around it are kept with the report. Messages the game's court reviewed for a claim are kept with that claim. |
| Dating | Settings while your account exists. A relationship and its timeline until 12 months after it ends. Asks and answers 90 days, longer if one was reported. Reports about dating are kept as other reports are (below). Deleting your account deletes all of it; the other person sees "Deleted account". |
| Who invited you | While your account exists. |
| Reports and moderation decisions | Items reviewed with no action: deleted within 90 days. Randomly checked messages with nothing wrong: not kept at all. Actions and their evidence (the message and the few around it): up to 400 days, so we can handle appeals and repeat problems, and longer where the law requires it (for example, evidence we must preserve after a report of sexual content involving a minor). In-app notices: 90 days after you see them. Daily totals with nothing about any one person in them are kept. |
7. How we protect it
The Data Protection Act, 2019 requires us to protect personal data by design and by default. We keep reasonable administrative, technical and physical safeguards for the data we hold. Among other things:
- Everything between your device and our servers is encrypted in transit (HTTPS).
- There are no passwords to steal. Sign-in links and codes work once and expire in minutes.
- Sign-in codes and session codes are stored only in a scrambled (keyed hash) form, so a copy of our database could not be used to sign in as you.
- Agents' KRA PINs and payout numbers are stored encrypted, and only the last digits are shown on screen.
- Repeated sign-in attempts are limited, and only a few people who need it for their work can reach the servers.
- We collect as little as we need and delete what we no longer need.
No system is perfectly secure. If someone gets into your personal data without permission and there is a real risk of harm to you, we will tell the Data Commissioner within 72 hours of becoming aware of it, and tell you in writing within a reasonably practical time, as section 43 of the Act requires. We may delay telling you if the police or another authority need that to investigate a crime, and we cannot tell you if we cannot work out who you are.
8. Your rights and choices
Under the Data Protection Act, 2019 you have the right:
- to be told how your data is used. This policy explains it. Ask us if anything is unclear.
- to get a copy of your data. In the game, open Account, then Download my data. You get one file with everything we hold about your account.
- to take it elsewhere. That file is in a common, machine-readable format.
- to have wrong or misleading data corrected. Change your display name in the game. To change your email address or anything else, write to us.
- to have it deleted. In the game, open Account, then Delete my account. Your account and saved game are deleted at once (see section 6 for the handle hold, backups and records the law makes us keep).
- to object to our use of your data, including where we rely on our legitimate interests.
- not to be subject to a decision made only by automated means that significantly affects you. Every automatic moderation action can be appealed, and a person on our team looks again (Terms, section 8). Only a person can close an account for good.
We do not sell your data, share it for targeted advertising, or use it for direct marketing, so there is nothing to opt out of there.
How to make a request
- Use the tools in the game, or use our contact form with the subject "Privacy or data request", giving the email address on your account.
- To protect you, we confirm requests by email to the address on the account before we act on them.
- You can ask someone to make a request for you. We will need your signed permission, and we may ask you to confirm the request yourself.
- We answer within the times set by the Data Protection (General) Regulations, 2021, counted from when we receive the request:
Request We answer within A copy of your data 7 days Correcting your data 14 days (7 days to tell you if we say no) Deleting your data 14 days Objecting to a use of your data, or asking us to limit it 14 days Moving your data to another service 30 days (7 days to tell you if we say no) - Using your rights is free. The one exception the regulations allow: for a request to move your data that goes beyond the download in the game, we may charge a reasonable fee that is no more than what it costs us, and we tell you first. We will never treat you differently for using your rights.
- We may refuse a request that is plainly unfounded or excessive, or where the law lets or makes us keep the data (section 6). If we say no to a request, we tell you why in writing, and that you can complain to the Data Commissioner. You can also ask us to look again by replying to that email.
- If you are not happy with how we handled your data or a request, you can complain to the Office of the Data Protection Commissioner (ODPC) at odpc.go.ke.
