TOTOCARE CONNECT PRIVACY POLICY

Last Updated: 21 September 2026

TotoCare Connect ("TotoCare Connect", "we", "us", or "our") is committed to protecting the privacy, safety and personal information of the families, TotoCare Connect Child & Home Assistants, administrators and other individuals who interact with our platform.

This Privacy Policy explains how we collect, use, disclose, store, protect and otherwise process personal data when you use the TotoCare Connect website, platform, applications, communication channels and related services (collectively, the "Platform").

TotoCare Connect is designed around a simple principle:

We collect the information necessary to provide safe, dependable childcare — and we do not collect or use personal information simply because we can.

This Privacy Policy should be read together with our Terms of Service, Safety Policy and any other notices presented to you when you use particular features of the Platform.

1. WHO WE ARE

TotoCare Connect is a childcare service platform that connects families with trained and verified TotoCare Connect Child & Home Assistants for childcare services.

For purposes of applicable Kenyan data protection law, TotoCare Connect may act as a data controller in relation to personal data for which we determine the purposes and means of processing.

Some third-party service providers may process personal data on our behalf as data processors.

Legal entity: TotoCare Connect Ltd

Registered address: Paramount Plaza, 4th Floor - Kipande Road, Nairobi.

Privacy/Data Protection contact: hello@totocareconnect.online

Data Protection Officer/Responsible Privacy Contact: Data Protection Officer

2. OUR COMMITMENT TO PRIVACY

We process personal data in accordance with applicable data protection law, including the laws of Kenya.

Our privacy practices are guided by the following principles:

• Lawfulness, fairness and transparency
• Purpose limitation
• Data minimisation
• Accuracy
• Storage limitation
• Security and confidentiality
• Accountability
• Privacy by design and by default
• Protection of children's best interests
• Appropriate controls over access and disclosure

We will not use personal data for purposes that are incompatible with the purpose for which it was collected unless permitted by applicable law.

3. WHOSE INFORMATION WE COLLECT

Depending on how you interact with TotoCare Connect, we may process information relating to:

Parents and guardians

People who create accounts, request childcare or otherwise use TotoCare Connect services.

Children receiving childcare

Information about children whose care is requested through the Platform.

TotoCare Connect Child & Home Assistants

People applying to join, being verified, trained, matched or assigned to provide services through TotoCare Connect.

Emergency contacts and authorised persons

Individuals identified by a parent, guardian or assistant for legitimate safety or operational purposes.

Other individuals

This may include people who contact us, participate in an investigation, submit a complaint, provide a reference, appear in evidence or otherwise interact with the Platform.

4. INFORMATION WE COLLECT

We only collect information that is reasonably necessary for the relevant purpose.

4.1 Account and identity information

Depending on the account type, this may include:

• Full name
• Phone number
• Email address
• Date of birth or age where necessary
• Account credentials or authentication information
• Profile photograph
• Account status
• Communication preferences
• Login and security information

TotoCare Connect uses OTP-based authentication where supported. We do not need to maintain a traditional password database where passwordless authentication is used.

5. INFORMATION ABOUT CHILDREN

Because TotoCare Connect provides childcare services, we necessarily process certain information about children.

This may include:

• Child's first name or preferred name
• Age or date of birth
• Relevant care requirements
• Feeding information
• Sleep routines
• Allergies or relevant medical information where necessary for safe care
• Medication-related information where appropriate
• Emergency information
• Behavioural or communication information necessary for appropriate care
• Special instructions provided by a parent or guardian
• Booking history
• Incident or safety information relating to a booking
• Information necessary for authorised handover

Parents and guardians should only provide information that is relevant and necessary for the requested care.

Children's information is treated with heightened protection.

TotoCare Connect does not permit children to create ordinary parent or assistant accounts for the purpose of accessing childcare services.

Parents or lawful guardians are responsible for providing information about children for whom they have appropriate authority.

We will not use children's personal information for targeted advertising or unrelated commercial profiling.

We will not publicly display children's names, addresses, photographs, school information, routines or other identifying information without an appropriate lawful basis and, where required, appropriate consent or authorisation.

