PickSpot Network Limited

Imprint, Terms & Conditions,
and Privacy Policy

Imprint

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Company Name: PickSpot Network Limited (the “Company”)
Registered Office: Building: Yare Towers Street/Road: Yusuf Hajj Avenue City/Town: Nairobi District: Starehe, County: Nairobi Station: North of Nairobi Postal Code: 00100 P.O. Box: 38904‍

Contact: Email – contact@pickspot.net;

Responsible Entity: PickSpot Network Limited is the responsible legal entity for the PickSpot Network platform and website. The Company’s directors or authorized representatives can be reached at the above contact for any legal or compliance matters.

Legal Disclaimer: All information provided by PickSpot Network Limited (on this website and related materials) is for general informational purposes only. While we strive for accuracy and timeliness, we do not guarantee that content is complete, up-to-date, or free of errors. Nothing on our platform constitutes financial or investment advice. PickSpot Network Limited is not liable for the content of external links—the operators of linked external sites are solely responsible for their content. Users are advised to exercise caution and do their own research, when relying on any information provided. Any reliance on information provided is at the user’s own risk.

Intellectual Property: Unless otherwise stated, all logos, brand names, images, and content on the PickSpot website and platform are the intellectual property of PickSpot Network Limited. Unauthorized use, reproduction, or distribution of this material is prohibited.

Jurisdiction: This imprint is provided in compliance with applicable laws and industry best practices. The Company operates under the laws of Kenya. Any official correspondence (e.g., legal notices) should be sent to the registered office address above.

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Terms & Conditions

Last Updated: June 16, 2025

These Terms and Conditions (“Terms”) govern your access to and use of the services provided by PickSpot Network Limited, including our automated smart locker network, and any related features or services (collectively, the “Platform”). By accessing or using the Platform – including creating a PickSpot digital address, using PickSpot lockers, or otherwise participating in the PickSpot Network – you (“User”) agree to be bound by these Terms. If you do not agree, you must not use the Platform or participate in the network.

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1. Definitions

For clarity in these Terms, the following definitions apply:

PickSpot Network / Platform: The network of automated parcel lockers and related software applications (web and mobile) operated by the Company for parcel delivery and pickup services. This includes all associated online services and features provided by PickSpot.

Services: The services provided by PickSpot Network Limited, including the provision and maintenance of smart locker hardware and software for parcel delivery and pickup, loyalty and reward programs (such as Spot Points), and any related support or ancillary services.

User: Any person or entity using the Platform or Services. This includes, without limitation, customers receiving or sending parcels via PickSpot lockers, merchants using PickSpot to dispatch deliveries, delivery or courier partners accessing lockers for deliveries, and visitors to our website or app. All such Users act as independent parties; nothing in these Terms creates any joint venture, partnership, agency, or employment relationship between Users and the Company (see Section 13 “No Partnership”).

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2. Platform Services

PickSpot Network Limited provides an innovative last-mile delivery solution through a distributed locker network and supporting digital platforms. Key aspects of our Services include:

Smart Locker Access: A network of shared, automated parcel lockers deployed in public and commercial areas, serving as secure points for deliveries and pickups. All locker infrastructure is deployed and maintained by PickSpot or its authorized operators as part of the network (individual users are not agents operating lockers). Users can send, store, and collect parcels through these lockers by following the instructions provided. Users must not use lockers for prohibited or dangerous items and must adhere to any usage guidelines (e.g., package size limits, storage time limits). The Company is responsible for locker upkeep and may perform maintenance or inspections as needed. Users should not tamper with or damage the lockers.

Digital Addresses (PickSpot Handles): Unique, human-readable digital addresses (for example, username@pickspot.africa or world ) that serve as delivery identifiers for Users. A PickSpot Handle links to the User’s designated locker or pickup point in our network, allowing Users to receive parcels without revealing a physical address. It provides a persistent digital delivery address mapped to the User’s preferred lockerlocation, enhancing privacy and convenience. These digital addresses are secured through the Platform’s systems so that only the rightful owner can access deliveries associated with the address.

PickSend (Merchant Portal): An online self-service portal for merchants and senders to create delivery orders directly to PickSpot lockers. PickSend enables businesses (including informal or small-scale merchants) to dispatch parcels to customers by generating parcel labels and secure pickup codes without needing complex integrations. Merchants can manage shipments, track deliveries, and route parcels into the PickSpot Network using this portal.

Deliver2Locker (Universal API): A developer API and integration layer that allows third-party e-commerce, logistics, or delivery applications to route parcels into PickSpot lockers. Deliver2Locker functions like a “Stripe for delivery,” providing standardized endpoints so external platforms (e.g., ride-hailing or e-commerce apps) can offer delivery-to-locker options to their users. This integration expands PickSpot’s reach by letting partners seamlessly utilize the locker network

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Spot Points (Digital Reward Credits): Spot Points are non-transferable digital points earned through verified user activity on the Platform—such as successful referrals of new users, creating and using a PickSpot digital address, participating in locker rating or voting features, and completing parcel pickups. These points form the foundation of PickSpot’s user loyalty and contribution program. Spot Points are not a currency or financial instrument and hold no intrinsic monetary value. However, the Company may periodically offer promotions or rewards based on the Spot Points you accumulate (see Section 5 for details on loyalty rewards). Spot Points cannot be traded or exchanged outside the Platform and are intended solely to encourage and recognize user engagement. Points may expire or reset after certain periods or reward cycles, as determined by the Company’s program rules

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All services are provided subject to these Terms. Users must follow any additional guidelines or instructions provided in-app or on-site when using specific services. The Company may introduce new services or modify existing services as the Platform evolves.

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3. User Eligibility and Account

Eligibility: To use the Platform or participate in the PickSpot Network (including creating a PickSpot Handle, using a PickSpot locker, etc.), you must be at least 18 years old (or the age of majority in your jurisdiction) and have the legal capacity to enter into contracts. By using the Platform, you represent that you meet these eligibility requirements. The Company reserves the right to refuse access to any person or entity at its discretion (for example, if you are in a country or region under economic sanctions or where ourServices are prohibited by law).

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Account Registration: Certain features of the Platform (such as managing deliveries, accessing the PickSend merchant portal, or participating in loyalty reward programs) require creating a user account with PickSpot. You agree to provide accurate and complete information when registering, and to keep your account information updated. This may include undergoing Know-Your-Customer (“KYC”) identity verification procedures (see Section 9) if requested. You are responsible for maintaining the confidentiality of your login credentials and for all activities that occur under your account. If you suspect any unauthorized access to or use of your account, you must notify us immediately.

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Digital Wallet and Address Security: When you create a PickSpot digital address, the Platform also provides you with a secure, non-custodial digital wallet within the app. This wallet is used to manage your Spot Points and to securely store the credentials (such as security keys or passcodes) associated with your digital address and parcel deliveries. You are solely responsible for safeguarding your wallet’s access credentials (e.g., private keys, recovery phrases, PINs). The Company will never ask you for these secret credentials; if anyone claiming to be from PickSpot requests them, it is fraudulent. Because the wallet is non-custodial, the Company does not have access to your private keys or the contents of your wallet, and we cannot recover your Spot Points or access your digital address if you lose your credentials. Any actions or transactions confirmed through your wallet (such as authorizing a delivery or using Spot Points in a promotion) are irreversible in most cases. Exercise extreme care in handling your wallet and credentials to prevent loss or unauthorized use.

4. User Obligations and Code of Conduct

By using PickSpot’s Platform or Services, you agree to the following obligations and rules of conduct:

Lawful Use: You agree to use the lockers, Platform, and Services only for lawful purposes and in compliance with all applicable laws and regulations (including postal/shipping regulations and any other relevant laws in your jurisdiction). Prohibited activities includes, but is not limited to: using the Platform to send or store illegal, hazardous, or contraband items; engaging in fraud, money laundering, or other criminal activity; infringing on others’ intellectual property or privacy rights; attempting to hack, disrupt, or gain unauthorized access to any part of the Platform or its underlying systems; and any other activity that violates these Terms or applicable law.

