Privacy Policy

Effective 2026 · Issued under the Data Protection Act, 2019 (Kenya)

1. Who we are

F360 Admin Central ("we", "us") operates the Facility360 platform that lets healthcare facilities in Kenya invite staff to receive schedules, announcements and task notifications. We are the data controller for the personal data described in this notice, as defined by the Data Protection Act, 2019 (the "Act").

2. What data we collect

When a facility invites you and you accept, we process:

Your name and email address (provided by your facility);
Your job title, department and facility affiliation;
Account credentials you set during sign-up;
Technical data needed to secure the account — IP address, device type and timestamps of invite and login activity.

If you use our mobile application, and only with the device permissions you grant, we may also process:

Location — your approximate or precise device location, captured only while the app is open and only at the moment you perform a location-based action (such as QR-code sign-in or attendance check-in) to confirm you are at the facility. We do not track your location in the background.
Camera — accessed only when you scan a QR code within the app. We process the scanned code; we do not take or store photographs of you.
Biometric unlock — if you enable fingerprint or face unlock, your device performs the check locally. Your biometric data never leaves your device and is never transmitted to or stored by us; we only receive a confirmation that the unlock succeeded.
Push notifications — a device notification token, used to send you schedules, announcements and task alerts. You can disable notifications in your device settings at any time.

3. Why we process it (lawful basis)

We rely on the following bases under section 30 of the Act:

Performance of your employment relationship — to deliver schedules, announcements and tasks from your facility;
Consent — which you give by accepting the invite and creating an account, and which you may withdraw at any time;
Legitimate interest and legal obligation — to keep an audit trail of invite acceptance and to secure accounts against misuse.
Presence and attendance — location checked at sign-in or check-in, and QR-code scanning, are carried out on the basis of your engagement with the facility and our legitimate interest in accurate attendance records — not solely your consent.
Optional convenience features — biometric unlock and push notifications are used only with your consent, which you may withdraw at any time in your device settings. Every device feature requires the relevant device permission, which you may decline or revoke at any time; declining location or camera only prevents the specific action that needs it, such as QR sign-in.

4. How we protect it and how long we keep it

Personal data is transmitted over HTTPS and stored with access restricted to your facility's authorised administrators on a need-to-know basis. Invite codes expire, are rate-limited, and every acceptance is logged. We retain your account data only for as long as your affiliation with the facility is active, plus any period required by law.

For mobile-app features specifically: we do not retain raw location coordinates after your presence at a facility has been confirmed — the coordinate is used to verify presence at the moment of sign-in or check-in and then discarded. The resulting sign-in or attendance record (the time and the confirmed facility) is retained for the duration of your affiliation plus any statutory record-keeping period. Scanned QR codes are processed to complete sign-in and are not stored as images.

5. Who we share it with

We do not sell your data. We share it only with the facility that invited you and with infrastructure providers acting as our data processors under written contract. We do not disclose your affiliation with one facility to any other facility.

6. Your rights under the Act

You have the right to:

Be informed of how your data is used;
Access the personal data we hold about you;
Request correction of inaccurate or incomplete data;
Request deletion of your data ("right to erasure");
Object to or restrict processing;
Withdraw consent at any time.

To exercise any of these rights, contact our Data Protection Officer at [email protected]. You also have the right to lodge a complaint with the Office of the Data Protection Commissioner (ODPC) of Kenya at www.odpc.go.ke.

7. Deleting your account and data

You may request deletion of your F360 Admin Central account and the personal data associated with it at any time. To request account and data deletion, email our support team at [email protected] from the address linked to your account, or include your account email in your message.

We will verify the request and delete your account and associated personal data, except any records we are required to retain to comply with a legal obligation. We aim to complete verified deletion requests within 30 days and will confirm once the deletion is done.

8. Children

This application is intended for adult healthcare professionals engaged by a facility. It is not directed at, or intended for use by, children.

9. Changes to this policy

We may update this policy to reflect changes in law or our practices. The effective year above indicates the current version.