Legal

Privacy Policy

Last updated 26 July 2026

This Privacy Policy explains how Smartwin Ltd. (“Betluku”, “we”, “us”) collects, uses, stores, and protects your personal information when you use the Betluku prediction market platform. By using Betluku, you consent to the practices described in this policy.

1. Information we collect

  • Account information: phone number, password hash, and optional profile details.
  • Identity information: Kenyan national ID or passport details submitted for KYC verification.
  • Transaction information: M-Pesa deposits, withdrawals, wallet balances, trades, and positions.
  • Device and usage information: IP address, browser type, device identifiers, and platform activity logs.
  • Communications: support tickets, emails, and other correspondence with our team.

2. How we use your information

  • To create and manage your account and wallet.
  • To process deposits, withdrawals, and trade settlements.
  • To comply with BCLB and KRA regulatory requirements, including tax reporting.
  • To detect and prevent fraud, money laundering, and other unlawful activity.
  • To improve the platform and respond to your support requests.

3. How we share your information

We do not sell your personal data. We share information only with: (a) Safaricom M-Pesa for payment processing; (b) our KYC/identity verification providers; (c) regulators such as the BCLB and KRA when legally required; and (d) service providers who help us host, secure, and operate the platform under strict confidentiality obligations.

4. Data security

We use industry-standard technical and organisational measures to protect your data, including encryption in transit, access controls, and regular security reviews. No system is completely secure, and we cannot guarantee absolute security.

5. Data retention

We keep your personal data for as long as your account is active and for a reasonable period thereafter to comply with legal, tax, and regulatory obligations. Transaction records are retained for at least seven years in accordance with Kenyan law.

6. Your rights

  • Access the personal data we hold about you.
  • Request correction of inaccurate or incomplete data.
  • Request deletion of your data, subject to legal retention requirements.
  • Object to certain processing activities.

7. Cookies and analytics

Betluku uses essential cookies to keep you signed in and secure. We may also use analytics cookies to understand how users interact with the platform. You can control non-essential cookies through your browser settings.

8. Contact us

For privacy questions or to exercise your rights, contact us at privacy@betluku.co.ke or write to Smartwin Ltd., Nairobi, Kenya.