Privacy Policy

Last updated: [DATE — fill in before publishing]

Mid Eleven ("Mideleven," "we," "us," or "our") operates mideleven.com, a job marketplace connecting job seekers and employers in Kenya. This Privacy Policy explains what personal data we collect, how we use it, and the rights you have over it under the Data Protection Act, No. 24 of 2019 of Kenya (the "DPA") and its accompanying regulations.

By using Mideleven, you agree to the collection and use of information as described in this policy. If you do not agree, please do not use the platform.

1. Who We Are

Mid Eleven is the data controller responsible for your personal data collected through this platform.

Contact: [midelevenjm@gmail.com]

2. What We Collect

We collect the following categories of personal data:

  • Account information: name, email address, phone number, password (stored securely, never in plain text).
  • Job seeker data: resume/CV files, work experience, education history, skills, and any information you add to your profile.
  • Employer/company data: company name, description, job postings, and related business information.
  • Payment data: M-Pesa transaction references for candidate micro-payments and employer billing. We do not store your M-Pesa PIN or full payment credentials — these are handled directly by Safaricom/M-Pesa's payment infrastructure.
  • Usage data: pages visited, jobs viewed or applied to, device and browser information, and log data collected automatically when you use the platform.

3. Why We Process Your Data

Under the DPA, we only process personal data where we have a lawful basis to do so. We rely on the following bases:

  • Contract: to create your account, match you with jobs or candidates, and operate the core marketplace functionality you've signed up for.
  • Consent: for optional features, such as marketing communications, which you can withdraw at any time.
  • Legal obligation: to comply with applicable Kenyan law, including tax and financial record-keeping requirements related to payments processed on the platform.
  • Legitimate interest: to keep the platform secure, prevent fraud and scam job postings, and improve our services.

4. How We Use Your Data

  • To create and manage your account.
  • To match job seekers with relevant job listings and help employers find suitable candidates.
  • To process payments, including M-Pesa transactions for candidate micro-payments and employer job-posting fees.
  • To communicate with you about your account or activity on the platform.
  • To detect and prevent fraud, including fake job listings and scam recruiters.
  • To improve and maintain the platform.

5. Who We Share Data With

We do not sell your personal data. We share data only in the following circumstances:

  • Between job seekers and employers: when you apply to a job, your profile and resume are shared with the employer who posted it. When an employer posts a job, their company information is visible to job seekers.
  • Payment processors: M-Pesa/Safaricom, to process transactions.
  • Service providers: hosting, database, and infrastructure providers who process data on our behalf under contractual confidentiality obligations.
  • Legal or regulatory authorities: where required by Kenyan law, including the Office of the Data Protection Commissioner.

6. Data Storage and Security

We take reasonable technical and organisational measures to protect your data against unauthorised access, loss, or misuse, consistent with the security safeguard obligations under the DPA. This includes secure password storage, encrypted connections, and access controls limiting who at Mideleven can view your data. No system is perfectly secure, and we cannot guarantee absolute security.

We retain personal data only for as long as necessary to fulfil the purposes described in this policy, or as required by law, after which it is deleted or anonymised.

7. Your Rights Under the Data Protection Act

As a data subject under the DPA, you have the right to:

  • Be informed of how your personal data is used.
  • Access and obtain a copy of your personal data.
  • Request correction of inaccurate or incomplete data.
  • Request deletion of your personal data, subject to legal exceptions.
  • Object to or restrict certain processing of your data.
  • Receive your data in a structured, commonly used format (data portability).
  • Withdraw consent at any time, where processing is based on consent.

To exercise any of these rights, contact us at [support email]. We will respond within a reasonable time as required by the DPA. If you believe we have not handled your data lawfully, you also have the right to lodge a complaint with the Office of the Data Protection Commissioner, Kenya.

8. Cross-Border Data Transfers

Some of our infrastructure providers may store or process data outside Kenya. Where this occurs, we take steps to ensure appropriate safeguards are in place, consistent with the DPA's requirements on transferring personal data outside Kenya.

9. Children's Privacy

Mideleven is intended for users who are at least 18 years old. We do not knowingly collect personal data from minors. If you believe a minor has provided us with personal data, please contact us so we can remove it.

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will post the updated version on this page with a revised "Last updated" date. Continued use of Mideleven after changes take effect constitutes acceptance of the updated policy.

11. Contact Us

If you have questions about this Privacy Policy or how your data is handled, contact us at [midelevenjm@gmail.com].