6. ASSISTANT VERIFICATION INFORMATION

TotoCare Connect is a managed childcare service and must verify the identity and suitability of people who provide services through the Platform.

For TotoCare Connect Child & Home Assistants, we may collect:

• Identification information
• Identification document details
• Profile photograph
• Selfie/liveness verification results
• Verification status
• Background or police clearance information
• Employment history
• Childcare experience
• References
• Training records
• Academy completion records
• Assessment results
• Competency records
• Professional qualifications
• First aid or related qualifications
• Qualification expiry dates
• Interview records
• Professional tier information
• Availability
• Service eligibility
• Performance and booking history
• Relevant reviews and feedback
• Safety and incident records where necessary

Some of this information may constitute sensitive personal data under applicable law.

TotoCare Connect will limit access to sensitive verification information to personnel who require it for legitimate operational, verification, safety, compliance or legal purposes.

7. IDENTITY AND LIVENESS VERIFICATION

Where TotoCare Connect requires identity or liveness verification, the Platform may process information necessary to determine whether the person completing verification corresponds to the identity being verified.

Depending on the verification method and service provider, this may involve biometric information or biometric-derived verification results.

Where a third-party identity verification provider is used, that provider may process relevant information on TotoCare Connect's behalf or independently as applicable to its service.

TotoCare Connect will seek to minimise the amount of biometric information it directly retains.

Where technically and operationally appropriate, TotoCare Connect will retain verification results, status, reference identifiers and audit information rather than unnecessary raw biometric material.

Raw biometric information will not be retained indefinitely.

Identity verification data will only be used for legitimate purposes such as:

• Establishing identity
• Preventing impersonation
• Protecting families and assistants
• Meeting verification requirements
• Preventing fraud
• Maintaining platform security
• Responding to legitimate safety or legal requirements

8. LOCATION INFORMATION

TotoCare Connect may process location information to provide childcare services safely and efficiently.

This may include:

• The childcare booking location
• Saved service addresses
• Approximate operational location
• Assistant location during an active dispatch
• Location accuracy information
• Timestamp associated with a location update

Parent booking location

A parent may provide a precise address or location where childcare will take place.

This information is private and is not publicly visible.

It is disclosed to an assigned assistant only when necessary to fulfil the booking and according to the Platform's operational rules.

Assistant location

TotoCare Connect may use location information to support matching, dispatch and operational safety.

Where live dispatch location sharing is used, the assistant will be informed when location sharing starts.

Participant-facing location sharing should be limited to what is necessary for the active journey and booking.

For example:

"Your location will be shared with the family while you travel to the booking location. Location sharing will stop when you arrive and check in."

TotoCare Connect does not intend to operate continuous background tracking of assistants for general surveillance.

Location sharing may stop when:

• The assistant arrives and checks in
• The booking is cancelled
• The booking ends
• Dispatch is terminated
• The relevant location-sharing period expires
• Another legitimate operational condition requires it

Location information will be retained only for as long as necessary for the relevant operational, safety, legal or dispute-resolution purpose.

9. BOOKING INFORMATION

When you request or provide childcare through TotoCare Connect, we may process:

• Booking ID
• Requested service
• Date
• Start and end time
• Number of children
• Relevant child age information
• Care instructions
• Booking location
• Assistant assignment
• Booking status
• Price
• Payment status
• Cancellation information
• Check-in/check-out information
• Relevant communications
• Service completion information
• Reviews and feedback
• Relevant incident information

TotoCare Connect uses this information to facilitate the requested childcare service and maintain an accurate record of the transaction.

10. SAFETY AND INCIDENT INFORMATION

Safety is a core part of TotoCare Connect's service.

We may process information relating to:

• Safety reports
• Complaints
• Incidents
• Accidents
• Safeguarding concerns
• Late arrival or no-show events
• Early departure
• Booking interruptions
• Emergency situations
• Communications concerning a safety issue
• Evidence submitted in connection with an incident
• Safety investigations
• Safety restrictions
• Relevant actions taken

Safety information is handled on a need-to-know basis.

A complaint or report does not automatically mean that an allegation is established as fact.

Where appropriate, TotoCare Connect may record the status and outcome of an investigation separately from the original allegation.

