Privacy Policy

1. Scope and our role

This policy covers people whose information is handled through ClubKey, including club staff, members, membership applicants, dependants, reciprocal visitors, guests and people who contact us. Your club determines why and how it uses membership and operational records and is normally the data controller. Hilltop Labs Africa LTD processes that data on the club's instructions. We act as controller for our own subscription, enquiry, security and support records.

2. What we hold

• Identity: name, member number, photograph, date of birth, national ID or passport number, occupation and employer where the club's application form collects it.
• Contact: phone number (+254…), email, postal address, next of kin.
• Credentials: RFID card serials, digital pass tokens, PIN hashes (never the PIN itself).
• Activity: gate taps, bookings, class attendance, bar, restaurant and pro-shop charges, room folios, statements and payments.
• Guests: guest name, ID number, phone and vehicle registration captured at the gate for the security log.
• Club and staff records: club details, staff identity and contact details, role, permissions, station sessions, attendance and actions taken in the platform.
• Documents and communications: membership application files, reciprocal agreements, support correspondence, consent choices and data-rights requests.
• Technical records: session, device and service logs needed to authenticate users, prevent misuse, investigate faults and keep the service available.

3. Why we hold it

• To perform the membership contract between the member and their club.
• To provide the service under our contract with each subscribing club.
• To keep the property secure — a legitimate interest of the club and its members.
• To meet legal obligations, including tax and accounting records.
• To send club marketing and offers only where the member has consented, with an easy opt-out in the member portal.

4. Payments

Payments are processed over M-Pesa (Safaricom Daraja), card and bank transfer by licensed providers supervised by the Central Bank of Kenya. We receive confirmation references and amounts, not full card numbers or mobile-money PINs. ClubKey records charges and payment status for the club but does not hold member funds or operate a pooled reciprocity wallet.

5. Sharing and reciprocity

We do not sell personal data. When a member presents their card at a reciprocal club, that host club sees only what verification requires: name, photograph, member number, club, standing and entitlement — never the member's financial history at their home club. The host club then controls the visit record and any information it lawfully collects while providing its facilities. We use service providers for hosting, authentication, storage, communications, payments and operational support. They receive only the information needed to provide their service and are subject to contractual and legal safeguards.

6. AI-assisted agreement review

An authorised club administrator may choose to submit the text of a reciprocal agreement to an AI service through our service provider to suggest structured terms. The suggestion is not activated automatically: administrators from the participating clubs must review and accept the terms. Clubs should avoid including personal information that is not needed for that review.

7. International processing

Our technology and service providers may process data outside Kenya. Where personal data crosses borders, the club and Hilltop Labs Africa LTD, as applicable, use the transfer grounds and safeguards required by the Data Protection Act, 2019 (Kenya). Contact us for information about the safeguards relevant to your data.

8. Retention

Clubs set retention periods for operational, membership, access and guest records according to their legal obligations and policies. We retain data while the club's account is active and as needed to provide the service. Financial and audit records may be kept for seven (7) years, as expected for tax and accounting records. When data is no longer required, it is deleted or anonymised, subject to legal holds, backups and lawful record-keeping duties. CCTV, where used, remains under the club's own policy.

9. Your choices and rights

Under the Data Protection Act, 2019 (Kenya) you may request access to your data, correction, deletion, restriction or objection to processing, and portability where those rights apply. You can also withdraw optional marketing consent without affecting earlier lawful processing. Contact your club first because it controls your membership record, or write to lloyd@hilltoplabs.ai and we will help route the request. We may need to verify your identity. You may also complain to the Office of the Data Protection Commissioner (ODPC).

10. Security

We use layered safeguards appropriate to the service. Club access is scoped by role, capability and club; database access rules provide an additional club-level boundary. Shared devices use attributed station sessions, PINs and one-time codes are not stored in readable form, uploaded documents are held in private storage, and sensitive file links are short-lived. Security-relevant actions are recorded for accountability. No online service is risk-free, so clubs must keep staff access current, protect credentials and tell us promptly about suspected misuse. We assess incidents and notify affected clubs and authorities where the law requires it.

11. Children and dependants

Dependant and junior member profiles are created by the responsible adult member, who provides any authority required by the club and applicable law. Clubs should collect only what is necessary to administer that dependant's membership, access and charges.

12. Essential device storage and changes

The service uses essential browser storage and similar technologies to keep users signed in, remember the selected country and protect core workflows. We may update this policy as the service or law changes. Material changes will be communicated to subscribing clubs through an appropriate channel.