Privacy Policy

1. Introduction

Pam Golding Properties Kenya ("Pam Golding Properties Kenya", "we", "our" or "us") is committed to protecting the privacy and personal data of our clients, prospective clients, property owners, landlords, tenants, buyers, sellers, service providers, employees, business partners and visitors to our website.

As a leading real estate company, we recognise the importance of safeguarding personal information entrusted to us throughout the course of our business. Whether you are buying, selling, leasing, renting, managing property, requesting a valuation or simply making an enquiry, we are committed to processing your personal data responsibly, transparently and in accordance with applicable law.

This Privacy Policy explains how we collect, use, store, disclose and protect your personal data and outlines your rights regarding the information we hold about you.

Our processing of personal data is governed by:

  • The Data Protection Act, No. 24 of 2019 (Kenya)
  • The Data Protection (General) Regulations, 2021
  • Any other applicable Kenyan laws governing privacy and electronic communications.

By using our website, engaging our services or providing us with your personal information, you acknowledge that you have read and understood this Privacy Policy.

2. Scope of this Privacy Policy

This Privacy Policy applies to all personal data processed by Pam Golding Properties Kenya through:

  • our website;
  • our offices;
  • email correspondence;
  • telephone conversations;
  • social media platforms;
  • online property portals;
  • property enquiries;
  • property sales;
  • property purchases;
  • residential and commercial leasing;
  • property management;
  • valuations;
  • recruitment activities;
  • events and exhibitions;
  • marketing campaigns; and
  • any other services offered by Pam Golding Kenya.

This Policy applies whether personal data is collected electronically, verbally or in paper format.

3. Who we are

Pam Golding Properties Kenya is a real estate company providing professional property services throughout Kenya.

Our services include, but are not limited to:

  • Residential Property Sales
  • Residential Letting
  • Commercial Property Sales
  • Commercial Leasing
  • Property Management
  • Property Valuation
  • Land Sales
  • Development Sales and Marketing
  • Investment Advisory
  • Property Consultancy
  • Holiday and Lifestyle Property Services

For purposes of the Kenya Data Protection Act, Pam Golding Properties Kenya generally acts as a Data Controller, determining how and why personal data is processed. In certain circumstances, we may also act as a Data Processor on behalf of clients or business partners.

4. Definitions

For purposes of this Privacy Policy:

Personal Data means any information relating to an identified or identifiable natural person, including information that can directly or indirectly identify an individual.

Sensitive Personal Data includes information relating to a person's:

  • health;
  • biometric data;
  • genetic data;
  • race or ethnic origin where required by law;
  • religious or philosophical beliefs where voluntarily provided;
  • financial information;
  • or any other category recognised as sensitive under Kenyan law.

Processing means any operation performed on personal data including collecting, recording, organising, storing, updating, using, sharing, transmitting, deleting or destroying personal data.

Data Subject means the individual to whom the personal data relates.

Consent means any freely given, specific, informed and unambiguous indication of a person's agreement to the processing of their personal data.

5. Personal data we collect

Depending on the services you request, we may collect various categories of personal data.

Personal identification information

  • Full name
  • National Identification Number
  • Passport Number
  • Alien Identification Number (where applicable)
  • Date of birth
  • Nationality
  • Gender (where required)
  • Photographs
  • Signature

Contact information

  • Mobile phone number
  • Alternative telephone number
  • Email address
  • Postal address
  • Physical address
  • County or region of residence

Property information

  • Property ownership details
  • Property preferences
  • Purchase requirements
  • Rental preferences
  • Investment interests
  • Property portfolio information
  • Property viewing history
  • Valuation requests
  • Property transaction records

Financial information

  • Bank account information
  • Payment records
  • Mortgage information
  • Financing arrangements
  • Income verification documents
  • Credit information where authorised by law
  • KRA PIN
  • Tax compliance information

Identity verification information

  • Copies of identity documents
  • Passport copies
  • Proof of address
  • Company registration documents
  • Directors' information
  • Beneficial ownership information
  • Anti-money laundering verification documents
  • Know Your Customer (KYC) documentation

Communications

We may retain records of:

  • Emails
  • Telephone conversations
  • Website enquiries
  • WhatsApp communications
  • SMS messages
  • Live chat conversations
  • Meeting notes
  • Property viewing feedback

Website and technical information

When you visit our website, we may automatically collect:

  • IP address
  • Browser type
  • Device information
  • Operating system
  • Referral source
  • Website usage information
  • Cookies
  • Session information
  • Pages visited
  • Time spent on our website

Marketing preferences

  • Newsletter subscriptions
  • Property alerts
  • Preferred locations
  • Property budgets
  • Investment interests
  • Marketing communication preferences

6. How we collect personal data

Information you provide directly

This includes information you voluntarily provide when you:

  • enquire about a property;
  • request a property valuation;
  • instruct us to sell or lease your property;
  • register on our website;
  • subscribe to newsletters;
  • complete online forms;
  • attend our events;
  • apply for employment;
  • contact our offices;
  • engage our agents;
  • request property management services; or
  • enter into agreements with us.