Safety records may be retained longer than ordinary operational records where necessary for safeguarding, dispute resolution, legal obligations, insurance, regulatory requirements or the establishment, exercise or defence of legal claims.

11. HEALTH INFORMATION

A parent may provide limited health-related information where it is reasonably necessary to provide safe childcare.

Examples may include:

• Allergies
• Food restrictions
• Relevant medical conditions
• Emergency information
• Medication instructions where appropriate

TotoCare Connect will seek to minimise health information collected.

Parents should not provide extensive medical records where such information is unnecessary for the requested childcare service.

Health information will receive additional access controls.

TotoCare Connect Child & Home Assistants will only receive health or emergency information that is reasonably necessary for them to provide the agreed care safely.

12. PAYMENT INFORMATION

TotoCare Connect may process payment-related information necessary to:

• Calculate charges
• Request payment
• Confirm payment
• Process refunds
• Reconcile transactions
• Process assistant earnings
• Process withdrawals
• Detect and prevent financial fraud
• Maintain financial records

Where payment or payout services are provided by third parties, payment information may be processed by those providers according to their own privacy notices.

TotoCare Connect does not need to store complete payment-card information where the relevant payment provider securely processes that information on our behalf.

For M-Pesa transactions, TotoCare Connect may process information such as:

• Phone number
• Transaction amount
• Transaction reference
• Transaction status
• Date and time
• Relevant payment metadata

13. COMMUNICATIONS

We may communicate with you through:

• In-app notifications
• SMS
• Email
• Telephone
• WhatsApp or other supported communication channels
• Other communication methods necessary to provide the service

Communications may relate to:

• Account security
• OTP verification
• Booking requests
• Assignment
• Assistant acceptance
• Payment
• Dispatch
• Arrival
• Cancellation
• Safety
• Complaints
• Service updates
• Important changes to our terms or policies

Operational and safety communications may be sent even where you have opted out of promotional communications.

14. INFORMATION WE COLLECT AUTOMATICALLY

When you use the Platform, we may automatically collect limited technical information such as:

• IP address
• Device type
• Browser type
• Operating system
• Session information
• Login events
• Security events
• Pages or features accessed
• Approximate usage information
• Error and diagnostic information

We use this information to:

• Maintain security
• Prevent fraud
• Diagnose technical problems
• Improve reliability
• Understand Platform usage
• Monitor performance
• Protect our systems

15. COOKIES AND SIMILAR TECHNOLOGIES

TotoCare Connect may use cookies and similar technologies.

These may include:

Essential cookies

Necessary for:

• Authentication
• Security
• Session management
• Core Platform functionality

Functional cookies

Used to remember preferences and improve the user experience.

Analytics technologies

Where used, these help us understand how people use the Platform and identify technical or usability problems.

TotoCare Connect will not use non-essential tracking technologies for purposes unrelated to the purposes disclosed to users.

Where consent is legally required, we will request it before using the relevant non-essential technology.

16. WHY WE USE PERSONAL DATA

We may process personal data for the following purposes:

Providing childcare services

To:

• Create accounts
• Receive bookings
• Match families with eligible assistants
• Assign assistants
• Coordinate bookings
• Facilitate payments
• Facilitate communication
• Track service status
• Complete bookings

Safety and safeguarding

To:

• Verify assistants
• Protect children
• Investigate incidents
• Respond to safety concerns
• Manage safety restrictions
• Support emergency response
• Prevent fraud and abuse

Verification

To:

• Confirm identity
• Conduct liveness verification
• Verify qualifications
• Check references
• Maintain professional readiness records

Platform security

To:

• Prevent unauthorised access
• Detect fraud
• Investigate suspicious activity
• Protect accounts
• Maintain system integrity

Legal and regulatory compliance

To comply with applicable laws, lawful requests, court orders, regulatory requirements and legitimate legal obligations.

Service improvement

To:

• Improve matching
• Improve reliability
• Understand service performance
• Fix technical problems
• Develop safer and more effective workflows

Where possible, information used for analytics or service improvement will be aggregated, anonymised or otherwise minimised.

