CircleDrama

Privacy Policy

1. About this Privacy Policy

This Privacy Policy explains how personal data is collected, used, stored, shared and protected when you access or use CircleDrama, a short-form microdrama entertainment platform made available to eligible users in Kenya.

In this Privacy Policy, "Platform" means the microdrama entertainment service, including any website, mobile page, app, link, player, message, support channel, feature or video content made available through it. "We," "us" and "our" refer to the party responsible for operating the Platform. "You" means a person who accesses or uses the Platform.

The Platform is an entertainment offering. It is separate from any gas supply, LPG delivery, equipment, safety, billing, customer account or other services provided by any third party. This Privacy Policy applies only to personal data processed in connection with the Platform.

2. Who can use the Platform

The Platform is intended for eligible users in Kenya who receive access or are otherwise authorised to use it.

We may process limited information to confirm that you are eligible to access the Platform and to monitor whether access is being used in accordance with this Privacy Policy and the Terms of Service.

3. Personal data we collect

We collect only the personal data reasonably needed to provide, secure, monitor and improve the Platform.

3.1 Information you provide

We may collect information that you provide directly, including:

mobile phone number;
email address, if used;
name or display name, if provided;
support messages or feedback;
language, notification or content preferences you select in the Platform.

3.2 Eligibility information

Because the Platform is made available only to eligible users, we may receive or process limited information from authorised partners or service providers to confirm eligibility and activate access. This may include:

mobile phone number;
customer reference, access code or account identifier;
eligibility status;
access activation status;
basic support or verification information.

We do not use eligibility information for unrelated purposes.

3.3 Usage, viewing and monitoring information

When you use the Platform, we may collect and monitor information about your activity for service operation, analytics, security, anti-fraud and anti-piracy purposes, including:

videos, episodes or series viewed;
watch progress;
clicks, searches or selections;
time spent using the Platform;
content preferences;
access attempts, failed logins or unusual account activity;
suspected misuse, unauthorised sharing, copying, screen recording, downloading, scraping or distribution activity;
error reports;
support activity.

3.4 Device and technical information

We may automatically collect technical information, including:

IP address;
device type;
browser or app version;
operating system;
language settings;
approximate location derived from IP address or device settings;
device identifiers;
log data;
crash reports;
diagnostic and performance data;
security signals used to detect unauthorised access, tampering, circumvention, automated activity or hacking attempts.

3.5 Cookies and similar technologies

If the Platform is accessed through a website, browser, mobile page or embedded player, we may use cookies, pixels, local storage or similar technologies to:

keep you signed in;
remember preferences;
measure performance;
understand how the Platform is used;
protect against misuse, unauthorised access, piracy and content distribution;
improve video delivery.

You may be able to manage cookies through your browser or device settings. Some features may not work properly if essential cookies are disabled.

3.6 Access information

We collect only the information reasonably needed to confirm eligibility, provide access, operate the Platform, provide support, secure the Platform, monitor compliance and understand Platform performance.

Access to the Platform is made available only as described in the invitation, access message or instructions provided to eligible users.

3.7 Sensitive personal data

The Platform is not designed to collect sensitive personal data. Please do not send sensitive personal data through the Platform unless we specifically request it for a lawful and necessary purpose.

4. How we collect personal data

We may collect personal data:

directly from you when you access the Platform, use features or contact support;
automatically when you use the Platform;
from authorised partners or service providers where needed to confirm eligibility, provide access or support the Platform;
from technical service providers that help us operate, secure, analyse, monitor or improve the Platform.

5. How we use personal data

5.1 To provide the Platform

We use personal data to:

confirm eligibility;
activate and maintain access;
provide video streaming;
remember watch progress;
show relevant content;
respond to support requests;
send service-related messages.

5.2 To secure and monitor the Platform

We use personal data to:

verify access;
prevent unauthorised use;
monitor access and usage patterns;
detect misuse, fraud, abuse, piracy or unauthorised distribution;
detect attempts to hack, bypass, disable, reverse engineer or interfere with the Platform;
protect the Platform, users, rights holders and our systems;
investigate technical, legal, security or intellectual property issues.

5.3 To improve the Platform

We may use usage, device and performance data to:

understand how the Platform is being used;
improve the user experience;
fix bugs;
improve video delivery;
measure Platform performance;
develop aggregated or anonymised insights.

5.4 To communicate with you

We may use your contact details to send:

access messages;
service updates;
support responses;
important notices about the Platform;
privacy or terms updates.

We will only send direct marketing where permitted by applicable law.

5.5 To comply with law and protect rights

We may process personal data where necessary to:

comply with applicable law;
respond to lawful requests;
enforce our terms;
resolve disputes;
protect legal rights, safety, intellectual property and security.

