Privacy Policy

Last updated: 13 October 2026 · Version 2026-10-13

The short version

• LangoHub is run by Vanray Systems. If you visited an estate, the estate decides how your visit record is used and is the data controller. We are its data processor.
• At the gate we record who came, when, and who they visited. A photo may be taken only after you are told about it, and you can decline it where the estate allows. Your ID card is handed straight back. Nobody keeps it.
• We do not use facial recognition or biometrics. We never sell data. We never use it for advertising.
• Visit records and photos are deleted automatically after 12 months, or sooner if the estate chooses.
• Our servers are outside Kenya (in the United States), and we use safeguards that Kenyan law requires.
• You can ask to see, correct or delete your data at langohub.app/data-request or by emailing privacy@langohub.app. You can also complain to the Office of the Data Protection Commissioner (ODPC).

1. Who we are

LangoHub (langohub.app, the web app and the Android app) is provided by Vanray Systems ("we", "us").

• Privacy contact and Data Protection Officer: privacy@langohub.app
• WhatsApp: +254 748 546 980

This policy explains how personal data is handled under the Data Protection Act, 2019 (the "Act") and its Regulations. Our Data Protection Terms page explains the legal words in plain English and Kiswahili.

2. Our two roles

(a) We process data for estates (we are the "data processor").

When an estate uses LangoHub, the estate decides why and how records about the following people are used:

• visitors;
• residents;
• guards;
• domestic staff; and
• delivery riders.

This is "Estate Data". The estate is the data controller. We handle Estate Data only on the estate's instructions, under our Data Processing Agreement. The estate's own notice at the gate (see our Visitor Privacy Notice) also applies. For questions about a specific visit, contact the estate first. We will help.

(b) We are responsible for some data ourselves (we are the "data controller").

We decide how to handle:

• sign-in accounts and security logs of all users (email or phone, password, sign-in history), which we need to run and protect the platform. The estate remains the controller of what residents, guards and staff do inside its records;
• our customer relationship with estate managers, owners and property managers;
• billing and payment records;
• support conversations;
• website and demo requests;
• information about estates our sales team visits; and
• information about our sales representatives.

3. What we process, why, and on what legal basis

3.1 Visitors (Estate Data. The estate is controller.)

What we collect

• name;
• phone number;
• ID, passport or driving-licence number;
• the unit or person visited, and the purpose;
• time in and out, and the gate used;
• number plate and vehicle type;
• a plain photo of the visitor and/or vehicle, if the estate uses photos;
• notes added by guards; and
• any pre-registration details the visitor or host gave.

Why

• to identify people entering the estate;
• to record entry and exit times;
• to let the host know a guest has arrived; and
• to investigate security incidents.

Legal basis the estate relies on

• Legitimate interests: the security of residents and property.
• Legal authority for guards: section 48 of the Private Security Regulation Act, 2016 allows guards to ask people to identify themselves and to record their entry and exit times. It also says that information recorded when a person is registered may be used only to identify them. Estates must keep to that limit.
• Photos are taken only after the visitor has been told. Where the estate allows, a visitor may decline a photo and be identified from their ID details alone.
• Regular visitors: to speed up check-in, the visitor's name, phone and ID number are kept as a "frequent visitor" suggestion. It is deleted when the estate's retention period has passed since their last visit.

3.2 Residents (Estate Data)

What we collect

• name, unit, phone and email;
• guests you pre-register;
• domestic-staff passes you set up; and
• your choice of alerts.

Why

• to give you resident features;
• to tell you when a guest arrives; and
• to let the gate check your pre-registered guests.

Legal basis

• your relationship with the estate, and its legitimate interests;
• your consent for WhatsApp alerts. You can withdraw consent at any time by replying STOP or ACHA, or in the app.

3.3 Guards and estate staff (Estate Data)

What we collect

• name and phone number;
• role and gate;
• a PIN, stored only in hashed (scrambled) form;
• which gate device was used; and
• actions taken in the app.

Why

• to run the gate;
• to keep an audit trail; and
• to secure access.

Legal basis: the estate's legitimate interests and its employment or service arrangements.