17. LAWFUL BASIS FOR PROCESSING

Depending on the circumstances, TotoCare Connect may rely on one or more lawful bases recognised under applicable data protection law, including:

• Performance of a contract
• Compliance with a legal obligation
• Consent
• Legitimate interests
• Protection of vital interests
• Other lawful grounds available under applicable law

The applicable basis depends on the specific processing activity.

For example, processing necessary to fulfil a childcare booking will generally be connected to providing the requested service.

Marketing communications that require consent will be based on the appropriate consent mechanism.

Where sensitive personal data or children's data is processed, TotoCare Connect will apply the additional requirements that apply to such processing.

18. CONSENT

Where TotoCare Connect relies on consent, we will seek consent in a manner that is:

• Freely given
• Specific
• Informed
• Unambiguous
• Appropriate to the processing involved

You may withdraw consent where consent is the lawful basis for processing.

Withdrawal of consent does not necessarily affect processing that was lawfully carried out before withdrawal.

Some information may still need to be processed after consent is withdrawn where another lawful basis applies, such as contractual, legal, safety or dispute-resolution requirements.

19. HOW WE SHARE PERSONAL DATA

TotoCare Connect does not sell personal data.

We may disclose personal data where necessary and lawful to:

Assigned TotoCare Connect Child & Home Assistants

Information necessary to provide the booked childcare service.

This may include relevant:

• Booking information
• Care instructions
• Child information
• Emergency information
• Booking location

Assistants do not receive unrestricted access to a family's account or personal information.

Parents or guardians

Information about the assigned assistant that is appropriate and necessary for the booking.

Service providers

We may use trusted third-party providers for services such as:

• Hosting
• Identity verification
• Liveness verification
• Payment processing
• M-Pesa services
• SMS
• Email
• Notifications
• Customer support
• Security
• Analytics
• Storage
• Technical infrastructure

These providers may process information on our behalf subject to appropriate contractual and security requirements.

Professional advisers

We may disclose information to lawyers, auditors, insurers, accountants or other professional advisers where necessary.

Authorities

We may disclose information where required or permitted by law, including where necessary to:

• Respond to lawful requests
• Protect children
• Respond to emergencies
• Investigate suspected criminal activity
• Protect users
• Protect TotoCare Connect's legal rights

20. THIRD-PARTY SERVICE PROVIDERS

TotoCare Connect carefully selects service providers that process personal data on its behalf.

Depending on the service, providers may process:

• Identity information
• Contact information
• Payment information
• Technical information
• Location information
• Verification information

Where appropriate, contracts with processors will require them to:

• Process information only for authorised purposes
• Maintain appropriate security
• Protect confidentiality
• Assist with data protection obligations
• Notify TotoCare Connect of relevant security incidents
• Delete or return information when required

21. INTERNATIONAL DATA TRANSFERS

Some service providers used by TotoCare Connect may process personal data outside Kenya.

Where personal data is transferred outside Kenya, TotoCare Connect will take appropriate steps required by applicable Kenyan data protection law, including ensuring that appropriate safeguards, lawful transfer mechanisms or other applicable requirements are satisfied.

We will not transfer personal data internationally merely for convenience where the transfer is unnecessary.

Where appropriate, our vendor and processor agreements will address:

• Security
• Confidentiality
• Data protection obligations
• Permitted processing
• Sub-processors
• Retention
• Data return or deletion
• Incident notification

22. DATA SECURITY

TotoCare Connect uses appropriate technical and organisational measures to protect personal data.

These may include:

• Access controls
• Role-based permissions
• Authentication controls
• Encryption where appropriate
• Secure communications
• Audit logging
• Database security
• Backup controls
• Monitoring
• Security testing
• Staff confidentiality obligations
• Restricted access to sensitive information
• Secure handling of verification documents
• Secure evidence storage

Access to sensitive information is based on the principle of least privilege.

Not every TotoCare Connect employee or administrator can access every category of information.

23. PRIVACY BY DESIGN

Privacy is considered when new TotoCare Connect features are designed.

For sensitive features such as:

• Children's data
• Identity verification
• Liveness verification
• Location sharing
• Safety investigations
• Health information
• Evidence storage

TotoCare Connect will assess privacy and security risks before or during implementation as appropriate.

