Tajji Privacy Policy
Last Updated: February 2026
1. Who We Are
Tajji Real Estate Limited ("Tajji", "we", "us") operates:
- BomaOS – Shared property infrastructure for landlords, operators, and property managers
- Jirani – Tenant identity, payment, and participation platform
Tajji is registered with the Office of the Data Protection Commissioner (ODPC), Kenya as both a Data Controller and Data Processor.
2. Our Regulatory Posture
Tajji operates as infrastructure, not as:
- A marketplace
- A broker or agent
- A rent-setting coordinator
- A tax representative
- A collection agent
Tajji provides governed coordination tooling and ledger infrastructure. Our data processing posture reflects that infrastructure role.
3. Roles Under Data Protection Law
Depending on context, Tajji may act as:
3.1 Data Controller
Where Tajji determines the purposes and means of processing, including:
- Platform account creation
- Identity verification (KYC/KYB/KYW)
- Tenant onboarding via Jirani
- Security monitoring and audit logging
- Compliance and regulatory reporting
3.2 Data Processor
Where we process data to enable portfolio operations under BomaOS on behalf of landlords or operators.
The Client (landlord/operator) does not become a Data Controller for Jirani-collected data. Cross-platform flows
are governed under Tajji’s unified compliance framework.
4. Categories of Personal Data We Process
We may process:
Tenants (Residential & Commercial)
- Full name
- National ID / Passport
- KRA PIN (where required)
- Phone, email, address
- Lease ID and occupancy dates
- Rent and arrears balances
- Payment method metadata
- Bank account (masked)
- Mobile wallet ID
- Transaction references
- Next-of-kin contact
- Support tickets
Landlords / Property Owners
- Identity details
- KRA PIN
- Contact information
- Bank account (masked)
- Disbursement preferences
PMFs / Workforce / Vendors
- Name
- Role
- Contact information
- Attendance logs (geo-tag timestamps where applicable)
- Audit logs
- Bank account (masked)
Payments Data
- Payer identity
- Payee identity
- Payment tokens
- Transaction references
- Settlement status
Security & Access Events
- Credential ID
- Entry/exit timestamps
- Device IDs
- Incident notes
Analytics (Pseudonymized)
- Hashed user ID
- Usage metrics
- Device metadata
- Error logs
- Consent version IDs
5. Sensitive Personal Data
We may process limited categories of sensitive data where necessary, including:
- Health data (for safety/emergency response)
- Biometric data (for access control where enabled)
- GPS location (for workforce attendance and security audit trails)
- Marital or next-of-kin information (for tenancy guarantees or succession support)
We do not profile individuals based on race, religion, sexual orientation, or
genetic data.
Sensitive data is processed only where legally required, with explicit consent (where required), and under documented
DPIA coverage.
6. Why We Process Personal Data
We process personal data to:
- Verify identity (KYC / KYB / KYW)
- Register and govern occupancy relationships
- Execute billing and rent reconciliation
- Process payments with fund-class separation
- Coordinate maintenance and workforce workflows
- Preserve evidence for disputes
- Comply with regulatory obligations
- Maintain audit-grade ledgers
- Enforce containment states when applicable
We do not sell personal data.
7. Fund-Class Separation and Financial Data
Platform Fees, Rent Pass-Through, Security Deposits, Maintenance Reserves, and Utility Pass-Throughs are
distinct fund classes.
Personal data associated with each fund class remains separately attributable, not pooled across principals, and
never set off across fund classes.
8. Data Retention
Key principles:
- Ledgers are never destroyed
- Obligation-anchored records remain retained while governed relationships exist
- Dispute evidence is preserved during dispute lock
- Deletion means access revocation and lawful anonymization
- Audit logs survive termination
We retain data only as long as required for:
- Operational continuity
- Compliance
- Lawful dispute/regulator hold
- Audit reconstruction
9. Cross-Border Transfers
Tajji infrastructure may be hosted outside Kenya, including in EU data centers. Cross-border transfers are subject to:
- Adequacy safeguards
- Encryption in transit and at rest
- Access controls
- processor contractual safeguards
10. Security Measures
We implement:
- Encryption at rest and in transit
- Role-based access control
- Multi-factor authentication
- Immutable audit logging
- Container isolation
- Regular patching and vulnerability scanning
- 3-2-1 immutable backups
- DDoS mitigation
- Tokenized payment handling
Security is architectural, not additive.
11. Data Subject Rights
Subject to legal limitations, individuals may:
- Request access to their personal data
- Request correction
- Request deletion (where lawful)
- Object to processing
- Request data portability
- Withdraw consent (where consent-based)
Where data forms part of an active obligation graph or legal hold, deletion may be lawfully restricted.
Requests may be submitted to: privacy@tajji.io
12. Automated Decision-Making
We may use AI-driven decision support for:
- fraud detection
- risk flagging
- workflow prioritization
- Yield analytics (portfolio-scoped)
- Request data portability
- Withdraw consent (where consent-based)
AI outputs are non-binding and do not constitute legal or financial advice. No automated decision has legal effect without human oversight.
13. Children’s Data
Tajji does not knowingly process children’s data except:
- where required for lawful occupancy (e.g., minor listed as resident)
- with guardian or legal representative consent.
14. Regulatory Disclosures
We may disclose data:
- To regulators
- Under court order
- Under lawful enforcement request
- For AML/fraud investigations
Disclosure does not create agency representation.
16. Changes to This Policy
We may update this Privacy Policy to reflect:
- Regulatory changes
- Infrastructure changes
- Security posture updates
- Changes to tracking technologies or analytics providers
Material changes will be notified through platform channels.
15. Changes to This Policy
We may update this Privacy Policy to reflect:
- regulatory changes
- infrastructure changes
- security posture updates
- For AML/fraud investigations
Material changes will be notified through platform channels.