Privacy policy

Who we are

This policy describes the processing of personal data by Finlay Real Estate (“we”, “us”, “our”) in connection with our real estate marketplace website, enquiry tools, and related communications. Our registered address and primary contact details are published on the Contact page.

For data-protection purposes, the controller is Finlay Real Estate. Where we process data on behalf of listing partners (for example, forwarding your enquiry to an agent), we act as a processor or joint controller only to the extent described in section 5 below.

1. What this policy covers

This policy applies when you visit our website, submit a property enquiry, create or manage an account, list a property, correspond with us, or otherwise interact with our services. It does not replace any separate agreement you have with us (for example, agent or developer listing terms).

Our Terms and conditions apply to use of the platform generally.

2. Information we collect

We may collect the following categories of information, depending on how you use the site:

• Contact and identity data: name, email address, phone number, and similar details you provide in forms, enquiries, or account registration.
• Enquiry and transaction-related data: messages you send about a listing, viewing preferences, and follow-up notes that you or our team add in connected workflows.
• Account and profile data: login identifiers, role (for example customer, agent, or delegate), preferences, and settings associated with your account.
• Listing and marketing content: property descriptions, images, location fields, pricing, and other materials you upload as a lister or partner.
• Technical and usage data: IP address, browser type, device identifiers, approximate location derived from IP, pages viewed, referring URLs, and timestamps. We may use cookies and similar technologies as described in section 3.
• Communications: records of emails, calls logged in our systems, and support tickets you exchange with us.

3. Cookies and similar technologies

We use cookies and similar tools where necessary to run the site (for example, session security, load balancing, or remembering your preferences), and, where enabled, to understand aggregate traffic and improve the experience. You can control many cookies through your browser settings; blocking essential cookies may limit some features.

4. How we use your information

We use personal data for purposes including:

• Operating the marketplace: displaying listings, processing enquiries, routing messages to listing owners or agents, and authenticating users.
• Communicating with you: responding to questions, sending service-related notices, and (where you have opted in or the law allows) marketing about properties or services.
• Safety and integrity: detecting abuse, fraud, or security incidents; enforcing our terms; and complying with legal obligations.
• Analytics and improvement: understanding how the site is used in aggregate, fixing errors, and developing features.
• Legal and compliance: record-keeping, dispute resolution, and cooperation with regulators or law enforcement when required.

5. Listings, agents, developers, and delegates

When you enquire about a property, we typically share your contact details and message with the party responsible for that listing (and, where applicable, our internal staff) so they can respond. Those parties may process your data under their own privacy notices for follow-up beyond our platform.

Agents, developers, and authorised delegates who publish listings are responsible for the accuracy of listing content and for any additional personal data they collect from leads. Their use of our tools is also governed by applicable listing terms.

6. Legal bases (Kenya)

Where the Kenya Data Protection Act, 2019 applies, we rely on appropriate lawful bases such as: your consent (for example optional marketing or non-essential cookies where required); performance of a contract or steps prior to a contract; compliance with legal obligations; and legitimate interests that are not overridden by your rights (for example securing the site, preventing fraud, and improving our services), in each case as relevant to the specific processing.

7. Sharing with third parties

We may share data with:

• Service providers who host our infrastructure, send email or SMS, provide analytics, or support customer service, under contracts that require protection of personal data.
• Professional advisers (lawyers, auditors) where necessary.
• Authorities or other parties when required by law or to protect rights, safety, and property.
• A successor entity in connection with a merger, acquisition, or sale of assets, subject to appropriate safeguards.

We do not sell your personal information in the conventional sense of selling lists of individuals to unrelated marketers.

8. International transfers

Some of our suppliers may process data outside Kenya. Where we transfer personal data across borders, we take steps consistent with applicable law (for example appropriate contractual safeguards or adequacy decisions) to protect your information.

9. Retention

We keep personal data only as long as needed for the purposes above, including legal, tax, and dispute-resolution requirements. Enquiry records, account data, and listing materials may be retained for different periods depending on context; we delete or anonymise information when it is no longer required.

10. Security

We implement technical and organisational measures designed to protect personal data against unauthorised access, loss, or alteration. No online service is completely secure; please use strong passwords and protect your login credentials.

11. Your rights

Depending on applicable law, you may have rights to access, correct, or delete your personal data; object to or restrict certain processing; withdraw consent where processing is consent-based; and lodge a complaint with a supervisory authority.

In Kenya, you may contact the Office of the Data Protection Commissioner (ODPC) regarding complaints. We encourage you to contact us first so we can try to resolve your concern.

To exercise rights or ask questions about this policy, email us at customercare@finlay.co.ke or use the contact details on our website.

12. Children

Our services are directed at adults. We do not knowingly collect personal data from children without appropriate parental authority. If you believe a child has provided us data, please contact us and we will take steps to delete it where appropriate.

13. Changes

We may update this policy from time to time. The “Last updated” date will change when we do. Material changes may be communicated by notice on the site or by email where appropriate.

14. Contact

Finlay Real Estate — Pili Trade Center, Mombasa Rd, Nairobi, Kenya. Email: customercare@finlay.co.ke. Website: finlay.co.ke.

Last updated: 1 April 2026.