Where processing is likely to create a high risk to individuals, TotoCare Connect will undertake an appropriate Data Protection Impact Assessment or equivalent privacy risk assessment.

24. LOCATION PRIVACY

TotoCare Connect does not use location functionality to continuously monitor assistants for general surveillance.

Location processing is intended to support:

• Booking location accuracy
• Matching
• Dispatch
• Arrival
• Safety
• Operational coordination

Participant-facing location sharing is limited to the relevant booking and operational period wherever technically possible.

Exact home addresses are treated as confidential information.

TotoCare Connect will not publicly publish the locations of families or assistants.

25. SAFETY EVIDENCE

Where an incident or safety concern requires evidence, TotoCare Connect may collect or retain information such as:

• Messages
• Photographs
• Documents
• Statements
• Incident descriptions
• Relevant location information
• Booking records
• Communication records
• Other evidence reasonably necessary for investigation

Safety evidence is restricted to authorised personnel.

Evidence will not be publicly displayed.

Access to sensitive evidence may be logged.

26. DATA RETENTION

TotoCare Connect does not retain personal data indefinitely.

Different categories of information may have different retention periods.

Retention depends on:

• The purpose for which the information was collected
• Whether the account remains active
• Whether a booking or transaction remains relevant
• Legal requirements
• Financial record requirements
• Safety and safeguarding requirements
• Dispute resolution
• Fraud prevention
• Establishment or defence of legal claims
• Regulatory requirements

Examples include:

Account information

Retained while the account is active and for an appropriate period afterwards where necessary for legitimate legal, security or operational purposes.

Booking information

Retained for as long as necessary to administer bookings, payments, disputes, safety matters, legal obligations and legitimate business records.

Financial records

May need to be retained for longer periods where required by applicable financial, tax or legal requirements.

Safety records

May be retained for longer where necessary to protect children, investigate incidents, manage disputes, comply with legal obligations or establish or defend legal claims.

Verification records

Retained only for as long as reasonably necessary for verification, safety, regulatory and legitimate operational purposes.

Raw biometric information

Where processed through a verification provider, TotoCare Connect will seek to minimise direct retention and will not retain raw biometric information indefinitely.

Location data

Retained only for the period necessary for the relevant booking, operational, safety, dispute or legal purpose.

When personal data is no longer required, it will be securely deleted, anonymised or otherwise disposed of in accordance with our retention procedures and applicable law.

27. YOUR DATA PROTECTION RIGHTS

Subject to applicable law and any lawful limitations, you may have rights including:

• The right to be informed about processing of your personal data
• The right to access your personal data
• The right to correction of inaccurate or misleading information
• The right to object to certain processing
• The right to deletion/erasure where applicable
• The right to restriction of processing where applicable
• The right to data portability where applicable
• The right to withdraw consent where consent is the basis for processing
• The right to complain about how your personal data is handled

The specific availability of each right depends on the circumstances and applicable law.

28. REQUESTING ACCESS TO YOUR INFORMATION

You may contact TotoCare Connect to request access to personal information that we hold about you.

We may need to verify your identity before responding.

This is necessary to prevent personal information from being disclosed to the wrong person.

Where a request concerns information about a child, we may require evidence that the requester has the appropriate parental or guardianship authority.

29. CORRECTING YOUR INFORMATION

If information held by TotoCare Connect is inaccurate or incomplete, you may request correction.

We may ask for reasonable supporting information where necessary to verify the requested correction.

30. DELETION REQUESTS

You may request deletion of personal information where applicable.

Deletion may not be immediate where TotoCare Connect has a lawful reason to retain information, including:

• Legal obligations
• Financial records
• Safety investigations
• Fraud prevention
• Dispute resolution
• Establishing or defending legal claims
• Legitimate regulatory requirements

Where deletion is not possible, we will explain the applicable reason where appropriate.

31. MARKETING COMMUNICATIONS

TotoCare Connect may send promotional communications where permitted by applicable law.

You can unsubscribe from promotional communications through the available unsubscribe mechanism or by contacting us.

