Privacy Policy — Kenya Addendum

• Controller. Otto Rentals Inc. is the controller for the Services. Otto Rentals KE Ltd ("Otto KE") generally acts as our processor for local support, KYC/onboarding, payment facilitation, tax invoicing/e-TIMS, and customer operations performed on our instructions. Where Otto KE independently determines purposes and essential means in order to meet mandatory Kenyan legal obligations (e.g., tax reporting or statutory record-keeping), it acts as an independent or joint controller only for that specific processing.
• Transfers. Personal data collected in Kenya is transferred to the United States for processing by Otto Rentals Inc. We implement safeguards permitted by the Data Protection Act, 2019 and the Data Protection (General) Regulations, 2021 (e.g., contractual clauses, adequacy, consent, or necessity to perform a contract), together with the technical and organizational measures in §9.
• Rights. Kenyan residents may exercise rights to be informed, access, correction/rectification, objection, erasure, restriction, and complaint to the Office of the Data Protection Commissioner (ODPC). Submit requests to help@ottogoes.com (subject: Kenya DSR). We will coordinate with Otto KE as needed.
• Retention. We may retain certain records to comply with Kenyan tax, invoicing, and accounting laws and for dispute resolution. See §8 for indicative retention periods.
• Local assistance. For regulator engagement or on-site inspections, Otto KE assists as our local processor/joint controller where applicable.