Abiding by Policies: You will comply with all rules, guidelines, and instructions provided by PickSpot in relation to the Services. This includes following all locker usage instructions (such as respecting package size and weight limits and observing parcel pickup deadlines), adhering to posted operating hours or procedures, and complying with any community guidelines. You also agree to follow any additional program-specific terms that may apply to certain services or promotions (for example, if separate terms are provided for a particular promotional campaign). These Terms, together with any such additional terms, collectively govern your use of the Platform. In the event of a direct conflict between these general Terms and specific program terms, the specificterms will govern for that program or feature.

Payment of Fees: You agree to pay any applicable fees or charges for using the Platform or Services, as indicated at the time of each transaction or as otherwise communicated by the Company. For example, if you use a locker to receive a package, you must pay any delivery, pickup, or storage fees that apply (as posted or communicated during the transaction process). If you are a merchant or sender using the Platform to deliver parcels (through PickSend or Deliver2Locker), you are responsible for any service fees or postage/shipping charges associated with those deliveries. If you make payments through a third-party payment provider (such as a mobile money service or credit card processor), you are responsible for any transaction fees that the provider may charge (e.g., mobile money fees or currency conversion fees). Fees are typically quoted in Kenyan Shillings (KES) or another specified currency (such as USD), and must be paid in the currency and manner stated. All payments to the Company are non-refundable, except where required by law or expressly stated otherwise by the Company

Taxes: You are responsible for determining and fulfilling your own tax obligations arising from your activities on the Platform. Any payments, rewards, or benefits you obtain through PickSpot (for example, referral bonuses or other promotional rewards) may be subject to taxes under the laws of your jurisdiction. PickSpot Network Limited does not calculate, withhold, or pay taxes on your behalf unless we are legally required to do so. We may provide you with records of your transactions or rewards upon request to assist with your tax reporting, but you alone are responsible for reporting and paying any applicable taxes. If the Company is required by law to withhold taxes or report your activities to tax authorities, we will comply with those obligations; otherwise, all tax compliance remains your responsibility

Prohibited Behavior: You shall not engage in any behavior that harms the Platform, other Users, or the Company’s operations. This includes but is not limited to: damaging, tampering with, or vandalizing any PickSpot locker or equipment; attempting to circumvent or disable any security or technical measures on the Platform; misrepresenting your identity or affiliation (for example, impersonating any person or entity); spamming, phishing, or attempting to defraud other users; introducing any viruses, malware, or harmful code into the Platform; or using any automated means (such as bots or scrapers) to extract data from the Platform without authorization. The Company reserves the right to suspend or terminate your access to the Platform for any behavior that it deems abusive, fraudulent, or in violation of these Terms (see Section 10 on Suspension & Termination).

Cooperation with Investigations: You agree to cooperate with the Company and law enforcement authorities in any investigation of misuse or suspected illegal activity related to your use of the Platform. We reserve the right to report any activities that we reasonably suspect to be unlawful to the appropriate authorities and to provide them withany information necessary to conduct their investigation.
Merchants: If you use the Platform as a merchant (for example, via the PickSend portal or API to send packages to customers), you are responsible for the content and legality of the shipments you send. You must ensure that each parcel is properly packaged, labeled, and contains no prohibited materials. You are also responsible for any information you input (such as recipient details and parcel contents) and you must comply with all shipping laws and regulations (including any required declarations or customs documentation for the parcel). Merchants are expected to adhere to any additional guidelines provided by PickSpot for senders. Any misuse of the Platform by a merchant — such as sending illicit goods, providing false information, or circumventing delivery procedures — may result in suspension or termination of your access, and potential legal action

Delivery Partners: If you are a delivery agent or logistics partner authorized to handle parcel drop-offs or pickups for PickSpot lockers, you must use the Platform strictly according to our policies and instructions. This means you should only access lockers to deposit or retrieve parcels that you are authorized to handle, follow the procedures for locker access (e.g., using valid access codes and locking procedures), and maintain the security and privacy of user parcels. Delivery partners must have any required credentials or agreements with the Company or with an affiliated logistics provider. Any unauthorized access to lockers, mishandling of parcels, or other misconduct by a delivery partner is a serious violation of these Terms and may result in immediate termination of access and possible legal consequences.

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5. Loyalty and Rewards Program

PickSpot may offer a loyalty and rewards program to encourage and reward user engagement on the Platform. The current loyalty program centers around Spot Points and related promotions. The following terms apply to participation in these programs:

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‍Spot Points – Earning and Nature: Spot Points are digital reward points that Users can earn by actively participating in the PickSpot Network. Points are earned through actions such as creating a PickSpot digital address, referring new users who join the Platform, voting or giving feedback on locker performance, picking up parcels on time, or other in-app activities that the Company may designate. Spot Points are provided as a gratitude and engagement reward; they are not cash or a financial asset. Spot Points have no cash value, are not transferable to other users, and cannot be exchanged outside of the Platform. Earning Spot Points is simply a way for the Company to track and acknowledge user contributions and activity
Reward Cycles and Expiration of Points: Spot Points may be tallied in time-based cycles (for example, monthly, quarterly, or another period set by the Company) to determine user eligibility for rewards. At the end of a cycle or promotional period, the Spot Points you accumulated during that period may be used to assess any rewards you qualify for. After rewards (if any) are distributed for that cycle, the Company reserves the right to reset all Users’ Spot Points to zero to begin a new cycle. Alternatively, the Company may let points carry over or expire on a rolling basis, depending on how the program evolves. We will inform Users of the rules for any given period—for instance, whether points will reset at a certain time or if they expire after a set duration of inactivity. It is your responsibility to stay informed of these rules, which we will communicate via the Platform or official announcements.
Promotional Rewards and Airdrops: Based on the Spot Points you earn and other participation criteria, the Company may periodically provide promotional rewards to Users. These rewards (sometimes called “airdrops” in industry parlance) are free bonuses given as a perk for being an active user. Rewards can take various forms, at the Company’s discretion. For example, PickSpot might grant bonus Spot Points, discount codes for delivery services, free locker usage credits, merchandise, or early access to new features. The selection and value of any reward will be determined by the Company and may depend on factors such as the number of Spot Points you earned in the cycle, your level of activity, or random draws among top contributors. Rewards are not guaranteed – participation in the Platform or accumulation of Spot Points does not entitle you to any specific reward. The Company will announce the criteria and terms of each promotional reward event (for instance, a promotion may state that the top 100 users in Spot Points for the month will each receive a certain voucher). All rewards are given on a goodwill basis to thank users; they are promotional and should not be viewed as earnings or rights.
No Cash Value & No Guarantee: Spot Points and any rewards provided are not redeemable for cash and are not intended as a promise of future benefits. The loyalty program is offered at the Company’s discretion and could be modified or terminated at any time. While we may provide opportunities to use Spot Points (such as redeeming them for a perk) or distribute occasional rewards, the existence of the program or any past distributions is not a guarantee of ongoing or future rewards. Users should not rely on Spot Points as they would on money or expect any set return from accumulating points. The Company, in its sole discretion, can decide to change how Spot Points work, change what activities earn points, adjust point balances (for example, if points were awarded in error), or discontinue the program entirely. We will notify users of major changes to the loyalty program, but we reserve the right to make such changes according to business needs or legal requirements.
Integrity of the Program: We expect Users to participate in the loyalty program fairly. Any attempt to manipulate or abuse the Spot Points system—such as creating fake transactions, using multiple accounts to earn points artificially, or any other deceptive behavior—constitutes a violation of these Terms. The Company reserves the right to investigate suspected abuse and to void or adjust Spot Points, deny rewards, orsuspend/terminate accounts if we determine that Spot Points were earned through fraud or in bad faith. By participating, you agree that the Company’s determination of any fraudulent activity will be final and binding. If you believe your points or rewards were revoked in error, you may contact us to dispute the decision, but the Company’s final decision will prevail

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6. User Acknowledgements and Assumption of Risk

While using the PickSpot Platform, you should be aware of and accept the following risks and responsibilities:

