Privacy Policy

Effective date: 13 June 2026 Website: https://elitemotionluxury.com/ Company: EliteMotion Luxury Limited Business: Luxury car hire, self-drive car hire, chauffeur services, and related transport services in Kenya.

EliteMotion Luxury Limited ("EliteMotion", "we", "us", or "our") respects your privacy. This Privacy Policy explains how we collect, use, store, share, and protect your personal data when you visit our website, contact us, request a quote, book a vehicle, use our car hire services, or communicate with us through email, social media, or other official channels.

This Privacy Policy is intended to comply with the Kenya Data Protection Act, 2019, its related regulations, and other applicable data protection laws.

1. Who We Are

EliteMotion Luxury Limited provides premium car hire services in Kenya, including self-drive vehicles, chauffeur services, airport delivery, home delivery, office delivery, short-term rentals, long-term rentals, corporate car hire, and related support services.

Contact details:

• Email: [email protected]
• Website: https://elitemotionluxury.com/

For privacy-related questions, requests, or complaints, contact us using the details above.

2. Scope of This Privacy Policy

This Privacy Policy applies to personal data we collect through:

• Our website
• Booking forms
• Contact forms
• SMS messages
• Emails
• Social media platforms
• Online advertisements
• Vehicle rental agreements
• Vehicle delivery and return processes
• Customer support interactions
• Payment and billing processes
• Vehicle safety, tracking, recovery, and incident management processes

This Privacy Policy does not apply to third-party websites or platforms that we do not control.

3. Personal Data We Collect

We may collect different types of personal data depending on how you interact with us.

3.1 Identity and Contact Information

This may include:

• Full name
• Email address
• National ID number
• Passport number
• Driving licence details
• Company name, where applicable
• Billing address
• Delivery address
• Emergency contact details, where needed

3.2 Booking and Rental Information

This may include:

• Vehicle selected
• Rental dates and times
• Pick-up location
• Drop-off location
• Destination or travel route, where needed for service planning
• Self-drive or chauffeur preference
• Special requests
• Airport delivery details
• Home, hotel, or office delivery details
• Rental agreement details
• Vehicle handover records
• Vehicle return records
• Customer support notes related to a booking

3.3 Verification Documents

For car hire safety, contract, and fraud-prevention purposes, we may request documents such as:

• Driving licence
• National ID
• Passport
• Visa or entry stamp, where applicable
• Company authorization letter, for corporate bookings
• Other documents reasonably required to confirm identity, eligibility, or authority to hire or drive a vehicle

3.4 Payment and Transaction Information

This may include:

• Amount paid
• Payment method
• M-Pesa transaction details
• Bank transfer confirmation
• Invoice details
• Receipt details
• Refund details
• Outstanding balances
• Penalties
• Damage charges
• Traffic fine or claim-related payments

We do not intentionally collect or store full payment card details unless this is handled through a secure payment provider.

3.5 Communication Records

When you contact us, we may keep records of:

• SMS messages
• Emails
• Social media messages
• Website form submissions
• Customer support conversations
• Complaint records
• Feedback records

3.6 Website, Device, Cookie, and Analytics Data

When you use our website, we may collect:

• IP address
• Browser type
• Device type
• Operating system
• Pages visited
• Time spent on the website
• Referring website
• Approximate location based on IP address
• Date and time of visit
• Cookie IDs
• Pixel IDs
• Advertising identifiers
• Click IDs
• Website form events
• Quote request events
• Booking-related website actions
• Analytics and advertising data

3.7 Vehicle, Safety, Tracking, and Incident Data

Where necessary for vehicle security, contract management, and incident handling, we may collect:

• Vehicle condition photos or videos during handover and return
• Accident or incident reports
• Police abstract details, where applicable
• Traffic offence or fine information
• Vehicle recovery information
• Breakdown reports
• Vehicle location or tracking data where a vehicle has security or tracking technology installed

Vehicle tracking data, where used, is mainly used for vehicle safety, theft prevention, vehicle recovery, emergency support, rental contract enforcement, and protection of our vehicles.

4. How We Collect Personal Data

We may collect personal data when you:

• Visit our website
• Fill in a booking form
• Fill in a contact form
• Request a quote
• Book a vehicle
• Contact us by email, SMS, social media, or another official channel
• Visit our office
• Sign a rental agreement
• Provide documents for verification
• Make a payment
• Use a hired vehicle
• Receive or return a vehicle
• Report an accident, breakdown, loss, delay, or other incident
• Interact with our online adverts
• Accept or manage cookies on our website
• Interact with analytics or advertising tools used on our website

We may also receive personal data from third parties such as:

• Corporate clients booking on behalf of employees, guests, or directors
• Chauffeurs or service providers
• Vehicle delivery or recovery teams
• Payment providers
• Law enforcement or public authorities, where lawful
• Referral partners
• Travel agents or hotel partners, where applicable
• Advertising and analytics platforms, where applicable

5. Why We Use Your Personal Data

We use personal data for lawful and legitimate business purposes.