Information collected automatically

When you interact with our website, we may automatically collect technical information through cookies and similar technologies to improve website functionality, analyse usage and enhance your experience.

Information from third parties

Where permitted by law, we may receive personal data from:

  • property owners;
  • landlords;
  • tenants;
  • buyers;
  • sellers;
  • financial institutions;
  • mortgage providers;
  • legal advisers;
  • valuers;
  • property developers;
  • government registries;
  • public records;
  • credit reference bureaus;
  • regulatory authorities;
  • business partners; and
  • publicly available sources.

We only collect such information where there is a lawful basis for doing so.

CCTV monitoring

For the safety and security of our employees, clients and visitors, CCTV surveillance may operate at our offices and certain managed properties. Recorded footage may be used for security, crime prevention and investigation purposes and will only be retained for as long as reasonably necessary or as required by law.

Recruitment

If you apply for employment with Pam Golding Kenya, we may collect personal data necessary to assess your suitability for employment. This may include your curriculum vitae (CV), employment history, educational qualifications, professional references and other relevant information provided during the recruitment process.

7. Lawful basis for processing personal data

Pam Golding Properties Kenya processes personal data only where there is a lawful basis to do so in accordance with the Data Protection Act, 2019.

We may process your personal data where:

  • You have provided your consent for one or more specific purposes;
  • Processing is necessary for the performance of a contract or to take steps at your request before entering into a contract;
  • Processing is required to comply with a legal or regulatory obligation;
  • Processing is necessary to protect your vital interests or those of another individual;
  • Processing is necessary for the performance of a task carried out in the public interest; or
  • Processing is necessary for our legitimate business interests, provided that those interests do not override your rights and freedoms.

Where we rely on your consent, you may withdraw it at any time by contacting us. Withdrawal of consent will not affect the lawfulness of processing carried out before the withdrawal.

8. How we use your personal data

We use personal data only for legitimate business purposes connected with the delivery of our services and the operation of our business. Your personal data may be used to:

Property transactions

  • Facilitate the purchase, sale, leasing or rental of residential, commercial and mixed-use properties;
  • Introduce buyers, sellers, landlords and tenants;
  • Arrange property viewings and inspections;
  • Prepare offers, agreements and related documentation;
  • Coordinate negotiations between parties;
  • Manage property transfers and transaction processes.

Property management

  • Manage tenancy relationships;
  • Collect rent and other payments;
  • Coordinate repairs and maintenance;
  • Respond to tenant and landlord enquiries;
  • Manage service providers and contractors;
  • Conduct property inspections;
  • Resolve disputes where necessary.

Customer relationship management

  • Respond to enquiries;
  • Provide customer support;
  • Maintain accurate client records;
  • Improve customer service;
  • Understand your property requirements;
  • Recommend suitable properties or services.

Valuation and advisory services

  • Conduct property valuations;
  • Prepare valuation reports;
  • Provide market insights;
  • Assess investment opportunities;
  • Deliver consultancy services.

Legal and regulatory compliance

  • Verify identity;
  • Conduct Know Your Customer (KYC) procedures;
  • Comply with anti-money laundering and counter-terrorism financing obligations;
  • Meet tax and accounting requirements;
  • Maintain statutory records;
  • Respond to lawful requests from government authorities, regulators or courts.

Recruitment

  • Assess applications;
  • Conduct interviews;
  • Verify qualifications and references;
  • Perform background checks where permitted by law;
  • Communicate recruitment outcomes.

Website administration

  • Operate and improve our website;
  • Analyse website traffic and user behaviour;
  • Enhance website security;
  • Diagnose technical issues;
  • Improve user experience.

Business operations

  • Maintain internal records;
  • Conduct audits;
  • Manage risk;
  • Resolve disputes;
  • Investigate complaints;
  • Prevent fraud;
  • Protect our legal rights;
  • Improve our services.

9. Marketing communications

Pam Golding Properties Kenya may send you information about our properties, services, market reports, events, investment opportunities and other information that may be relevant to your property interests.

Marketing communications may be sent through:

  • Email;
  • SMS;
  • Telephone;
  • WhatsApp;
  • Social media platforms; or
  • Other electronic communication channels.

Where required by law, we will obtain your consent before sending direct marketing communications.

You may opt out of receiving marketing communications at any time by:

  • Clicking the unsubscribe link included in our emails;
  • Updating your communication preferences;
  • Contacting us directly using the contact details provided in this Privacy Policy.