3.4 Domestic staff, delivery riders and people on an estate blacklist (Estate Data)

What we collect

• name, phone and role;
• the days and times you are allowed in;
• for riders, the delivery platform; and
• for the blacklist, the reason and expiry date set by the estate.

Why: access control and security.

Legal basis: the estate's legitimate interests in security.

Safeguards

• A blacklist entry must give a specific reason and have an expiry date of no more than 12 months.
• A blacklist match is only an alert. A person always decides.

3.5 Estate managers, owners and property managers (we are controller)

What we collect

• name, email and phone number;
• the estate's name, address and number of units;
• the account type;
• billing, payments and invoices;
• your acceptance of these documents; and
• support conversations.

Why: to provide the service, bill for it, support you and keep records required by tax law.

Legal basis: performance of our contract with the estate, and legal obligations (tax records).

3.6 Estate contacts our sales team meets (we are controller)

What we collect

• name and phone number of the manager or contact;
• the estate's name, location and size; and
• notes and follow-up dates.

Why: to offer LangoHub to estates and arrange demos.

Legal basis: our legitimate interests in business-to-business sales.

You can ask us to stop contacting you at any time.

3.7 Our sales representatives (we are controller)

What we collect

• name, phone and email;
• M-Pesa number for commission;
• training progress;
• the approved phone used for work; and
• the GPS location captured only when you tap "check in" at an estate visit.

Why: to run the sales programme, verify visits and pay commission.

Legal basis: our contract with you, and legal obligations (tax).

3.8 Website visitors and demo requests (we are controller)

What we collect

• what you type in the demo or contact forms; and
• basic technical data such as pages viewed, device type and approximate country (from our hosting provider's aggregate statistics).

Why: to reply to you and to keep the site working.

Legal basis: legitimate interests. We send marketing messages only if you asked for them (see section 12).

3.9 App and device data

What we collect

• device ID and app version;
• the registered status of a gate device;
• error reports; and
• offline records waiting to sync.

Why: to keep the app working offline, deliver updates and secure gate devices.

Legal basis: legitimate interests, and contract.

4. ID scanning

An estate may switch on ID scanning. It is off unless the estate turns it on. When it is on:

• (a) the guard asks the visitor first. The visitor may ask the guard to type the details instead;
• (b) the photo of the ID is sent over an encrypted connection to our text-recognition provider (OpenAI, through the Lovable AI gateway). The provider is told to read only the holder's name and document number, and nothing else such as date of birth;
• (c) the ID image is not saved by LangoHub. Under its own terms, the AI provider may keep it for a limited period, up to 30 days, for abuse monitoring. It is not used to train AI models;
• (d) only the name and number, as checked by the guard, are saved in the visit record; and
• (e) the ID card itself is handed straight back.

5. AI features and automated decisions

5.1 Pre-registration notes. Residents may type a short note about a guest, such as "John at 3pm, KAA 123B". The note is sent to an AI provider (Anthropic's Claude, through the Lovable AI gateway) to fill in the form.

• Nothing is saved until the resident checks and confirms the result.
• Do not include ID numbers or sensitive details in these notes.

5.2 No automated decisions. LangoHub does not make decisions about people based solely on automated processing.

• Blacklist matches and ID-scan results are suggestions that a guard reviews.
• If you think an automated alert affected you, you can ask for a person to review it (section 35 of the Act).

5.3 No facial recognition or biometrics. We do not use facial recognition, fingerprints or any biometric matching. Photos are plain photos kept as part of the record. They are never compared by software.

6. Children

6.1 LangoHub accounts are for adults (18 and over).

6.2 When the visitor is a child (under 18), guards record only:

• the minimum details;
• the host; and
• the accompanying adult.

They must not take the child's photo or ID number.

6.3 Telling the parent or guardian. A parent or guardian who is with the child is told about the record at the gate. If the child arrives without a parent or guardian, the guard records only the child's first name and the unit visited. The resident being visited is asked to let the parent or guardian know.

6.4 Requests about a child's data. A parent or guardian can make requests about their child's data (sections 27 and 33 of the Act).