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‍Account Security and Loss of Access: Because PickSpot uses a non-custodial model for certain features (like your digital wallet for Spot Points and delivery credentials), losing access to your account credentials can have permanent consequences. If you lose your password and other recovery information for your account or wallet, or if your device with the PickSpot app is lost or stolen without any backup of your credentials, you could lose access to your account and any Spot Points or benefits stored in it. The Company does not have the ability to retrieve or reset private keys or secret recovery phrases for your digital wallet. Additionally, if an unauthorized person gains access to your account (for example, by obtaining your login information or hacking your device), they may be able to misuse your digital address or redeem your Spot Points, and transactions or changes they make might be irreversible. You assume full responsibility for keeping your account credentials, recovery phrases, and devices secure. We strongly recommend using strong passwords, enabling any offered security features (like two-factor authentication), and safely backing up any recovery information provided to you.
Service Availability and Technical Risks: You acknowledge that the Platform may experience downtime, delays, or errors due to a variety of factors, some of which are beyond the Company’s control. This includes, for example, unanticipated technical problems, hardware failures, software bugs, power outages, interruptions in internet connectivity or telecommunications, or issues with third-party service providers (such as cloud hosting, payment gateways, or SMS/email delivery services). While PickSpot will take reasonable measures to ensure reliable service and will attempt to inform Users of any significant outages or maintenance periods, we cannot guarantee that the Platform will be available 100% of the time or that it will function error-free. By using the Platform, you understand and accept that occasional disruptions or delays may occur. The Company will not be liable for any losses or inconveniences resulting from such technical issues beyond the remedies provided in these Terms.
No Guarantee of Business Success or Continuity: The PickSpot Platform is a growing service, and its future availability and success depend on a variety of factors including user adoption, operational performance, and external conditions. You acknowledge that the Platform could undergo significant changes over time, and in a worst-case scenario,the service or some of its features could be scaled back or discontinued. The Company makes no guarantee that the Platform will continue indefinitely or that it will meet all users’ expectations. For example, if usage is lower than expected, if regulations impede operations, or if business circumstances change, the Company may decide to discontinue certain features or cease operations. By using PickSpot, you accept the risk that the time or effort you invest (including any Spot Points accumulated) is at your own discretion and that the Company is not responsible for any loss of anticipated benefits or opportunities due to changes in the Platform’s scope or existence. If the Platform is ever terminated, we will endeavor to provide advance notice to users and address any outstanding obligations, but any unredeemed loyalty points or pending rewards may be forfeited without compensation.

(The above list is not exhaustive; please understand there may be other risks associated with blockchain projects and token economies that you should research and understand before participating.)

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7. Disclaimers

No Warranties: The Platform and all services are provided on an “as is” and “as available” basis, without any warranties of any kind, either express or implied. To the fullest extent permitted by law, the Company expressly disclaims all warranties and representations, express, implied, or statutory, including (but not limited to) any implied warranties of merchantability, fitness for a particular purpose, title, non-infringement, and any warranties that might arise from dealing or usage of trade. We do not warrant that the Platform will be uninterrupted, secure, or free of errors, nor do we guarantee that any defects or issues will be corrected. We make no promises that any content or information provided through the Platform is accurate, complete, or current. You acknowledge that use of the Platform is at your own risk. No advice or information (whether oral or written) obtained from the Company or through the Platform shall create any warranty not expressly stated in these Terms.

No Investment Advice: Any information provided by PickSpot (for example, in articles, guides, blog posts, or support communications) is intended for general informational purposes only and does not constitute professional advice. This includes, without limitation, financial, investment, legal, or tax advice. You should not make decisions based solely on information you obtain from our Platform without independently verifying the information and, if necessary, consulting with a qualified professional advisor. The Company is not responsible for actions you take based on information on the Platform, and you agree that you use such information at your own risk

Third-Party Content and Services: The Platform may integrate with, or contain links to, third-party services and content that are not owned or controlled by the Company. For example, we may use third-party logistics providers or courier services in connection with Deliver2Locker integrations, third-party payment processors to handle transactions, mapping or location services to display locker locations, or analytics providers to understand Platform usage. The Platform might also include content or information provided by third parties (such as user reviews, third-party advertisements, or socialmedia feeds). We do not endorse or assume any responsibility for third-party services or content. If you access or use any third-party services (whether through our Platform or via an external link), you do so at your own risk and subject to whatever terms and privacy policies those third parties impose. PickSpot Network Limited is not liable for any acts or omissions of third parties, nor for the accuracy, reliability, or legality of any third-party content. Any reference on our Platform to a third-party product, service, or website is for your convenience and does not imply an endorsement or recommendation by the Company.

Forward-Looking Statements: From time to time, the Company or its representatives may make forward-looking statements or projections about our future plans, goals, or performance. Any such statements (e.g., estimates of how the network may grow, planned features or expansions, or anticipated user benefits) are inherently subject to uncertainties and change. Actual outcomes and results may differ materially from what is expressed or implied in any forward-looking statement due to various risks and factors beyond the Company’s control (such as market conditions, operational challenges, regulatory changes, etc.). We undertake no obligation to update or revise any forward-looking statements, even if there is new information or events that affect what was projected. Users are cautioned not to place undue reliance on any forward-looking information obtained from the Platform or the Company

Jurisdiction-Specific Limitations: Some jurisdictions do not allow the exclusion of certain warranties or conditions or do not allow limitations on how long an implied warranty lasts. To the extent that these laws apply to your use of the Platform, some of the disclaimers above may not apply to you in full. However, in such cases, the disclaimers and limitations will apply to the maximum extent permitted by the laws of your jurisdiction

8. Limitation of Liability

To the fullest extent permitted by law, PickSpot Network Limited and its affiliates, officers, directors, employees, and agents shall not be liable for any: indirect, incidental, special, consequential, exemplary, or punitive damages; or any loss of profits, revenues, data, goodwill, or other intangible losses, arising out of or in connection with your access to or use of (or inability to use) the Platform or Services, even if we have been advised of the possibility of such damages.

In particular, without limiting the generality of the above, the Company and related parties are not liable for:

The cost of procurement of substitute goods or services arising from any issue with the Platform.

Any reliance that you place on the accuracy or usefulness of information or content on the Platform (for example, using a PickSpot digital address or accumulating Spot Pointsdoes not guarantee any particular outcome or benefit).

Any damage, loss, or injury resulting from your misuse of the Platform, or from any error, omission, interruption, defect, delay in operation or transmission, computer virus, connectivity failure, or system outage related to the Platform, whether or not stemming from factors outside our control (including, without limitation, any Force Majeure events described in Section 10).

Actions, content, or information of any third parties (including other Users, couriers or merchants using the Platform, third-party service providers, or external websites linked to/from our Platform).

Any unauthorized access to or use of the Platform or to your account, or any alteration, theft, destruction or loss of your data, including personal information or Spot Points, that occurs without our fault.

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The aggregate liability of PickSpot Network Limited for any claims arising out of or relating to these Terms or the Platform is limited to the greater of: (a) the total amount you have paid to us (if any) for use of the Services in the six (6) months immediately preceding the event giving rise to the claim; or (b) USD $100 (or equivalent in local currency). This limitation applies to the maximum extent permitted by applicable law and applies regardless of the legal theory on which the claim is based (contract, tort, negligence, strict liability, etc.).

Consumer Rights Notice: Nothing in these Terms is intended to exclude or limit any guarantee, warranty, right, or remedy that cannot be lawfully excluded or limited under applicable consumer protection laws. If you are entitled to the benefit of statutory rights or remedies that conflict with the provisions of these Terms, then to the extent of such conflict, your statutory rights and remedies will not be affected, and the specific inconsistent term herein shall be deemed modified to conform to applicable law. All other terms will remain in full force and effect. You agree that if you are dissatisfied with any aspect of the Platform or these Terms, your sole and exclusive remedy (apart from any remedies that cannot be excluded by law) is to discontinue use of the Platform.