Please note that even if you opt out of marketing communications, we may still contact you regarding ongoing property transactions, contractual obligations or important service-related notices.

10. Sharing and disclosure of personal data

Pam Golding Properties Kenya respects the confidentiality of your personal data and will not sell, rent or trade your personal information to third parties.

We may share personal data only where necessary to provide our services, comply with legal obligations or protect legitimate business interests. Your personal data may be shared with:

Members of the Pam Golding Group

Where necessary, information may be shared between Pam Golding offices, subsidiaries, franchisees and affiliated companies for the purposes of delivering consistent property services and maintaining client relationships.

Professional advisers

  • Advocates;
  • Auditors;
  • Accountants;
  • Tax advisers;
  • Valuers;
  • Surveyors;
  • Property consultants.

Financial institutions

  • Banks;
  • Mortgage providers;
  • Insurance providers;
  • Payment service providers.

Property developers

Where you express interest in a development or purchase directly from a developer, relevant information may be shared to facilitate the transaction.

Service providers

We may engage trusted third-party service providers who assist us in delivering our services, including providers of information technology, cloud hosting, website management, marketing platforms, customer relationship management systems, payment processing, document storage and security services.

These service providers are required to process personal data only on our instructions and in accordance with appropriate confidentiality and security obligations.

Government authorities

We may disclose personal data where required by law to:

  • Courts;
  • Law enforcement agencies;
  • The Office of the Data Protection Commissioner;
  • Kenya Revenue Authority;
  • Ministry of Lands, Public Works, Housing and Urban Development;
  • Land Registries;
  • Other competent regulatory or government authorities.

Other parties

Where necessary, we may also disclose personal data:

  • To protect our legal rights;
  • To investigate fraud or criminal activity;
  • To enforce contractual obligations;
  • To protect the safety of clients, employees or members of the public.

11. International transfers of personal data

Some of our service providers may store or process personal data outside Kenya.

Where personal data is transferred outside Kenya, Pam Golding Properties Kenya will ensure that appropriate safeguards are implemented in accordance with the Data Protection Act, 2019. These safeguards may include:

  • Transfers to jurisdictions with adequate levels of data protection;
  • Appropriate contractual clauses;
  • Data processing agreements;
  • Technical and organisational security measures;
  • Any other safeguards recognised under applicable law.

We will take reasonable steps to ensure that personal data transferred internationally receives a level of protection comparable to that required under Kenyan law.

12. Third-party websites and links

Our website may contain links to third-party websites, property portals or social media platforms for your convenience.

Pam Golding Properties Kenya is not responsible for the privacy practices, security measures or content of third-party websites. We encourage you to review the privacy policies of any external websites before providing personal information.

Your use of third-party websites is subject to their own terms and privacy policies.

13. Automated decision-making

Pam Golding Properties Kenya does not make decisions that produce legal or similarly significant effects based solely on automated processing of personal data.

Where technology is used to assist with property recommendations, customer analytics or marketing preferences, meaningful human oversight is maintained.

14. Data security

Pam Golding Properties Kenya is committed to protecting the confidentiality, integrity and availability of the personal data entrusted to us.

We maintain appropriate technical, administrative and physical safeguards designed to protect personal data against unauthorised access, disclosure, alteration, loss, misuse or destruction. Our security measures may include:

  • Secure information technology systems and networks;
  • Password-protected databases and user authentication controls;
  • Encryption of sensitive information where appropriate;
  • Firewalls and anti-malware protection;
  • Access controls based on business need;
  • Secure storage of physical records;
  • Staff training on data privacy and information security;
  • Confidentiality obligations for employees, contractors and service providers; and
  • Regular reviews of our security procedures and systems.

While we take reasonable steps to safeguard personal data, no method of electronic transmission or storage is completely secure. We therefore cannot guarantee absolute security, although we continually work to maintain industry-appropriate standards of protection.

If we become aware of a personal data breach that is likely to result in a risk to your rights or freedoms, we will respond promptly and, where required by law, notify the Office of the Data Protection Commissioner (ODPC) and affected individuals within the prescribed timelines.

15. Data retention

Pam Golding Properties Kenya retains personal data only for as long as necessary to fulfil the purposes for which it was collected, including to:

  • Provide our services;
  • Complete property transactions;
  • Manage contractual relationships;
  • Meet legal and regulatory obligations;
  • Resolve disputes;
  • Enforce our agreements; and
  • Protect our legitimate business interests.

The length of time we retain personal data depends on the nature of the information and the purpose for which it was collected.

When personal data is no longer required, we will securely delete, anonymise or destroy it in accordance with our internal retention procedures and applicable law. Where we are required by law to retain records for a specified period, we will do so before securely disposing of the information.