6. Compliance with Kenya Data Protection Law

EliteMotion Luxury Limited processes personal data in accordance with the Kenya Data Protection Act, 2019 and applicable data protection regulations.

Where required by law, we will maintain registration with the Office of the Data Protection Commissioner as a data controller and/or data processor.

We will take reasonable steps to ensure that personal data is:

• Processed lawfully, fairly, and transparently
• Collected for specific, clear, and legitimate purposes
• Limited to what is necessary
• Accurate and kept up to date where required
• Stored only for as long as necessary
• Protected using reasonable security safeguards
• Processed in line with your rights under applicable data protection law

You may contact us about your personal data using the contact details in this Privacy Policy. You also have the right to lodge a complaint with the Office of the Data Protection Commissioner in Kenya if you believe your personal data has been handled unlawfully.

7. Cookies, Pixels, Analytics, and Advertising Tools

Our website uses cookies, pixels, tags, scripts, local storage, server-side events, device identifiers, and similar technologies.

Some tracking technologies are necessary for the website to work. Others help us understand how visitors use our website, measure the performance of our adverts, improve our services, and show more relevant marketing.

7.1 Tools We Use

We use, or may use, the following third-party analytics and marketing tools:

• Google tools, including Google Analytics, Google Tag Manager, Google Ads, and related Google measurement tools
• Meta tools, including Meta Pixel, Meta Events Manager, Meta Conversions API, Facebook, Instagram, and related Meta Business Tools
• TikTok tools, including TikTok Pixel, TikTok Events API, TikTok Ads Manager, and related TikTok for Business tools

These tools may collect or receive information from our website, including:

• IP address
• Browser type
• Device type
• Operating system
• Page URL
• Referring website
• Pages viewed
• Buttons clicked
• Forms started or submitted
• Quote requests
• Booking-related website actions
• Date and time of visit
• Approximate location based on IP address
• Cookie IDs
• Pixel IDs
• Click IDs
• Advertising identifiers
• User agent information
• Campaign source, advert, or referral information
• Hashed contact details, such as email address, where advanced matching or server-side event tracking is enabled and allowed by law

We do not intentionally send Google, Meta, TikTok, or similar advertising platforms copies of your National ID, passport, driving licence, payment card details, vehicle tracking data, rental agreement copies, private messages, or other sensitive documents.

7.2 Why We Use These Tools

We use analytics and marketing tools to:

• Measure website traffic
• Understand which pages visitors use
• Improve our website and booking process
• Measure advert performance
• Understand whether adverts lead to enquiries or bookings
• Prevent duplicate adverts where possible
• Create marketing reports
• Show relevant adverts on Google, Facebook, Instagram, TikTok, and related platforms
• Retarget visitors who have interacted with our website, where allowed by law
• Improve our advertising campaigns

7.3 Google Analytics and Google Tools

We use Google Analytics and related Google tools to understand how visitors use our website and to measure website and advertising performance.

Google may receive information from our website, such as your IP address, page URL, browser information, device information, cookie information, and website activity information. Google may use this information according to Google's own privacy terms and settings.

You can learn more from Google's pages:

• Google Privacy Policy: https://policies.google.com/privacy
• How Google uses information from sites and apps: https://policies.google.com/technologies/partner-sites
• Google Analytics opt-out browser add-on: https://tools.google.com/dlpage/gaoptout

7.4 Meta Pixel and Meta Business Tools

We use Meta tools, including Meta Pixel, to measure activity on our website and to understand the performance of adverts on Facebook, Instagram, and other Meta services.

Meta may receive website event information, such as page views, button clicks, form submissions, quote requests, booking-related actions, browser details, device details, cookie information, and advertising identifiers.

Meta may use this information according to Meta's own privacy terms and settings.

You can learn more from Meta's pages:

• Meta Privacy Policy: https://www.facebook.com/privacy/policy/
• Meta Business Tools Terms: https://www.facebook.com/legal/technology_terms
• Meta Privacy Centre: https://www.facebook.com/privacy/center/

7.5 TikTok Pixel and TikTok Business Tools

We use TikTok tools, including TikTok Pixel, to measure website activity and the performance of adverts on TikTok.

TikTok may receive website event information, such as page views, button clicks, form submissions, quote requests, booking-related actions, IP address, browser information, device information, cookie information, user agent information, and advertising identifiers.

TikTok may use this information according to TikTok's own privacy terms and settings.