6. Legal basis for processing

We process personal data only where we have a lawful basis under applicable Kenyan data protection law. Depending on the purpose, we may rely on:

your consent;
performance of a service requested by you;
compliance with legal obligations;
our legitimate interests in operating, securing, monitoring and improving the Platform;
protection of legal rights, safety, intellectual property and security.

Where we rely on consent, you may withdraw consent at any time, subject to any legal or operational limits.

7. Sharing personal data

We do not sell your personal data.

We may share personal data only where necessary and appropriate, including with the categories of recipients below.

7.1 Authorised partners and service providers

We may share limited information with authorised partners or service providers to:

confirm eligibility;
activate or maintain access;
provide support;
prevent misuse, fraud, piracy or unauthorised distribution;
monitor Platform performance and compliance;
resolve technical or access issues.

7.2 Technical and operational service providers

We may use trusted service providers for:

hosting;
video delivery;
authentication;
analytics;
customer support;
error reporting;
security monitoring;
anti-piracy monitoring;
communications;
system administration.

These providers may process personal data only for authorised purposes and must apply appropriate safeguards.

7.3 Legal, safety and rights-protection reasons

We may share personal data where necessary to:

comply with applicable law;
respond to lawful requests from authorities;
enforce our terms;
investigate suspected misuse, hacking, piracy or unauthorised distribution;
protect users, systems, rights, safety and property.

7.4 Business or operational changes

If the Platform is reorganised, transferred or discontinued, personal data may be transferred or handled as part of that process, subject to appropriate safeguards and applicable law.

8. International transfers

Some service providers may process personal data outside Kenya. Where personal data is transferred outside Kenya, we will take steps required by applicable law to protect the data, including using appropriate contractual, technical and organisational safeguards where required.

9. Retention

We keep personal data only for as long as necessary for the purposes described in this Privacy Policy.

eligibility and access records are kept for the duration of Platform access and a reasonable period afterward for support, audit, security and dispute purposes;
support records are kept as long as needed to resolve your request and maintain service records;
technical logs and security monitoring records are kept for a limited period for security, debugging, anti-piracy, compliance and performance purposes;
aggregated or anonymised data may be kept for longer because it no longer identifies you.

When personal data is no longer needed, we will delete it, anonymise it or securely retain it only where required by law or legitimate operational needs.

10. Security

We may monitor usage activity, device activity, concurrent sessions, IP activity, playback behaviour and technical indicators to detect piracy, credential sharing, unauthorised distribution, scraping, recording, automation, circumvention, hacking attempts or other misuse of the Platform.

Unauthorised copying, screen recording, redistribution, rebroadcasting or commercial exploitation of content may result in suspension, termination of access, legal action, reporting to authorities and other enforcement measures permitted by applicable law.

If we become aware of a data security incident affecting personal data, we may investigate, contain, notify affected parties and take other steps in accordance with applicable Kenyan law.

We use reasonable technical and organisational measures to protect personal data against unauthorised access, loss, misuse, alteration or disclosure.

These measures may include access controls, encryption in transit, monitoring, restricted permissions, anti-fraud controls, anti-piracy monitoring and secure operational practices.

No online service is completely secure. You should protect your device and access details and contact us if you suspect unauthorised use.

11. Children and minors

Users should be at least 18 years old or otherwise access the Platform only with appropriate parental or guardian supervision where permitted by applicable law.

The Platform is intended for eligible users and is not directed to children.

If a child or minor accesses the Platform, a parent or guardian should supervise that use. If we become aware that personal data of a child has been collected without appropriate consent or legal basis, we will take appropriate steps to delete or restrict the data, unless we are legally required to retain it.

A parent or guardian may contact us using the details below.

12. Your rights

Subject to applicable law, you may have the right to:

be informed about how your personal data is used;
request access to your personal data;
request correction of inaccurate or outdated personal data;
request deletion of personal data in appropriate circumstances;
object to certain processing;
request restriction of processing in appropriate circumstances;
withdraw consent where processing is based on consent;
request portability where applicable;
lodge a complaint with the Office of the Data Protection Commissioner in Kenya.

To exercise your rights, contact us using the details below. We may need to verify your identity before responding.

13. Complaints

Please contact us first if you have a privacy concern so we can try to resolve it.

You may also lodge a complaint with the Office of the Data Protection Commissioner in Kenya.

14. Third-party links and platforms

The Platform may contain links to third-party websites, platforms, app stores, device services or content delivery services.

We are not responsible for the privacy practices of third parties that we do not control. You should review their privacy notices before using those services.

15. Changes to this Privacy Policy

We may update this Privacy Policy from time to time.

If we make material changes, we will take reasonable steps to notify users, such as by posting the updated Privacy Policy through the Platform or another appropriate channel.

The updated Privacy Policy will apply from the effective date shown above.