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9. Know-Your-Customer (KYC) and Compliance

Given the nature of our Services and to maintain the integrity and security of the PickSpot Network, we may require Users to undergo identity verification and other compliance checks in certain circumstances:

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KYC Procedure: You may be asked to complete a KYC verification process when registering an account or before accessing specific services or transaction levels on the Platform. This process can involve providing personal identification details and documentation. For example, the Company might request your full name, date of birth, government-issued identification document (such as a national ID or passport), proof ofaddress (like a utility bill or bank statement), a photograph or “selfie” for identity verification, and any other information deemed necessary to verify your identity and comply with legal requirements (e.g., anti-money laundering and counter-terrorism financing regulations). By using the Platform, you agree to provide accurate and truthful information for KYC purposes and acknowledge that access to certain services may be withheld or restricted until your identity is verified to our satisfaction. If you do not complete KYC when required, or if your provided information is found to be inaccurate or raises legal concerns, the Company may suspend or terminate your access to some or all Services. Any personal data obtained through the KYC process will be handled in accordance with our Privacy Policy (see the Privacy Policy below), including potentially screening your information against governmental sanctions lists or watchlists as required by law.

Ongoing Compliance: Even after you have passed an initial KYC check, the Company may require periodic updates to your information or additional verification steps, especially if your usage of the Platform changes (for instance, higher transaction volumes) or if required by law or changes in your profile. We may also monitor transactions and activities on the Platform for signs of suspicious behavior. If any unusual activity is detected, we may request clarification or additional documentation from you, and we reserve the right to freeze account activity if necessary until the matter is resolved. We also comply with any legal obligations to report certain transactions or activities to relevant authorities, and by agreeing to these Terms, you acknowledge that we will fulfill such obligations as needed. Our compliance measures are intended to protect both the Platform’s integrity and our user community from misuse

Sanctions and Restricted Parties: You represent and warrant that you are not subject to any sanctions or on any list of prohibited or restricted parties (such as maintained by the United Nations, United States, European Union, or Kenyan authorities). If it becomes known that you are such a party or are using the Platform on behalf of a sanctioned entity, we may be required to terminate all relations with you immediately. Additionally, we do not permit usage of the Platform in certain restricted regions. It is your responsibility not to use the Platform if any applicable laws prohibit it in your location. We reserve the right to refuse or terminate service to any user if required by law or if the user’s presence could expose the Company to legal liability or sanctions risk.

(Note: We take compliance seriously to protect our Users and the network. We appreciate your cooperation in these procedures, which ultimately benefit the legitimacy and longevity of the PickSpot Network.)

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10. Suspension, Termination and Force Majeure

Suspension or Termination by Company: PickSpot may suspend, limit, or terminate your access to the Platform (in whole or in part) immediately and without prior notice if, in our reasonable opinion, you have violated these Terms, engaged in unlawful activity, or otherwise acted in a way that could harm the Platform, other users, or the Company. For example, without limitation, we may take such action if we suspect that you have provided false identity information, attempted to interfere with the locker hardware orsoftware, engaged in fraudulent transactions, or violated any applicable laws or regulations. In cases of minor violations or where feasible, we may attempt to notify you and work with you to resolve the issue before taking severe action; however, we are not obligated to provide notice or an opportunity to cure in every case. If your account or access is suspended or terminated, you remain responsible for any obligations incurred before the suspension/termination, and any provisions of these Terms intended to survive termination will continue to apply.

User Termination: You are free to stop using the Platform at any time. If you wish to delete your PickSpot account, you may do so through the account settings (if available) or by contacting us with a request for account deletion. We will process such requests in accordance with our Privacy Policy and applicable law. Note that certain data may be retained even after account deletion if required for legal or compliance purposes (see Privacy Policy, Section 6 on Data Retention). If you cease using the Platform and close your account, these Terms will no longer govern your use (except for sections that are meant to survive, such as provisions on liability, arbitration, and any other continuing rights or obligations).

Force Majeure: PickSpot Network Limited shall not be liable for any delays or failure to perform any obligation under these Terms if the delay or failure results from a Force Majeure event. Force Majeure means any event beyond our reasonable control, including but not limited to: natural disasters (e.g., earthquakes, floods, hurricanes); acts of God; fire or other catastrophic events; war, acts of terrorism, or civil unrest; epidemics, pandemics, or quarantine restrictions; actions or decrees of governmental bodies (such as government orders restricting operations, regulatory changes, or import/export restrictions); national or regional strikes or labor disputes; power grid failures or widespread telecommunications/internet outages; and failures or disruptions of third-party services or networks that are critical to our operations. During a Force Majeure event, the obligations of the Company under these Terms that are affected by the event will be suspended for the duration of that event, and the Company will not be considered in breach of these Terms to the extent such obligations cannot be performed. For example, if a major internet outage or governmental order prevents us from operating normally, some Platform features may be temporarily unavailable or delayed (e.g., if a payment network is down, transactions might not process until service is restored). We will make reasonable efforts to mitigate the impact of the Force Majeure event and to resume full performance as soon as it is practical. If a Force Majeure event continues for an extended period, we will communicate with users about the status of the Services and what steps might be taken (including the possibility of modifications to the Services or, in extreme cases, partial or full termination of certain features). Users agree that the Company will not be liable for any consequences arising from Force Majeure delays or failures, as permitted by law.

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11. Modification of Terms

The technology and regulatory environment in which PickSpot operates is continuously evolving, and our business and services may change over time. As a result, the Company reserves the right to modify or update these Terms & Conditions at any time. If we make material changes to the Terms, we will provide reasonable notice to Users. This may include posting the updated Terms with a new “Last Updated” date on our website and/or notifying you through other communication channels (such as email or an in-app notification). It is your responsibility to review any updated Terms. By continuing to use the Platform after the effective date of updated Terms, you agree to the revised Terms. If you do not agree with any amendment to the Terms, you must stop using the Platform before the updated Terms take effect. In the event of a material change that you do not accept, you may request to terminate your account (if applicable). We will not impose retroactive changes that substantially negatively affect your rights without your consent; changes typically will apply only going forward from the effective date. However, certain modifications may be required to comply with new laws or address urgent business or security needs and could become effective immediately. We encourage you to periodically review the Terms for the latest information on our practices.

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12. Governing Law and Dispute Resolution

These Terms & Conditions are governed by and shall be construed in accordance with the laws of the Republic of Kenya, without regard to its conflict of law principles. However, nothing in this section shall deprive you of any consumer protection rights or other mandatory provisions that apply under the law of your country of residence that cannot be waived by contract. In other words, if you are considered a “consumer” under the laws of your home jurisdiction and those laws provide you certain non-waivable rights or protections, those rights will remain in effect (Kenyan law will not override those mandatory provisions).

Dispute Resolution (Arbitration): In the event of any dispute, claim, or controversy arising out of or relating to these Terms or your use of the Platform that cannot be resolved amicably through negotiation within 30 days of the issue being raised with the other party, the dispute shall be referred to and finally resolved by binding arbitration. The arbitration will be conducted in Kenya, in English, under the rules of a reputable arbitration body in Kenya (for example, the Nairobi Centre for International Arbitration), unless the parties agree to a different arbitral forum. One arbitrator shall preside, unless the parties agree to a panel. The arbitrator’s decision shall be final and binding, and judgment on the award rendered by the arbitrator may be entered in any court of competent jurisdiction.

Class Action Waiver: To the maximum extent permitted by law, you and the Company agree that each may bring claims against the other only in an individual capacity and not as a plaintiff or class member in any purported class, collective, or representative proceeding. This means that, except where prohibited by law, you will not participate in any class action or class-wide arbitration against PickSpot. If this class action waiver is determined to be illegal or unenforceable with respect to a particular claim, then that claim (and only that claim) willproceed in court and not in arbitration, but the remainder of the arbitration agreement shall still apply.

Exceptions and Small Claims: Not withstanding the above arbitration clause, either party has the right to seek relief in a small claims court for disputes or claims within the scope of that court’s jurisdiction (if applicable), and either party may seek injunctive or equitable relief in a court of law for matters involving intellectual property infringement or other matters not readily subject to arbitration.

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If you are a consumer residing in a jurisdiction that does not allow mandatory arbitration of disputes or prohibits the waiver of certain rights (for example, some laws allow you to choose to resolve disputes in your home country’s courts), then some or all of the arbitration and class action waiver provisions above may not apply to you. In such cases, the jurisdiction and venue for disputes shall be the courts of Kenya, unless otherwise required by the laws of your country of residence.

