Privacy Policy

1. Introduction

The Displaced Times ("we," "us," or "our") is an independent, non-partisan media organization co-owned by Refugee-Led Organizations. We are committed to protecting and respecting the privacy of every person who visits our website, subscribes to our newsletter, donates to our mission, or otherwise engages with our services.

This Privacy Policy describes the types of personal data we collect, the legal basis for processing that data, how we use and store it, your rights as a data subject, and the measures we take to protect your information. It applies to all users of our website, mobile applications, email communications, and any offline interactions where personal data is collected.

By accessing or using our services, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy. If you do not agree with this policy, please discontinue use of our services immediately.

2. Data Controller

The data controller responsible for your personal data is The Displaced Times, Ltd. For any questions concerning this policy or your personal data, you may contact us at:

3. What Data We Collect

We collect personal data only when it is necessary for the purposes described in this policy. The categories of data we may collect include:

Information you provide directly

• Contact information: name, email address, phone number, and WhatsApp number when you subscribe to our newsletter, apply to the Council of RLOs, or contact us directly.
• Donation information: email address, donation amount, and transaction reference when you make a financial contribution through our payment processor. We do not store credit card numbers, bank account details, or other financial instrument data on our servers.
• Council application data: full name, email, phone, role, country, location, organization name, community served, membership count, years active, registration status, funding source, governance structure, focus areas, languages spoken, motivation statement, and any other information provided in the application form.
• Communications: any messages, feedback, or correspondence you send to us via email or through our website.

Information collected automatically

• Device and browser information: IP address, browser type and version, operating system, device type, screen resolution, and preferred language settings.
• Usage data: pages visited, time spent on pages, referring URLs, click interactions, search queries performed on our site, and general navigation patterns.
• Language preferences: your selected language for our translation service, which is stored locally in your browser.

Information from third parties

• Payment confirmation data from our payment processing partner, including transaction status and reference numbers (but never your full card or banking details).

4. How We Use Your Data

We use the personal data we collect for the following purposes:

• Delivering our services: To provide you with access to our journalism, articles, audio content, and video broadcasts.
• Newsletter communications: To send you editorial updates, breaking news alerts, and organizational announcements if you have opted in to our mailing list. Every email includes an unsubscribe mechanism.
• Processing donations: To process your financial contributions securely through our payment processor, send donation receipts, and maintain financial records as required by law.
• Council applications: To evaluate applications from Refugee-Led Organizations seeking membership on our governing council, and to communicate with applicants about the status of their applications.
• Translation services: To translate content into your preferred language using our automated translation service. The text you view is sent to the translation service without any identifying information attached.
• Text-to-speech: To generate audio versions of articles using our text-to-speech service, improving accessibility for users who prefer to listen to content.
• Site improvement: To understand how visitors use our website, diagnose technical issues, improve user experience, and inform editorial decisions.
• Legal compliance: To comply with applicable laws, regulations, legal processes, or enforceable governmental requests.

5. Legal Basis for Processing

We process your personal data on the following lawful bases:

• Consent: When you subscribe to our newsletter, submit a council application, or make a donation, you provide explicit consent for us to process the data you submit for those specific purposes. You may withdraw your consent at any time.
• Legitimate interest: We have a legitimate interest in understanding how our website is used, preventing abuse, ensuring security, and improving our editorial outputs — provided these interests do not override your fundamental rights and freedoms.
• Legal obligation: We may process certain data to comply with financial reporting requirements, tax obligations, and other legal duties imposed by Kenyan law or international regulations that apply to our operations.
• Contractual necessity: When processing donation transactions, we process data as necessary to fulfill the transaction you have initiated.

