Legal

Privacy Policy

Last updated: 17 August 2026 · Effective: 17 August 2026

We wrote this in plain language because we believe you should actually read it. If something is unclear, email us at dataprivacy@castalia.co.ke and we will explain it.
Registration status: Castalia Kenya Limited is in the process of registering as a data controller/processor with the Office of the Data Protection Commissioner (ODPC) under the Data Protection Act 2019. We are complying with the Act's substantive obligations (lawful processing, security safeguards, data subject rights) ahead of and independent of registration, which is an administrative step. This notice will be updated with our registration number once issued.

Who we are

Castalia is a venture evaluation platform built on the SVIE OS framework. We are operated by Castalia Kenya Limited, registered in Kenya. When this policy says "Castalia", "we", "us", or "our", it means us.

Our contact for data matters: dataprivacy@castalia.co.ke · castalia.co.ke · Nairobi, Kenya.

What data we collect — and why

We only collect data that is necessary to operate the platform. Here is what that means in practice:

Account information

When you create an account, we collect your name, email address, and (if you sign in with Google) your Google profile name and profile picture. We use this to identify you, secure your account, and contact you about your evaluation. We do not sell this to anyone.

Venture evaluation data

The answers you provide during an SVIE OS evaluation — your problem description, customer validation evidence, business model details, and all other module responses — are private to you by default. This is your venture intelligence. It belongs to you.

Your evaluation data is shared with third parties only in two circumstances: (a) you explicitly choose to share your profile with a Tier 2 or Tier 3 partner on the platform, or (b) we are required to by law. We will tell you before sharing unless a court order prevents us from doing so.

Chat helper

If you use the in-app chat helper, we store your conversation — your messages, the assistant's replies, and any files you attach — so you can return to past conversations and so the assistant can use earlier context in the same thread. This history is private to your account: we don't use it to answer other users' questions, and staff cannot browse your conversation content directly. You can delete any conversation permanently at any time from the chat panel, which also removes any files you attached to it.

We do keep a separate, lightweight record of the questions asked and answers given (without your full conversation thread) so we can identify common questions and improve the platform's help content. This record is used for improving the product, not for personalising ads or profiling you individually.

Compliance and sector-readiness evidence

If your evaluation includes sector-specific compliance modules, any evidence you upload (licences, permits, registration documents, or other supporting files) is stored against your evaluation and treated with the same privacy protections as your other evaluation data. It is not shared with regulators or third parties by us; you remain responsible for your own regulatory filings.

Payments

If you pay for a plan or credits, we collect the billing details needed to process payment. Card payments are handled by Stripe; M-Pesa payments are handled via Safaricom's M-Pesa API. We do not store your full card number. For M-Pesa, we retain your phone number and transaction reference to confirm and reconcile payment. We do not have access to your M-Pesa PIN or banking credentials.

Support tickets and newsletter

If you contact support or raise a ticket, we store your message and any files you attach so we can respond and keep a record of the resolution. If you subscribe to our newsletter, we store your email address and subscription status; you can unsubscribe at any time via the link in any newsletter email or by contacting us.

Profile images and organisation details

If you upload a profile photo, or if you create or join a studio or investor organisation, we store that image and the organisation's name, logo, and country. Organisation admins can see the profile information of members associated with their organisation (for example, a studio can see the founders in its cohorts).

Data shared with us by studios and investors

If a studio invites you into a cohort, or an investor invites you to evaluate via their invite link, the studio or investor may provide us with your name and email address to send that invitation. If you are matched to an investor thesis, or an investor leaves notes on your venture in their deal pipeline, that information is stored against your venture profile. If you do not match an investor's thesis, the investor is told that you applied and did not match, and why — this explanation may reference details from your evaluation.

Usage data

We collect basic usage data — which pages you visit, how long you spend on each module, whether you complete an evaluation. We use this to improve the platform. We do not build advertising profiles. We do not sell usage data.

AI processing

Your evaluation answers are processed by Google Gemini to generate your scored results and evaluation feedback. This is subject to Google's own data processing terms, and we configure our use of their API to prevent your data from being used to train their underlying models. If you have questions about this processing, email us.