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Subject to the foregoing and the outcome of any arbitration or legal proceedings, you and the Company consent to the exclusive jurisdiction of the courts of Kenya for the resolution of any disputes that are not required to be arbitrated or that for any reason are not resolved through arbitration. You and the Company also consent to the personal jurisdiction and venue of the Kenyan courts, and waive any objections based on inconvenience or any similar grounds, to the extent permitted by law.

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13. Miscellaneous

Entire Agreement: These Terms, along with the Privacy Policy and any additional guidelines or terms that apply to specific services or features of the Platform (each of which is incorporated by reference herein), constitute the entire agreement between you and PickSpot Network Limited regarding your use of the Platform. They supersede all prior or contemporaneous communications, agreements, or understandings (whether oral or written) concerning the subject matter.

Severability: If any provision of these Terms is held by a court or tribunal of competent jurisdiction to be invalid, illegal, or unenforceable, that provision shall be severed and the remaining provisions of these Terms shall remain in full force and effect. The invalid provision shall be deemed modified to the narrowest extent necessary to make it enforceable (if possible) or disregarded if modification is not possible, but only to the extent of its invalidity, and no further.

No Waiver: No failure or delay by the Company in exercising any right, power, or privilege under these Terms will operate as a waiver of that right or provision, nor will any single or partial exercise preclude any further exercise of the same or any other right, power, or privilege. Any waiver of any provision of these Terms will be effective only if in writing and signed by an authorized representative of the Company. The waiver of any breach or default does not constitute a waiver of any other or subsequent breach ordefault.

Assignment: You may not assign or transfer any of your rights or obligations under these Terms without the prior written consent of PickSpot Network Limited. Any attempted assignment in violation of this provision is null and void. The Company may freely assign or transfer these Terms (in whole or in part), including in connection with a merger, acquisition, corporate reorganization, or sale of assets, or by operation of law. These Terms will bind and inure to the benefit of the parties, their successors, and permitted assigns.

No Partnership: Nothing in these Terms shall be construed as creating any joint venture, partnership, employment, or agency relationship between you and the Company. You and the Company are independent parties. You have no authority to make or accept any offers or representations on behalf of the Company, and you shall not represent to any third party that you have any such authority

Headings: Section headings and summaries (such as the brief italicized descriptions at the beginning of sections, if any) in these Terms are for convenience and reference only and have no legal effect. They do not define, limit, or describe the scope or intent of any provision

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If you have any questions or concerns about these Terms & Conditions, please contact us at contact@pickspot.net. By proceeding to use the Platform, you acknowledge that you have read, understood, and agree to all of the above.

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Privacy Policy

Last Updated: June 16, 2025

PickSpot Network Limited (“Company,” “we,” “us,” or “our”) is committed to protecting your privacy and handling your personal data transparently and securely. This Privacy Policy explains what information we collect about Users of the PickSpot Network platform (including our website, app, and related services) and how we use, share, and safeguard that information. It also outlines your rights in relation to your personal data and how you can exercise those rights. This Policy is in accordance with applicable data protection laws, including the EU General Data Protection Regulation (GDPR) and Kenya’s Data Protection Act, 2019, among others. By using our Platform or Services, you consent to the practices described in this Policy

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1. Information We Collect

We collect several types of information from and about Users, including:

Personal Identification Information: When you create a PickSpot account (or otherwise register to use our services), we may collect personal details such as your full name, date of birth, physical address, phone number, email address, and other identifying information. This category also includes information you may provide as part of any identity verification (KYC) process, such as government-issued identification numbers, images of identification documents (e.g., passport or national ID), and photographs or selfies for verification purposes. We collect this information directly from you when you provide it through our website or app (for example, via registration forms, profile setup, or KYC submission forms). No Account Use by Children: Our Platform and services are not directed to individuals under 18 years old. We do not knowingly collect personal data from children. If we learn that we have inadvertently collected personal information from someone under the applicable age of consent, we will delete that information in accordance with applicable law.

Financial and Transactional Information: To facilitate transactions through the Platform, we may collect certain financial information. Depending on how you use our services, this might include your mobile payment details or banking information (for instance, your M-Pesa mobile money number, credit or debit card information, or bank account number) when you make or receive payments related to our services. We will also maintain records of transactions you conduct via the Platform, such as payments for parcel deliveries, locker usage fees, or promotional credits. If you participate in our loyalty or referral programs, we keep track of Spot Points earned, rewards redeemed, and related transactional details. Note: We do not collect or store sensitive payment details like full credit card numbers on our own servers — such information may be handled by certified third-party payment processors. Likewise, while you may use an in-app digital wallet for Spot Points and delivery credentials, we do not have access to your private wallet keys or any secret passphrases; those remain under your control. We may, however, associate an internal wallet identifier or public key with your account for purposes of tracking your Spot Point balance and facilitating transactions within the Platform.

Transactional and Usage Data: We log details of your interactions with the Platform toensure functionality and security. For example:
- Locker and Delivery Activity: If you use PickSpot lockers to send or receive
- Loyalty and Referral Activity: We record events related to our loyalty program or
- Website/App Interaction: We collect information about how you navigate and
Technical and Device Information: When you access the Platform, certain technical information about your device and internet connection is automatically collected. This may include: your device’s Internet Protocol (IP) address, device type (e.g., smartphone, tablet, desktop), operating system and version, browser type and version (if using the web interface), device identifiers or advertising IDs, and general geographic location based on IP or device settings (such as city or region). We also log the dates and times of access, and may collect telemetry data like application crash reports or error logs to diagnose technical issues. This technical information is used mainly to ensure the Platform’s compatibility with your devices, to detect and prevent fraud or unauthorized access, and to analyze the performance of our services across different environments.

Cookies and Tracking Technologies: Our website and mobile application utilize cookies and similar tracking technologies to enhance your experience and gather information. Cookies are small files placed on your web browser or device that allow us to recognize you and maintain your preferences. For example, we use cookies to keep you logged in during a session, to remember your language preference, and to collect aggregate data about user traffic and interactions (via analytics cookies). We may also use web beacons or SDKs (software development kits) in our app for similar purposes (for instance, to see if you opened an email or to measure in-app actions). You can control cookies through your browser settings and, for our app, control certain tracking via your device privacy settings. Note that disabling certain cookies or trackers might affect functionality (for example, if you block authentication cookies, you might not be able to log in). For more details, see Section 9 (Cookies Notice) below or contact us.

Communication with us: If you correspond with us (such as by email, through support chat, or by phone), we will collect and maintain records of that communication. This can include your contact information (like email address or phone number), the date and time of the communication, and the content of your inquiry or feedback along with our responses. We use this information to follow up on your questions, provide customer support, and improve our services and training.

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We may combine information collected from you with information from other sources (for example, if we receive verification information from a third-party identity check or update address details through a courier’s system). All information collection will be conducted lawfully, fairly, and in a transparent manner. Where required by law, we will obtain your consent for certain data collection.

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2. How We Use Your Information

We use the personal and usage information we collect for various purposes consistent with applicable laws and principles of transparency and data minimization. The main purposes include:

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Service Delivery and Operations: To provide, maintain, and support the core services of the Platform. For example, we use your registration information to set up and manage your user account and PickSpot digital address. We use delivery and contact information to facilitate parcel deliveries and pickups (e.g., generating a pickup code and sending it via SMS/email to notify you of a delivery). If you are a merchant or sender, we use the information you provide to route your parcels through our network and keep you and the recipient updated. We also use information about your Spot Points and activities to operate the loyalty rewards program (such as tracking points and determining eligibility for promotions).

Identity Verification and Security: To verify your identity and ensure the security of the Platform. For users required to complete KYC, we use your personal identification information to confirm you are who you claim to be (e.g., by verifying your documents and comparing your photo to your ID). We also may screen your provided details against government watchlists or sanctions lists to comply with anti-money laundering and other regulations. Technical information like device IDs and IP addresses are used to help recognize authorized devices and detect unusual account activity. For instance, we might use IP address analysis to flag a login attempt from a new location, or device identifiers to determine if multiple accounts are being created on the same device in violation of our policies. All these measures help protect you and us from fraud, abuse, and security threats.