Operational communications relating to:

• Bookings
• Payments
• Security
• Safety
• Account access
• Verification
• Service changes

are not promotional communications and may continue where necessary to provide the service.

TotoCare Connect does not sell personal data to advertisers.

32. AUTOMATED MATCHING AND HUMAN OVERSIGHT

TotoCare Connect may use automated rules to help identify and rank assistants who may be suitable for a childcare booking.

Matching may consider factors such as:

• Service eligibility
• Child age experience
• Availability
• Reliability
• Relevant experience
• Location suitability
• Previous family continuity
• Professional tier
• Performance information

Matching is intended to support operational decision-making.

TotoCare Connect maintains human oversight of assignment decisions through its administrative matching processes.

An assistant's matching score is not a general safety score, personality score or assessment of their worth.

Parents do not receive access to internal matching scores.

33. CHILD SAFETY AND PRIVACY

TotoCare Connect recognises that information relating to children requires additional protection.

We therefore seek to:

• Minimise children's data collection
• Limit access to children's information
• Use children's information only for legitimate purposes
• Avoid unnecessary public disclosure
• Protect children's home and school information
• Limit access to care instructions
• Apply appropriate safeguards to health information
• Restrict children's photographs and media
• Retain information only as necessary
• Design systems with children's safety and privacy in mind

Parents and guardians should avoid providing unnecessary information about a child through free-text fields, messages or attachments.

34. PHOTOGRAPHS, VIDEO AND AUDIO

TotoCare Connect may receive photographs, video or audio where users voluntarily submit them for legitimate purposes such as:

• Profile creation
• Identity verification
• Training
• Incident reporting
• Customer support
• Evidence
• Service administration

Such media will not be used for unrelated purposes merely because it has been submitted to TotoCare Connect.

We will apply appropriate access restrictions to media containing children, identity information or sensitive circumstances.

TotoCare Connect will not use children's photographs for advertising or promotional purposes without the appropriate lawful basis and required consent/authorisation.

35. ACCOUNT SECURITY

You are responsible for keeping your authentication information and device reasonably secure.

If you believe that:

• Your account has been compromised
• Your OTP has been exposed
• Someone has accessed your account without permission
• Your phone number has been compromised

you should contact TotoCare Connect immediately.

TotoCare Connect may temporarily restrict an account where necessary to protect the account holder, a child, another user or the Platform.

36. DATA BREACHES AND SECURITY INCIDENTS

TotoCare Connect maintains procedures for identifying, investigating, containing and responding to personal data breaches.

Where a breach creates obligations to notify affected individuals or a regulator, TotoCare Connect will make the required notifications in accordance with applicable law.

Where appropriate, users may receive information about:

• What happened
• What information may have been affected
• What TotoCare Connect has done
• What users should do
• Where to obtain further information

37. CHILDCARE SERVICE PROVIDERS AND DATA CONFIDENTIALITY

TotoCare Connect Child & Home Assistants may receive information about families and children solely because they have been assigned to provide childcare.

Assistants are expected to:

• Keep family information confidential
• Not photograph or record children without appropriate authorisation
• Not share family addresses
• Not publish information about families
• Not disclose children's routines
• Not disclose health information
• Not use family information for unrelated purposes
• Not retain family information unnecessarily after the booking
• Follow TotoCare Connect safety and privacy requirements

Unauthorised disclosure may result in suspension, removal from the Platform or other appropriate action.

38. ADMINISTRATIVE ACCESS

TotoCare Connect administrators may have access to information required to operate the service.

Administrative access is controlled according to role and responsibility.

For example:

• Operations personnel may need booking information
• Finance personnel may need payment and earnings information
• Safety personnel may need incident information
• Verification personnel may need identity and qualification information

No administrator should access personal information merely out of curiosity.

Access to sensitive areas may be logged and reviewed.

39. CHILDCARE SERVICE PARTNERS AND THIRD PARTIES

If TotoCare Connect introduces additional service partners, integrations or features that materially change how personal data is processed, we may update this Privacy Policy and provide additional notices where required.

Users should review the privacy policies of third-party services where those services independently determine how they process personal data.