Legal basis for processing (Kenya DPA 2019)

Under the Kenya Data Protection Act 2019, we must have a lawful reason to process your data. Our reasons are:

  • ·Performance of a contract — we process your data to provide you with the evaluation service you signed up for.
  • ·Legitimate interest — we use usage analytics to improve the platform in ways that benefit users.
  • ·Consent — where we ask your permission before doing something specific with your data (e.g. sharing your profile with a partner), we rely on your explicit consent, which you can withdraw at any time.

Pan-African note

If you are using Castalia from Nigeria, your data processing is also conducted in accordance with Nigeria's Nigeria Data Protection Act 2023 (NDPA). If you are in South Africa, it is conducted in accordance with the Protection of Personal Information Act 2013 (POPIA). In all cases, the Kenya DPA 2019 standard applies as our baseline, and where another country's law is stricter, we apply the stricter standard.

Cross-border data transfers

Some of the infrastructure providers we use to run Castalia are hosted outside Kenya. This means your personal data may be transferred to and processed in other countries, including the United States and the European Union, by the following categories of provider:

  • ·Database and file storage — Supabase, which hosts our database and stores uploaded files.
  • ·AI processing — Google Gemini (see above) for generating evaluation scores and feedback.
  • ·Payments — Stripe (card payments) and Safaricom M-Pesa (mobile money) for processing transactions.

Under the Kenya Data Protection Act 2019, we may only transfer personal data outside Kenya where appropriate safeguards are in place. Our safeguards include: using providers that are contractually bound by their own data processing terms and industry-standard security certifications, transmitting all data over encrypted connections, and limiting what is sent to each provider to what is necessary for the service they perform. We do not transfer sensitive personal data outside Kenya without your consent.

How long we keep your data

  • ·Your account information: until you delete your account, plus 90 days for backup recovery.
  • ·Your evaluation data: until you delete it, or until you delete your account.
  • ·Chat conversations and attached files: until you delete the conversation, or until you delete your account.
  • ·Usage analytics: aggregated and anonymised after 12 months.
  • ·Backups: retained for 30 days, then permanently deleted.

Your rights

Under the Kenya Data Protection Act 2019 (and applicable regional laws), you have the right to:

  • ·Access — request a copy of all personal data we hold about you.
  • ·Correction — ask us to fix inaccurate or incomplete data.
  • ·Deletion — request that we delete your data. We will comply within 30 days unless we are legally required to retain it.
  • ·Portability — request your evaluation data in a machine-readable format.
  • ·Restriction — ask us to pause processing your data while a dispute is resolved.
  • ·Objection — object to specific processing activities.
  • ·Withdraw consent — where we rely on consent, you can withdraw it at any time without affecting what happened before withdrawal.

To exercise any of these rights, email dataprivacy@castalia.co.ke. We aim to acknowledge your request within 7 days and resolve it within 30 days — the same timeframe the Act sets for data portability requests, which we apply as our standard for all rights requests. Complex or unusual requests may take longer; we will tell you if that's the case and why.

Data security

We take data security seriously. Specifically:

  • ·All data is transmitted over HTTPS/TLS.
  • ·Passwords are hashed using bcrypt — we cannot read your password.
  • ·Your evaluation data is stored in Supabase (hosted infrastructure with SOC 2 compliance).
  • ·We use row-level security to ensure no user can access another user's data.
  • ·API keys and credentials are stored in environment variables, not in code.

No system is perfectly secure. If we ever suffer a data breach that affects your personal data, we will notify you within 72 hours and report it to the Office of the Data Protection Commissioner (Kenya) within the legally required timeframe.

Cookies

We use only the cookies necessary to keep you logged in (session cookies). We do not use advertising cookies, tracking pixels, or third-party analytics cookies. You can disable cookies in your browser, but doing so will prevent you from staying logged in.

Children

Castalia is designed for adults operating or evaluating businesses. We do not knowingly collect data from anyone under 18. If you believe a child has created an account, contact us at dataprivacy@castalia.co.ke and we will delete the account immediately.

Changes to this policy

If we make material changes to this policy, we will notify you by email at least 14 days before the changes take effect. Non-material changes (like fixing typos) will be updated without notice. The "last updated" date at the top of this page always shows when the policy was last changed.

Contact and complaints

For privacy questions: dataprivacy@castalia.co.ke

If you are not satisfied with our response, you have the right to complain to the Office of the Data Protection Commissioner (ODPC) in Kenya at odpc.go.ke.

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