Transaction Processing: To process transactions and maintain transaction records. Whenever you undertake a transaction on the Platform (e.g., paying a locker fee, sending a parcel, or redeeming a reward), we use the relevant information to execute that transaction. This can involve communicating with third-party payment processors (using your provided payment details to charge your card or mobile wallet), updating our ledger of Spot Points (adding points to your balance when earned, subtracting when redeemed), and keeping internal records for accounting and auditing. We also use your contact details to send transactional communications, such as payment receipts or delivery confirmations.

Communications:
- Transactional Communications: We use your contact information (email, phone
- Marketing and Promotional Communications: With your consent (or as otherwise
Platform Improvements and Analytics: We use the usage and technical data (often aggregated or pseudonymized so it does not directly identify you) to understand how our Platform is performing and how users engage with it. This helps us troubleshoot problems (for instance, analyzing crash logs to fix bugs) and make informed decisions about improvements. For example, we might analyze data to see if certain locker locations are being underutilized, if a new feature in the app is increasing user engagement, or how users navigate through the sign-up process. These insights can guide optimizations such as improving the user interface, adding more lockers in high-demand areas, or streamlining certain workflows. We may utilize third-party analytics services (like Google Analytics or similar tools) to assist with these analyses, under agreements that protect your data (these service providers cannot use your data for their own purposes outside what we instruct).
Personalization: To personalize and tailor your experience on the Platform. Based on information such as your usage history, location, and preferences, we might customize certain elements of the service for you. This could mean recommending the nearest or most frequently used lockers when you open the app, pre-filling forms with your saved info, showing the app in the language you used last, or highlighting features that we think might be relevant to you (for example, if you frequently use a specific service, wemight put that option more prominently in your app interface). Any personalization is intended to make the Platform more convenient and useful to you.
Compliance and Legal Obligations: We may process and retain your information to comply with legal obligations and enforce our rights. This includes using data for activities such as: auditing and record-keeping as required by law, responding to lawful requests by public authorities, preventing or investigating fraud and other prohibited activities, monitoring and mitigating security incidents, and enforcing these Terms & Conditions. For example, if law enforcement provides a lawful subpoena or court order for certain data, we may need to use and disclose data to comply. Also, if you or another user breaches the Terms, we might use relevant data to investigate the issue and take appropriate action (such as providing information to lawyers or courts if a legal claim arises).

Corporate Transactions: If PickSpot Network Limited undergoes a business transition such as a merger, acquisition by another company, or sale of some or all of its assets, user information (including personal data) is typically one of the assets transferred or evaluated as part of the transaction. We will use your data in connection with that due diligence process (e.g., disclosing basic operational metrics which might include user statistics to potential investors or purchasers under confidentiality) or to actually transfer the records to the successor entity that will operate the business. In any such event, we will ensure that any successor entity is contractually bound to adhere to privacy standards equivalent to those set out in this Policy. If ownership or control of your personal data changes, we will notify you of any significant changes to its use or any choices you may have, by posting a notice on our website or contacting you directly

Other Purposes with Consent: If we ever need to use your personal data for a purpose not described in this Policy (and not obvious in the context of collection), we will obtain your consent as required by law. For instance, if we wanted to use a customer testimonial with your name on our website, we would seek your permission. You have the right not to consent or to withdraw consent at any time, and we will honor that decision (though this will not affect any uses of the data that have already occurred with your consent).

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We always aim to use the minimum amount of data necessary for each purpose and have a valid legal basis for processing. Our legal bases include: performing the contract we have with you (Terms & Conditions) for service-related uses; your consent (for optional uses like marketing); compliance with legal obligations (for data we need to keep or report by law); and our legitimate interests (for uses like improving our services, securing our platform, or communicating with you about updates—balanced against your data protection rights).

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3. How We Share Your Information

We treat your personal information with care and confidentiality. However, to operate our business and provide our services, we sometimes need to share information with third parties. We do so under strict conditions and for the purposes outlined below:

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Service Providers (“Processors”): : We employ trusted third-party companies and individuals to perform certain tasks on our behalf in connection with operating the Platform (“service providers” or “data processors”). These include, for example: payment processing companies (to handle transactions securely), identity verification services (to conduct KYC checks), cloud hosting providers (to store data and run our applications), email/SMS delivery services (to send verification codes or notifications), analytics and performance monitoring tools, and customer support software providers. We share only the information necessary for these providers to perform their functions, and we require them to protect your data and use it solely for the purpose of providing their services to us. For example, if we use a third-party payment gateway, that service will receive your payment details to process a payment, but is not permitted to use your data for any other purpose. All our processors are bound by contractual agreements to safeguard personal data in line with this Policy and applicable privacy laws.

Business Partners and Integrations: In some situations, we may partner with other businesses or integrate our Platform with third-party services to jointly offer certain functionalities. For example, if an e-commerce platform or logistics company partners with PickSpot to allow their customers to choose delivery to a PickSpot locker, we will need to share certain information with that partner to fulfill the service (such as a parcel tracking number, the locker pickup code, or confirmation that a package was picked up). Similarly, if we have subsidiaries, affiliates, or a parent company that helps facilitate the services (for instance, an affiliate providing local support or additional services in another region), we may share data with them. In all such cases, we will only share what is necessary for the integration or partnership to work, and we will ensure that such partners are under obligations to protect your data. If an external application or service is optional and you choose to connect to it (for example, if you choose to link a third-party account), we will also clearly inform you what information will be shared and seek your consent before proceeding.

Legal Compliance and Protections: We may disclose your personal information when we believe in good faith that such disclosure is necessary to comply with a legal obligation or request. This includes responding to court orders, warrants or subpoenas, cooperating with regulatory authorities, or other lawful requests by public authorities (including to meet national security or law enforcement requirements). We will also share information as needed to enforce our Terms & Conditions or other agreements, or to establish or exercise our legal rights or defend against legal claims. Additionally, if we believe it is necessary, we may share information in connection with investigating or preventing fraud, security issues, or other harmful or illegal activity. For instance, if a user is suspected of committing a crime or engaging in dangerous activities through our Platform, we might provide data to law enforcement to assist in their investigation (asrequired or permitted by law). Our policy is to carefully review each request and only comply if it’s legally valid and necessary; where allowed, we may object to or narrow requests that we believe are overly broad.

Third-Party Features or Services on the Platform: If you choose to use a feature of our Platform that is powered by or interfaces with a third-party service, some of your information might be shared with or collected by that third party. For example, if you elect to use an external payment service to add funds or pay fees, that service will receive the necessary transaction details and personal information to process the payment. As another example, if a third-party courier application is used in conjunction with Deliver2Locker, that courier app might receive your locker location and an access code to complete a delivery on your behalf. In all such cases, we will make clear when you are engaging with a third-party service (often you will be presented with the third party’s own terms or privacy notice), and any data exchange will be limited to what is required. These third parties will process your information according to their own privacy policies, which we encourage you to review.

Business Transfer: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of PickSpot Network Limited or a portion of its assets, or transition of service to another provider, your information may be transferred as part of such a transaction. We would share the necessary data with parties involved (for example, a prospective buyer and its auditors/advisors) under appropriate confidentiality terms. In the event that another company acquires us or any of our assets, or if PickSpot enters bankruptcy or any other corporate restructuring process, that company would obtain the personal data collected by us as part of the business assets transferred. However, your personal data will remain subject to this Privacy Policy (unless you are notified otherwise and consent to a new policy). We will endeavor to notify you of any ownership change or data transfer and to outline any choices you may have regarding your personal information at that time

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With your Consent: Apart from the scenarios above, if we ever need to share your personal information for a purpose outside of this Policy, we will obtain your consent. You have the right to opt-in or opt-out of such sharing as required by law. For example, if we wanted to feature your story or testimonial on our blog and include personal details, we would ask for your permission

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Importantly, we do not sell your personal data to third parties for their own marketing or other independent uses. We may share information as described in this section, but always for purposes related to providing and improving our services, or as required by law.