9. Adults only
Guests. You can play the single-player parts without an account. A guest's saved game stays in their own browser and we keep no copy, so it is lost if that browser's storage is cleared (by you, when a private window closes, or by the browser itself: some browsers, Safari for one, clear a site's storage after about seven days without a visit). We do not ask a guest for an email, a name or a date of birth, and we do not try to work out who a guest is. When a guest starts a life, our server gives their browser a signed note of the time and keeps a small guest record with a session cookie: no email, no name, no birth date, just a random tag ("Nairobian #4f2a"), the job they picked, when it was last used, and, if they work gigs, the gigs, where the game saw them on a gig, ratings and a wallet that can only receive gig pay. It lets the game count the time they already played, pay them for gigs and keep their table wins if they make an account later, when the record becomes their account. A guest record nobody uses for 90 days is deleted, with what its wallet held. While a guest plays, our server sees the same things it sees for any player in the street (where their character is, its look and job, never a name) and the usage stats in section 2. The random ids and the ticket are used only to run and measure the game, never for advertising or to build a profile of anyone. A guest never writes their own words to anyone and never receives anyone else's (posts and replies typed by players reach a guest without the words). Messages, posts, dating, sending game money, publishing and buying players' books need an account confirmed 18 or older. Anyone may read a free book by a player, or the opening pages of one for sale, unless it is marked 18+. Someone who signs in only to read and buy books (a reader) gives us an email address and a date of birth (we keep the year) and accepts the Terms; we keep those, their purchases and what they read, as for any account, and they need not make a character.
GrindLife is meant for adults, and is not made for children. Under Kenyan law a child is anyone under 18, and the Data Protection Act, 2019 allows a child's data to be processed only with a parent's or guardian's consent. We do not ask for that consent, because we do not knowingly collect personal data from anyone under 18. Chat, dating, posting, payments and other features that involve other players need an account confirmed 18 or older. If you believe someone under 18 has given us information, tell us through our contact form and we will delete it.
If you tell us you are under 18. When the birthday you enter says you are under 18, you can't make an account, and you can keep playing as a guest on your device. We keep no birthday and no email: the date is checked on your device and never sent to us, and if you had already signed in with an email, that email is deleted at once. Your guest record on our server (if there was one) is deleted too. From then on, on that device, other players are hidden from you and you are hidden from them, and the parts of the game that involve other players are closed. To stop the age check from simply being tried again with another date, we keep one thing: a scrambled marker made from the random id your browser already has (section 5). It can't be turned back into that id, it says nothing about who you are, and it is kept with no birthday, email, IP address or anything else. While it lasts, that browser can't make a new account. It is deleted after one year. Your browser also keeps a note of the answer for the same year.
We do not ask everyone for ID. If something suggests a player may be under 18 (what they write, or a report), we ask them to confirm their date of birth again and limit some features until a person on our team checks. We may later offer an age-verification provider for this; if we do, we will name it here first, and say what it receives.
10. Where your data is stored
Your data is stored on servers outside Kenya, in the United States. The servers are run for us by Hetzner, in Ashburn, Virginia. Some of our service providers (section 4) also process data outside Kenya. So when you use the Service, your personal data is transferred out of Kenya.
The Data Protection Act, 2019 (sections 48 and 49) and its regulations allow a transfer out of Kenya on a few grounds. We rely on two:
- Appropriate safeguards. Each provider that receives your data outside Kenya is bound by a written contract to use it only on our instructions, keep it secure and confidential, and not pass it on except as the contract allows. We add our own safeguards from section 7: encryption in transit, keyed hashes for sign-in codes, encryption for KRA PINs and payout numbers, and access limited to the few people who need it. We keep a record of these transfers and can show it to the Data Commissioner.
- Our contract with you. The game you signed up for runs on those servers, so the transfer is necessary to provide it to you.
We do not ask for sensitive personal data (such as your health, religion, ethnicity or sexual orientation), and we do not move any out of Kenya on purpose. You keep every right in section 8 wherever your data is stored. Privacy laws in the United States differ from Kenya's.
11. Changes to this policy
If we change this policy, we will update the date and version at the top. If a change matters, we will tell you in the game or by email, and where the law requires it we will ask for your agreement.
12. Contact us
Connect on X: @delicto_nick
Contact: grindlife.app/contact