16. Your rights under the Kenya Data Protection Act

Subject to applicable law, you have the following rights regarding your personal data.

Right to be informed

You have the right to know how your personal data is collected, used, stored and shared.

Right of access

You may request confirmation as to whether Pam Golding Properties Kenya holds personal data about you and request access to that information.

Right to correction

If you believe any personal data we hold is inaccurate, incomplete or outdated, you may request that we correct or update it.

Right to erasure

You may request that we delete or anonymise your personal data where:

  • the information is no longer necessary for the purpose for which it was collected;
  • you withdraw consent where consent is the lawful basis for processing;
  • processing is unlawful; or
  • deletion is otherwise required by law.

Please note that we may be unable to delete certain information where we are legally required to retain it.

Right to object

You may object to the processing of your personal data where processing is based on our legitimate interests or where you believe your rights outweigh those interests.

Right to restrict processing

You may request that we temporarily restrict the processing of your personal data while concerns regarding its accuracy or lawful processing are being resolved.

Right to data portability

Where technically feasible and legally applicable, you may request a copy of your personal data in a structured, commonly used and machine-readable format.

Right to withdraw consent

Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent will not affect processing carried out before the withdrawal.

Exercising your rights

Requests relating to your personal data may be submitted using the contact details provided at the end of this Privacy Policy.

To protect your privacy, we may request proof of identity before responding to your request. We will respond within the timeframes required under applicable law.

17. Cookies and similar technologies

Our website uses cookies and similar technologies to improve functionality, enhance user experience and better understand how visitors use our website. Cookies may be used to:

  • Remember your preferences;
  • Improve website performance;
  • Analyse website traffic;
  • Personalise content;
  • Enhance security; and
  • Measure the effectiveness of our marketing activities.

Most web browsers automatically accept cookies. However, you may choose to disable or manage cookies through your browser settings. Please note that disabling cookies may affect certain features and functionality of our website.

Where required by law, we will seek your consent before placing non-essential cookies on your device.

18. Children's privacy

Our services are intended for individuals who are legally capable of entering into property transactions.

We do not knowingly collect personal data directly from children unless permitted or required by law, or where consent has been obtained from a parent or legal guardian.

If we become aware that personal data relating to a child has been collected without appropriate authorisation, we will take reasonable steps to delete or otherwise manage that information in accordance with applicable law.

19. Third-party service providers

Pam Golding Properties Kenya works with trusted third-party providers who support our operations, including providers of:

  • Cloud storage and hosting services;
  • Customer relationship management systems;
  • Property marketing platforms;
  • Email and communication services;
  • Website analytics;
  • Payment processing services;
  • Document management systems; and
  • Professional advisory services.

We require these providers to maintain appropriate security measures and process personal data only for authorised purposes and in accordance with applicable data protection laws.

20. Changes to this Privacy Policy

Pam Golding Properties Kenya may update this Privacy Policy from time to time to reflect:

  • Changes in applicable laws or regulations;
  • Changes to our services or business operations;
  • Technological developments;
  • Regulatory guidance; or
  • Improvements to our privacy practices.

Where material changes are made, we will publish the updated Privacy Policy on our website and revise the "Last Updated" date. Where required by law, we will notify affected individuals through appropriate communication channels.

We encourage you to review this Privacy Policy periodically to remain informed about how we protect your personal data.

21. Contact us

If you have any questions, requests or concerns regarding this Privacy Policy or our processing of your personal data, please contact:

Pam Golding Properties Kenya
Email: nairobi@pamgolding.co.ke
Telephone: +254 7 10 559 573

Postal address:
Sandton International Ltd (Pam Golding Properties)
10th Floor, Fortis Towers, Woodvale Grove
P.O. Box 66365-00800
Westlands, Nairobi

22. Complaints

If you believe that Pam Golding Properties Kenya has not handled your personal data in accordance with the Kenya Data Protection Act, 2019, we encourage you to contact us first so that we may have the opportunity to address your concerns.

If you remain dissatisfied with our response, you have the right to lodge a complaint with:

Office of the Data Protection Commissioner (ODPC)
Website: www.odpc.go.ke
Email: info@odpc.go.ke

The ODPC is responsible for overseeing compliance with Kenya's data protection laws and investigating complaints relating to the processing of personal data.

23. Acceptance of this Privacy Policy

By accessing our website, engaging our services or providing your personal data to Pam Golding Properties Kenya, you acknowledge that you have read and understood this Privacy Policy.

Where consent is required under applicable law, your continued use of our services or your express consent will constitute your agreement to the collection, use and processing of your personal data in accordance with this Privacy Policy.

Last updated: June 2026
Document owner: Sandton International Ltd (Pam Golding Properties)