Whenever we share data with third parties, we strive to anonymize or aggregate it when full details are not needed (for example, sharing general usage statistics that do not identify individuals). When personal data is shared, we implement appropriate contractual and technical safeguards to ensure it is handled securely and lawfully by all parties.

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4. International Data Transfers

PickSpot is headquartered in Kenya, but our user base and operations are global. Consequently, the personal data we collect may be transferred to or stored in multiple countries, including countries that may have different data protection standards than your home country

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If you are located outside of Kenya, you understand that we may transfer your personal data to Kenya and/or other countries for processing. Servers or service providers we use might be located in the African region, Europe, North America, or other jurisdictions. We will take steps to ensure that your data is afforded a similar level of protection as in your home country, by using appropriate safeguards.
For transfers from the European Economic Area (EEA) or other regions with data transfer restrictions, we will rely on legally-provided mechanisms to transfer data across borders. This may include using the European Commission’s Standard Contractual Clauses (SCCs) or ensuring the recipient is certified under frameworks like the EU-U.S. Data Privacy Framework (if applicable). We also consider derogations allowed by law (such as when a transfer is necessary to perform a contract with you, or you have given explicit consent in certain cases).
For transfers out of Kenya, we comply with the Kenya Data Protection Act’s requirements on cross-border data sharing, ensuring that the recipient country or entity has commensurate data protection standards or that we have put in place agreements or measures to ensure the security of the data (such as data transfer agreements or obtaining your consent where permitted).
Regardless of where your data is processed, we will apply the protections described in this Privacy Policy. We also will comply with any applicable local legal requirements providing additional data protections to you. However, you should be aware that, in certain cases, data in other jurisdictions may be accessible to law enforcement, courts, and regulatory authorities in those jurisdictions, according to their laws (for example, data stored in the United States might be lawfully accessed by U.S. authorities for national security or law enforcement reasons).
We will notify you if required by law in the event of certain transfers or disclosures. By using our services, you consent to your information being transferred to and stored or processed in other countries as described here, with the understanding that we will take appropriate measures to protect it.

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5. Data Security

We are committed to safeguarding your personal data and have implemented a combination of administrative, technical, and physical security measures to protect it from unauthorized access, disclosure, alteration, or destruction. These measures include:

Encryption: We use encryption protocols to protect sensitive data. For instance, our website is served over HTTPS, which encrypts data in transit between your device and our servers. Certain sensitive information (like passwords) is stored using strong hashing algorithms with salt, so that they are not stored in plain text and cannot be easily reversed.

Access Controls: Access to personal data within our organization is limited to those employees, contractors, and agents who need such access to perform their job duties (principle of least privilege). They are subject to confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations. Our systems require authentication and have time-out sessions to reduce the risk of unauthorized use. We also use firewalls and network access controls to prevent unauthorized external access.

Monitoring and Testing: We monitor our systems for possible vulnerabilities and attacks. We employ intrusion detection and prevention systems, and we regularly review our practices and policies to enhance security. We may run periodic penetration tests and security audits, sometimes with the assistance of third-party specialists, to test the strength of our defenses. Additionally, we maintain logs of access to critical systems and data, which are reviewed for any suspicious activities.

Training and Policies: We ensure that our staff are trained in best practices regarding data protection and information security. We have internal policies in place concerning data handling, incident response, and confidentiality.

Incident Response: In the event of a data breach or security incident, we have a process to contain and assess the issue, notify affected parties and regulators as required, and take steps to prevent future occurrences. We will notify you of any breach affecting your personal data where required by law and within the timeframes for notification set out by relevant regulations.

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It is important to note that, while we strive to protect your information, no security measures are infallible. The internet by its nature has inherent security risks, and we cannot guarantee absolute security of data. You also play a vital role in protecting your information. We encourage you to use a strong, unique password for your PickSpot account and to keep your login credentials confidential. If you suspect any unauthorized access to your account or any other security breaches, please contact us immediately so we can assist and take appropriate measures.

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6. Data Retention

We retain personal information for only as long as necessary to fulfill the purposes for which it was collected, or to satisfy any applicable legal, accounting, or reporting requirements. The exact duration we keep data varies depending on the type of information and the reasons for processing it. Here are some general guidelines:

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Account information: For as long as you have an active account with us, we will retain the personal information associated with your account. If you decide to close your account, or if your account is terminated by us (in accordance with our Terms & Conditions), we will typically delete or anonymize your personal data within a reasonable period after the closure or termination. However, we may retain certain data for longer if needed for legitimate business interests or legal purposes (e.g., to resolve disputes or to keep financial records). Data that is retained will be handled in accordance with this Privacy Policy and applicable laws.

Transaction and Usage Records: We maintain records of transactions (such as delivery records, payments, rewards issued) to comply with financial regulations, for auditing, and for customer support reference. These records might be kept for a number of years as required by law. For example, in Kenya and many other jurisdictions, financial and transaction data may need to be kept for a minimum of 5 to 7 years for tax, audit, and anti-money laundering compliance. Even if you delete your account, we might retain transaction records without directly identifiable information, or with identifiers replaced by a code, for these legal obligations

Communications: If you’ve communicated with our support team or through other channels, we may keep those communications for a certain period (which could be around 2-3 years, for instance) to ensure we have a history of your requests, to train our staff, and to improve our services. Call recordings or chat logs might be kept shorter unless needed for a specific reason.

Analytical Data: Analytics data that is collected about how users interact with our Platform is often aggregated or anonymized, and may be retained longer for historical analysis. If any analytics data is tied to personal identifiers, we typically either delete or anonymize it once it’s no longer needed for improving our services (for example, raw logs might be kept for a few months, whereas aggregated trends may be kept indefinitely).
Loyalty Program Data: If Spot Points or rewards are part of our service, we will maintain records of points earned and spent for as long as necessary to administer the program. If the program is discontinued or your participation ends, we may delete or anonymize those records after a period, unless they need to be retained for other purposes (like auditing or fraud prevention).
Legal Holds: In certain cases, even if you request deletion, we might retain data if it is subject to a legal hold or needed for a legal dispute. If, for example, we are involved inlitigation or receive a lawful subpoena related to your data, we would preserve relevant information until the issue is resolved and then proceed with deletion as appropriate.

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Once the retention period expires or the purpose for collecting personal data has been fulfilled, we will safely delete or anonymize the personal data. When anonymized, the data will no longer be associated with you and may be retained for analytical or statistical purposes without further notice, since it ceases to be personal data.

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7. Your Rights and Choices

Depending on your jurisdiction and applicable privacy laws, you may have some or all of the following rights regarding your personal information:

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Right to Access: You have the right to request confirmation of whether we are processing your personal data, and if so, to request a copy of the data and certain information about how we use it. This is sometimes called a “data subject access request.” Upon verification of your identity, we will provide you with a copy of the personal data we have about you, in accordance with legal requirements (subject to certain exceptions, such as if providing a copy would adversely affect the rights and freedoms of others).
Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to ask us to correct it. You can also update some of your personal data directly by logging into your PickSpot account (for example, you can change your contact details). We encourage you to keep your information up to date so we can serve you better.
Right to Erasure: This is also known as the “right to be forgotten.” You can request that we delete your personal data when it is no longer necessary for the purposes for which it was collected or if you believe it is being processed unlawfully. We will honor such requests where required by law. Note that this right is not absolute; sometimes we may have a legal obligation or a compelling legitimate interest to retain certain data (for instance, records of transactions for audit purposes). If we cannot delete data you asked us to, we will inform you of the reasons, subject to any legal restrictions. Deleting your personal data may result in closure of your account and removal of service availability, as we need certain data to provide the Platform to you.
Right to Restrict Processing: In certain circumstances (for example, if you contest the accuracy of your data or object to our processing of it), you have the right to request that we restrict processing your data while your concern is being resolved. This means we will continue to store your data, but will temporarily limit processing to certain purposes(like security or legal requirements, or until the issue causing the restriction is resolved).
Right to Object: You have the right to object to our processing of your personal data when we base the processing on our legitimate interests, and you believe those interests are overridden by your privacy rights. You also have an absolute right to object to the processing of your personal data for direct marketing purposes. If you object to marketing, we will stop using your data for that purpose immediately. If you object to other types of processing, we will evaluate your request and will stop processing the data unless we have compelling legitimate grounds or a legal reason to continue.
Right to Data Portability: In jurisdictions that provide this right (such as the EU under GDPR), you can request to receive personal data that you have provided to us in a structured, commonly used, and machine-readable format, and you may have the right to have that data transmitted to another controller where technically feasible. This right typically applies to data processed by us with your consent or for performance of a contract, and if the processing is carried out by automated means. We can provide a digital file containing your basic account information and transaction history upon request, to the extent required by applicable law.
Right to Withdraw Consent: Where we rely on your consent to process your personal information (for example, for sending promotional emails), you have the right to withdraw that consent at any time. Withdrawing consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, and it may not affect processing under other legal bases. If you withdraw consent for something that is necessary for us to provide the service, we might need to limit or terminate your use of that service. For instance, if you withdraw consent to a crucial permission in the mobile app (like access to storage for scanning documents for KYC), certain functionalities might be disabled.
Right to Complain: If you have concerns about how we handle your personal data, you have the right to lodge a complaint with a supervisory authority. In Kenya, this would be the Office of the Data Protection Commissioner. In the EU, you can contact the data protection authority in the country where you live or work, or where you feel the violation occurred. We would, however, appreciate the chance to address your concerns directly before you approach a regulator, so we invite you to contact us with any issues and we will do our best to resolve them.

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To exercise any of the above rights, please contact us using the contact information provided in Section 11 (“Contact Us”). We may need to verify your identity before acting on your request (this is to protect your information from unauthorized requests). We will respond to valid requests within the timeframe required by law (generally within one month, but this can be extended in certain circumstances by another two months, in which case we will let you know).

Please note: certain rights may not be available to you depending on your location or the legal basis for processing your data. For instance, if you are not in a jurisdiction that grants a right to data portability, we are not obligated to provide data in a portable format. Likewise, if we are processing data solely based on legal obligations, some rights like deletion might not apply if the law requires retention.

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8. Additional Notices for Specific Jurisdictions

We adhere to all applicable data protection laws and want to ensure individuals in certain regions are aware of specific provisions that may apply to them:

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Kenya: This Privacy Policy is intended to comply with Kenya’s Data Protection Act, 2019. Kenyan users have rights under this Act largely aligned with those described above, including the rights to be informed, to access, to correction, and to deletion of personal data, subject to certain exceptions. We have appointed a Data Protection Officer (DPO) as required, who oversees our compliance with Kenyan data protection laws. If you are in Kenya and have any concerns about your data, you may reach out to our DPO (see Contact Us below). You also have the right to lodge a complaint with Kenya’s Office of the Data Protection Commissioner if you believe your data rights have been infringed.
European Union (GDPR): If you are located in the European Economic Area (EEA) or a country that has adopted the GDPR (such as an EU member state), you are entitled to the rights detailed in Section 7, among others. We act as the “data controller” for your personal data when providing our services. The legal bases for processing your data are typically: your consent (where we request it, for example for marketing), performance of a contract (providing you the services as per our Terms), compliance with legal obligations, and our legitimate interests (such as improving our services, preventing fraud, and securing our network). We have implemented measures such as Standard Contractual Clauses for data transferred outside the EEA. You also have the right to lodge a complaint with your local Data Protection Authority; a list of DPAs can be found on the European Data Protection Board’s website.
United Kingdom: Following Brexit, the UK has its own data protection law (UK GDPR and the Data Protection Act 2018). If you are in the UK, the rights and protections are essentially the same as under the EU GDPR. References in this Policy to the GDPR should be taken to include UK data protection law if you are a UK resident. You may lodge complaints with the UK’s Information Commissioner’s Office (ICO).
United States: Currently, U.S. federal law does not provide a comprehensive privacy law like the GDPR, but certain states have laws (like CCPA in California, as amended by CPRA). If you are a California resident, under the California Consumer Privacy Act (CCPA) (if applicable to our business), you may have rights to know about personal data we have collected, to request deletion of personal data (with similar exceptions for necessity and legal compliance), to opt-out of the “sale” of personal data (note: we do not sell personal data as defined by CCPA), and to not be discriminated against for exercising your rights. We will treat any relevant requests in accordance with applicable law. If our operations ever meet the threshold where CCPA applies, we will update ourpractices to ensure compliance and will provide a CCPA-specific notice. Other states may have their own laws (e.g., Virginia, Colorado, etc.), and we will comply with those as applicable.
Other Countries: If you are in a country not specifically listed, we still strive to respect the privacy principles of transparency, access, and control. Many countries (Canada’s PIPEDA, Australia’s Privacy Act, Singapore’s PDPA, etc.) provide rights similar to those described above. If you contact us with a privacy request and you are in a jurisdiction with specific requirements, we will endeavor to honor your request in accordance with applicable law.

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If any provision of this Privacy Policy is contrary to a law in your country, that specific provision will be superseded by that law to the extent of the conflict, and the rest of the Privacy Policy will remain in effect.

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9. Cookies and Tracking Technologies (Brief Notice)

As noted earlier, we use cookies and similar tracking tools to enhance your experience on our website and app. When you visit our site or use our app, we may place a small data file (cookie) on your device to remember information about you, such as your login status or preferences.

Other technologies like web beacons, pixels, or SDKs in the app serve similar functions (collectively referred to here as “cookies” for simplicity).

Why we use cookies: Some cookies are necessary for the Platform to function (for example, to remember your session so you don’t have to log in repeatedly as you navigate pages). Other cookies help us improve the Platform by tracking usage patterns (analytics cookies) or help us personalize content for you (functional cookies). If we ever use cookies for advertising (unlikely in our context, but if we did), they would collect information about your browsing to display relevant ads; however, at present we do not host third-party ads on our service.

By using our website, you consent to our use of cookies and similar technologies. You can manage or disable cookies through your browser settings, but note that disabling certain cookies may affect functionality (for instance, you might not be able to stay logged in without session cookies).

For more details on specific cookies we use and how you can manage them, you can refer to our detailed Cookies Policy (if available on our website) or contact us for our detailed cookie policy

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10. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons. When we update the Policy, we will revise the “Last Updated” date at the top. If any changes are material (significantly affecting how your datais processed or your rights), we will provide prominent notice such as by posting a notice on our website, and/or notifying you via email or through the app.

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Continued use of our Platform after any changes take effect indicates your acceptance of the revised Privacy Policy. If you do not agree with any updated Policy, you should stop using the Platform and may request that we delete your personal data as per Section 7. We encourage you to review this Policy periodically to stay informed about how we are protecting your information.

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11. Contact Us

If you have questions or concerns about this Privacy Policy or your personal data, contact our Data Protection team:

Email: contact@pickspot.net (Please include the subject line “Privacy Inquiry” for clarity).
Address: PickSpot Network Limited, Valley View Office Park, Parklands, Nairobi, Kenya

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We will do our best to address any questions or issues you have in a timely and professional manner. We appreciate the opportunity to address your concerns directly before you contact any supervisory authorities.

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PickSpot Network Limited — Official Registration Details

PickSpot Network Limited is a Private Limited Company lawfully incorporated in Kenya. Below are our official registration details for transparency and verification:

Registered Address
- Building: Yare Towers
- Street/Road: Yusuf Hajj Avenue
- City/Town: Nairobi
- District: Starehe
- County: Nairobi
- Postal Code: 00100
- P.O. Box: 38904

Disclaimer: The information provided here is for informational and verification purposes only. It does not constitute an endorsement, investment advice, or any form of guarantee by the Company.

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Thank you for reviewing our Imprint, Terms & Conditions, and Privacy Policy. By using PickSpot, you are helping to modernize and decentralize last-mile logistics, and we are committed to ensuring your trust and security as the network grows. If you have further questions or feedback, please reach out to us at contact@pickspot.net.

PickSpot Network Limited Imprint, Terms & Conditions, and Privacy Policy