40. DATA USED FOR ANALYTICS AND IMPROVEMENT

TotoCare Connect may analyse service information to understand:

• Booking patterns
• Service demand
• Assistant availability
• Matching effectiveness
• Cancellation patterns
• Platform performance
• Safety trends
• Operational performance

Where practical, TotoCare Connect will use aggregated, anonymised or pseudonymised information for analytics rather than directly identifying individuals.

We will not use children's identifiable information for unrelated commercial profiling.

41. DATA USED FOR FRAUD AND SECURITY PREVENTION

TotoCare Connect may process information to identify and prevent:

• Account takeover
• Identity fraud
• Payment fraud
• False identity information
• Manipulation of bookings
• Abuse of the Platform
• Unauthorised access
• Repeated fraudulent activity

Where fraud or security concerns are identified, access to some services may be temporarily restricted while the matter is reviewed.

42. INFORMATION YOU PROVIDE ABOUT OTHER PEOPLE

You should only provide another person's personal information where you have a lawful basis or appropriate authority to do so.

This is particularly important when providing information about:

• Children
• Emergency contacts
• References
• Family members
• Other household members

By providing such information, you confirm that you are authorised to provide it for the stated purpose where such authorisation is required.

43. DATA ACCURACY

TotoCare Connect seeks to maintain accurate and current personal information.

You should notify us where important information changes, particularly:

• Phone number
• Email
• Emergency contact
• Child information
• Relevant care requirements
• Assistant qualifications
• Assistant identity information
• Payout information

44. PRIVACY OF FAMILY ADDRESSES

Family addresses are particularly sensitive because they identify locations where children may be present.

TotoCare Connect therefore treats booking addresses as confidential information.

Addresses should only be accessible to people who require them for legitimate operational purposes.

They should not be displayed publicly or included unnecessarily in notifications, URLs, analytics or logs.

45. PRIVACY OF ASSISTANT INFORMATION

TotoCare Connect also protects assistants' personal information.

Information such as:

• Identification documents
• Personal phone numbers
• Home addresses
• Identity verification information
• Biometric information
• Police/background information
• References
• Sensitive safety records

will not be publicly displayed.

Parents receive only the assistant information reasonably necessary to make and manage a childcare booking.

46. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time.

Changes may be made because of:

• Changes to the Platform
• New services
• Changes to applicable law
• Changes to our data processing
• Changes to security practices
• Regulatory guidance
• Operational requirements

When changes are material, we will provide an appropriate notice.

The "Last Updated" date at the beginning of this policy will indicate when the policy was most recently revised.

47. CONTACTING TOTOCARE CONNECT ABOUT PRIVACY

If you have questions, concerns or requests relating to your personal data, contact:

TotoCare Connect

Legal entity: TotoCare Connect Ltd

Privacy/Data Protection Contact: hello@totocareconnect.online

Data Protection Officer/Responsible Contact: Data Protection Officer

Physical Address: Paramount Plaza, 4th Floor - Kipande Road, Nairobi.

Telephone: +254 111 869 444

When making a privacy request, please provide enough information for us to understand the request.

We may need to verify your identity before processing certain requests.

48. COMPLAINTS

If you believe that TotoCare Connect has handled your personal data inappropriately, we encourage you to contact us first so that we can investigate and address the concern.

You may also have the right to lodge a complaint with the Office of the Data Protection Commissioner (ODPC) or another competent authority in accordance with applicable law.

49. GOVERNING LAW

This Privacy Policy is intended to operate in accordance with the applicable laws of Kenya, including the Data Protection Act, 2019 and applicable regulations and guidance.

Where another law applies to a particular processing activity, TotoCare Connect will comply with the applicable legal requirements.

50. OUR PRIVACY PROMISE

TotoCare Connect exists to help families access dependable childcare.

That responsibility extends to the information entrusted to us.

We will therefore seek to ensure that:

We collect only what we need.

We use it for legitimate purposes.

We protect information about children with particular care.

We limit who can access sensitive information.

We do not sell personal data.

We do not use private family information as a marketplace commodity.

We do not continuously track people simply because technology allows us to.

We retain information only for as long as reasonably necessary.

We give people meaningful control over their personal information.

Privacy and child safety are built into TotoCare Connect — not added afterwards.