6. Data Sharing & Third Parties

We do not sell, rent, or trade your personal data to any third party for marketing purposes. We share data only in the following limited circumstances:

• Payment processor: Our payment processor receives your email address and donation amount to process transactions securely. Our payment partner is PCI-DSS compliant and maintains its own privacy policy governing how it handles financial data.
• Translation and accessibility providers: Article text (without personal identifiers) is sent to third-party services for translation and text-to-speech features. These providers process data under enterprise data protection agreements.
• Hosting providers: Our website is hosted on infrastructure that may log standard access data (IP addresses, request timestamps) for security and operational purposes.
• Law enforcement: We may disclose personal data if required to do so by law, court order, or governmental regulation, or if we believe in good faith that such disclosure is necessary to protect the rights, property, or safety of The Displaced Times, our users, or the public.

7. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law:

• Newsletter subscriptions: Your email is retained until you unsubscribe. Upon unsubscription, your email is deleted from our mailing list within 30 days.
• Donation records: Transaction records are retained for a minimum of 7 years to comply with financial reporting and tax obligations under Kenyan law.
• Council applications: Application data is retained for the duration of council membership, plus 2 years following the end of membership. Unsuccessful applications are retained for 12 months to allow for re-evaluation, after which they are deleted.
• Usage data: Automatically collected browsing data is aggregated and anonymized within 90 days.

8. Your Rights

Depending on your jurisdiction, you may have the following rights with respect to your personal data. We honor these rights for all users regardless of location:

• Right of access: You may request a copy of the personal data we hold about you.
• Right to rectification: You may request correction of inaccurate or incomplete personal data.
• Right to erasure: You may request deletion of your personal data, subject to legal retention requirements.
• Right to restrict processing: You may request that we limit how we use your data in certain circumstances.
• Right to data portability: You may request that we provide your data in a structured, machine-readable format.
• Right to object: You may object to our processing of your personal data where we rely on legitimate interest as the legal basis.
• Right to withdraw consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, email us at privacy@displacedtimes.com. We will respond to your request within 30 days.

9. Cookies & Local Storage

Our website uses minimal cookies and browser local storage to ensure essential functionality:

• Language preference: We store your selected language in local storage so the site displays in your chosen language across sessions. This data never leaves your browser.
• Translation cache: Translated text is cached in browser memory during your session to reduce redundant API calls. This cache is cleared when you close your browser.

We do not use advertising cookies, tracking pixels, or third-party analytics cookies. We do not participate in cross-site tracking or behavioral advertising networks.

10. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

• All data transmitted between your browser and our servers is encrypted using TLS (Transport Layer Security).
• Payment processing is handled entirely by a PCI-DSS Level 1 compliant third-party payment processor. We never receive or store your full card details.
• Access to personal data within our organization is restricted to authorized personnel on a need-to-know basis.
• Security credentials and secrets are stored securely and are never exposed to the client-side browser.

While we take every reasonable precaution, no method of transmission over the Internet or electronic storage is completely secure. We cannot guarantee absolute security, but we are committed to maintaining the highest standards practicable for an organization of our scale.

11. International Data Transfers

Our operations are based in Kenya, but our services are used by people worldwide. Your personal data may be transferred to and processed in countries other than your country of residence, including:

• The United States (translation and text-to-speech services)
• Nigeria (payment processing infrastructure)

Where data is transferred internationally, we ensure that appropriate safeguards are in place, including reliance on service providers' data protection agreements, standard contractual clauses, and compliance with the Kenya Data Protection Act, 2019.

12. Children's Privacy

Our services are not directed at children under the age of 16. We do not knowingly collect personal data from children under 16. If we become aware that we have inadvertently collected personal data from a child under 16, we will take prompt steps to delete that data.

If you are a parent or guardian and believe your child has provided personal data to us, please contact us at privacy@displacedtimes.com so we can take appropriate action.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational needs. When we make material changes, we will:

• Update the Last Updated date at the top of this page.
• Post a notice on our website for a reasonable period of time.
• Where required by law, notify you by email if you are a registered subscriber.

Your continued use of our services after such changes constitutes your acceptance of the updated policy.

14. Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of the Republic of Kenya, including the Kenya Data Protection Act, 2019 (Act No. 24 of 2019) and the regulations made thereunder. Any disputes arising from this policy shall be subject to the exclusive jurisdiction of the courts of Kenya.