7. Who we share data with

Inside the estate. Estate Data is shared only with the estate's authorised people:

• managers;
• guards; and
• the resident being visited, who sees your name and arrival time.

Service providers (sub-processors). We use service providers for hosting, messaging and AI text reading. They must protect the data and use it only to provide their service to us. They are listed on our Sub-processors page.

Payment providers. Payment providers and M-Pesa process payments under their own licences and privacy policies.

Authorities. Police, courts or regulators receive data only when the law requires it, for example under a court order. We will tell the estate unless the law prohibits it.

A buyer or successor. If the LangoHub business is transferred to another business, including a company formed to run LangoHub, the data goes with it. The same protections continue.

We never sell personal data and we do not use it for advertising.

8. Transfers outside Kenya

Our main database and file storage are hosted by Lovable Cloud (built on Supabase) in Amazon Web Services' Oregon region in the United States. WhatsApp messages and AI text reading are also processed in the United States. Address look-ups for our internal sales map use services in the United Kingdom and EU, and involve business addresses only. Authorised LangoHub staff may access data from outside Kenya to give support, using secured accounts.

The Act allows these transfers with appropriate safeguards (sections 48–50 and Regulations 40–41). We use the following:

• data-protection agreements with our providers, made directly or through Lovable (which contracts with the AI model providers), including standard contractual clauses where the provider offers them;
• encryption in transit and at rest;
• strict access controls;
• keeping data to the minimum each provider needs; and
• a record of each transfer, which we can show to the Data Commissioner on request.

LangoHub does not process the kinds of data that Kenyan law requires to be stored in Kenya. Estates can ask us for our transfer documentation.

9. How long we keep data

10. How we protect data

The main measures are listed below. Full details are on our Security page.

• Encryption: all data is encrypted in transit (HTTPS/TLS) and at rest.
• Separation between estates: each estate's data is walled off from every other estate's at the database level.
• Access by role: managers, guards and residents each see only what their role needs.
• Guard PINs: PINs are stored only in hashed form.
• Photos: photos are kept in private storage and shown only through short-lived links. They are never included in CSV exports, and are provided only on request (for example for an access request, or at the end of a subscription).
• Audit log: access by our own staff is logged.
• Breach response: if a breach happens:
  • we tell affected estates without delay, and where possible within 48 hours;
  • we tell the Data Commissioner within 72 hours where we are the controller; and
  • we tell affected people where required.

11. Your rights

Under the Act, you have the rights below. The deadline column shows how long the person responsible has to respond under the Data Protection (General) Regulations, 2021.

How to make a request

• Use the form at langohub.app/data-request, email privacy@langohub.app, or ask the estate.
• Do not send a copy of your ID. We may ask you to confirm a code sent to your phone, or to show ID at the estate office, so we can confirm it is you.
• Requests are free.

If your request is about Estate Data

• We pass it to the estate within 2 working days and help it respond in time.
• Some requests can be refused where the law allows, for example if records are needed for a legal claim or to investigate an incident. You will be told why.

12. Marketing

What we send. We send marketing messages only to business contacts such as estate managers who asked to hear from us, or who would reasonably expect it.

Opting out. Every message tells you how to opt out for free, for example by replying STOP.

What we never do. We never send marketing to visitors or residents, and never use Estate Data for marketing.

13. Cookies and device storage

We use only the storage needed to keep you signed in, remember your language and let the gate app work offline. There are no advertising cookies. See our Cookies & Storage page.

14. Complaints

If you are unhappy with how your data is handled, please contact us first at privacy@langohub.app.

You also have the right to complain to the Office of the Data Protection Commissioner (ODPC):

• Online: www.odpc.go.ke (use "File a complaint")
• Email: info@odpc.go.ke
• Phone: 020 780 1800
• Address: Britam Tower, 12th Floor, Hospital Road, Upper Hill, Nairobi

15. Changes to this policy

We will update this policy when our practices or the law change. The date at the top shows the latest version. Material changes are announced in the app and by email to estate managers.

16. Language

This policy is in English, and a Kiswahili summary is provided. Ask us if you need help understanding any part of it.