You can learn more from TikTok's pages:

• TikTok Privacy Policy: https://www.tiktok.com/legal/privacy-policy
• TikTok Pixel information: https://ads.tiktok.com/help/article/tiktok-pixel
• TikTok Business Products Data Terms: https://ads.tiktok.com/i18n/official/policy/product

7.6 Server-Side Event Tracking

We may use server-side event tracking tools, such as Meta Conversions API or TikTok Events API, where enabled.

Server-side event tracking allows some website or booking-related events to be sent from our server to analytics or advertising platforms. This may improve measurement where browser cookies are blocked or limited.

Where we use server-side event tracking, we will take reasonable steps to limit the data shared to what is necessary for analytics, campaign measurement, fraud prevention, and advertising performance.

7.7 Cookie Choices

Where required by law, we will ask for your consent before using non-essential analytics or marketing cookies.

You may control cookies by:

• Using our cookie banner or cookie settings tool, where available
• Blocking or deleting cookies through your browser settings
• Adjusting your privacy settings on Google, Facebook, Instagram, TikTok, or other platforms
• Contacting us to ask questions about our use of cookies and tracking tools

Blocking cookies may affect some website features or reduce our ability to understand how visitors use the website.

7.8 Types of Cookies We Use

7.9 No Sale of Personal Data

We do not sell your personal data.

However, when we use Google, Meta, TikTok, or similar analytics and advertising tools, some website activity data may be shared with those platforms for analytics, measurement, advertising, retargeting, and campaign optimisation purposes, as described in this Privacy Policy.

8. Marketing Communications

We may send you marketing messages about our vehicles, offers, discounts, updates, or services where permitted by law.

Marketing messages may be sent through:

• Email
• SMS
• WhatsApp
• Social media platforms
• Online advertising platforms

You can opt out of marketing messages at any time by:

• Replying "STOP" or using a similar opt-out instruction
• Contacting us at [email protected]
• Using any unsubscribe option provided in the message
• Adjusting your privacy or advert settings on the relevant platform

Even if you opt out of marketing, we may still send service-related messages about active bookings, payments, vehicle delivery, vehicle return, safety issues, legal matters, or customer support.

9. When We Share Personal Data

We do not sell your personal data.

We may share your personal data with trusted third parties where necessary, including:

• Employees, agents, chauffeurs, and customer support staff
• Vehicle delivery and pick-up teams
• Payment providers, banks, or M-Pesa-related service providers
• Roadside assistance providers
• Garages, mechanics, or vehicle recovery providers
• IT service providers
• Website hosting providers
• Booking system providers
• CRM providers
• Cloud storage providers
• Marketing providers
• Analytics and advertising partners, including Google, Meta, TikTok, and similar platforms
• Professional advisers, such as lawyers, auditors, and accountants
• Police, courts, regulators, tax authorities, or other public authorities where required by law
• Corporate clients, where a booking is made under a company account

We only share personal data where there is a valid reason and appropriate safeguards.

10. International Data Transfers

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

This may include providers such as website hosting providers, cloud storage providers, analytics platforms, advertising platforms, payment providers, CRM providers, or communication tools.

Where personal data is transferred outside Kenya, we will take reasonable steps to ensure that the data is protected in line with applicable data protection laws. This may include using service providers with proper security measures, contractual safeguards, or other lawful transfer mechanisms.

11. How Long We Keep Personal Data

We keep personal data only for as long as reasonably necessary for the purpose it was collected.

Retention periods may depend on:

• The type of booking or service
• Legal, tax, accounting, and contract requirements
• Whether there is an active dispute, claim, accident, damage issue, unpaid amount, or investigation
• The need to prevent fraud or protect our vehicles
• Customer support and business record needs
• Marketing consent and opt-out records
• Website analytics and advertising reporting needs

As a general guide:

• Enquiry records may be kept for a reasonable period for follow-up and customer support.
• Rental agreements, payment records, and related business records may be kept for longer where required for tax, accounting, legal, or contract purposes.
• Verification documents are kept only for as long as needed for verification, legal, contract, fraud-prevention, or dispute purposes.
• Vehicle handover and return records may be kept for contract and dispute-management purposes.
• Marketing contact records may be kept until you opt out or request deletion, unless we need to keep a suppression record to respect your opt-out.
• Cookie and analytics data may be kept according to the retention settings of the relevant analytics or advertising tools.

When personal data is no longer needed, we will delete it, anonymise it, or securely archive it where appropriate.

12. How We Protect Personal Data

We use reasonable technical and organisational measures to protect personal data from loss, misuse, unauthorised access, disclosure, alteration, or destruction.

These measures may include:

• Restricted access to personal data
• Password protection and account controls
• Secure storage of documents
• Staff confidentiality requirements
• Secure communication where appropriate
• System monitoring and access logs
• Data backup and recovery processes
• Review of service providers where appropriate
• Limiting access to verification documents
• Limiting the personal data shared with analytics and advertising platforms
• Using secure systems where reasonably possible

No system is completely secure. You should avoid sending unnecessary sensitive information through insecure channels.

13. Your Rights

Subject to applicable law, you may have the right to:

• Be informed about how your personal data is used
• Access personal data we hold about you
• Request correction of false, inaccurate, outdated, or misleading data
• Request deletion of false, misleading, unnecessary, or unlawfully processed data
• Object to the processing of all or part of your personal data
• Withdraw consent where processing is based on consent
• Object to direct marketing
• Request restriction of processing in certain cases
• Request transfer of your personal data where applicable
• Lodge a complaint with the Office of the Data Protection Commissioner in Kenya

To exercise your rights, contact us at:

Email: [email protected] We may need to verify your identity before responding to a request.

14. Consequences of Not Providing Personal Data

Some personal data is required for us to provide car hire services.

If you do not provide required information, we may be unable to:

• Respond to your enquiry
• Confirm your booking
• Verify your identity
• Verify your driving eligibility
• Deliver a vehicle
• Provide self-drive or chauffeur services
• Process payment
• Issue receipts or invoices
• Support accident, safety, or security processes
• Comply with legal or regulatory requirements

15. Children's Privacy

Our car hire services are intended for people who are legally able to enter into a rental agreement and, where applicable, legally allowed to drive.

We do not knowingly collect personal data from children for car hire bookings unless the information is provided by a parent, guardian, or authorised adult for a lawful and necessary purpose.

If you believe a child has provided personal data to us without proper authority, contact us so that we can review and take appropriate action.

16. Vehicle Tracking and Safety

Some vehicles may have tracking, anti-theft, recovery, or security technology installed.

Where vehicle tracking is used, it may help us:

• Protect the vehicle
• Prevent theft
• Recover a vehicle
• Respond to emergencies
• Confirm vehicle location during an active rental
• Manage breakdowns
• Investigate contract breaches
• Handle disputes, accidents, or incidents

Vehicle tracking is not intended to be used for unnecessary surveillance. We will use tracking information only where there is a valid business, safety, legal, or contract reason.

Customers should not remove, disable, damage, interfere with, or attempt to block vehicle tracking or safety systems.

17. Third-Party Links

Our website may contain links to third-party websites, social media pages, payment services, map services, WhatsApp, or other platforms.

We are not responsible for the privacy practices of third-party websites or platforms. You should read their privacy policies before sharing personal data with them.

18. Social Media and WhatsApp

When you contact us through WhatsApp, Instagram, Facebook, TikTok, or other social media platforms, your use of those platforms is also governed by their own terms and privacy policies.

We may use the information you send through these channels to:

• Respond to enquiries
• Manage bookings
• Provide customer support
• Send booking updates
• Send service messages
• Keep business records
• Handle complaints or disputes
• Send marketing messages where permitted by law

Avoid sending unnecessary sensitive information through social media or messaging platforms.

19. Automated Decision-Making

We do not intend to make decisions about you based solely on automated processing where such decisions would have a legal or similarly significant effect on you.

If this changes, we will update this Privacy Policy and provide any notices required by law.

20. Data Breach Handling

If we become aware of a personal data breach that may affect your rights or freedoms, we will take reasonable steps to contain, investigate, and address the breach.

Where required by law, we will notify affected individuals and/or the Office of the Data Protection Commissioner.

21. Data Protection Impact Assessments

Where required by law, we may carry out a data protection impact assessment for processing activities that may present a high risk to individuals.

This may apply to activities involving sensitive personal data, large-scale processing, systematic monitoring, new technologies, vehicle tracking, or other processing that requires extra review under applicable law.

22. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

When we update it, we will revise the effective date above. The updated version will apply from the date it is posted on our website unless stated otherwise.

You should review this page regularly to stay informed about how we handle personal data.

23. Contact Us

For questions, requests, or complaints about this Privacy Policy or how we handle personal data, contact us at:

EliteMotion Luxury Limited Email: [email protected] Website: https://elitemotionluxury.com/

24. Complaints and the Data Commissioner

If you have a privacy concern, please contact EliteMotion first so we can review and respond to the issue. We may need to verify your identity before acting on a privacy request.

If you are not satisfied with our response, you may have the right to contact the Office of the Data Protection Commissioner in Kenya or use another remedy available under applicable law.

25. Practical Privacy Notes for Car Hire Customers

To help us protect your information, please avoid sending unnecessary sensitive documents through public comments, social media posts, or unsecured channels. Use official EliteMotion contact channels for booking documents, payment confirmations, licence details, incident reports, and identity verification.

If your booking involves other drivers or passengers, share only the information needed for booking, safety, handover, or customer support.