Privacy Policy

Last updated: 6 November 2026. This Privacy Policy explains how the operator of ZXenia ("ZXenia", "we", "us" or "our") collects, uses, discloses, retains and protects your personal data when you use our website, applications and related services (the "Service"), and the rights you have in relation to it. We process personal data in accordance with the Data Protection Act, 2019 of Kenya and its Regulations, and with other data protection laws that apply to you.

Because ZXenia is a space for adults to meet, some of the information you share may reveal your sex life or sexual orientation, which the law treats as sensitive personal data. We have designed the Service so that you decide what to share, who can see it and when, and so that as little as possible is kept for as short a time as possible.

1. Who We Are

ZXenia is the data controller of the personal data described in this Policy. Where the law requires it, we are registered with the Office of the Data Protection Commissioner. You can contact us, and our data protection lead, through our Contact page or at the support email address shown there.

2. The Personal Data We Collect

Information you give us:

Account information: your display name, email address, password (stored only as a salted, irreversible hash) and date of birth.
Profile information: your gender, the genders you are open to meeting, your preferred age range, city and country, what you are here for, your interests, your biography, your boundaries, prompt answers and compatibility answers, and your privacy choices.
Photographs: profile photos, chat photos and verification selfies. Every uploaded image is re-encoded on our server, which removes hidden data such as GPS location and camera details.
Communications: reactions, notes sent with a knock, posts at tables, reports, reviews and messages you send to us. Private messages are end-to-end encrypted: they are locked in your browser before they are sent, with a key that only you and the other person hold. We store only the locked form and cannot read it. We do see when a message was sent, by whom, to whom, and whether it has been delivered and read (read receipts only if you both share activity).
Date Safety plans: who you are meeting, where and when, and the name and email address of a trusted contact who has agreed to be contacted.
Payment information: the plan, amount, method and status of each payment, your M-Pesa number if you choose M-Pesa renewal, and a card label (such as "Visa ending 1234") and a reusable authorisation reference from Paystack if you choose card renewal. We never receive your full card number, card security code or M-Pesa PIN.

Information created when you use the Service:

Activity: your knocks, passes, matches, saved profiles, profile views, table memberships, boosts, ZXenus Points history and when you were last active.
What the matching engine learns: weights, derived from your own knocks and passes, describing the kinds of profiles you tend to prefer. You can see them in your data download.
Security information: login attempts, a signed cookie that recognises browsers you have used before, and records of security events. Your IP address is used briefly to apply rate limits and to estimate your country, as described in clause 4.
Screening results: for each photo, the result of an automated check for nudity, missing faces and duplicates, which helps our moderators.

We do not collect your precise location, your contacts or address book, your biometric data, or information about you from data brokers, and we do not use advertising trackers.

3. How and Why We Use Your Data

We process your personal data only where we have a lawful basis under section 30 of the Data Protection Act, 2019:

To provide the Service under our contract with you: creating and securing your Account, showing your profile to people you may want to meet, suggesting matches, enabling knocks, conversations and tables, processing payments and renewals, administering ZXenus Points, and providing support.
With your explicit consent, for sensitive personal data: processing information about your sex life or sexual orientation that you choose to include in your profile, intents and preferences. You may withdraw consent at any time by editing or deleting that information or your Account; this does not affect processing that took place before withdrawal.
To comply with legal obligations: keeping payment records for tax and accounting purposes, responding to lawful requests from authorities, and protecting children in accordance with our Child Safety Standards.
For our legitimate interests, where these are not overridden by your rights: keeping the Service and its members safe, including automated screening of photos and messages, detecting fraud, scams, spam and abuse, enforcing our Terms, applying rate limits, alerting you to logins from new devices, and improving the Service.
To protect vital interests: contacting the trusted person you named in a Date Safety plan if you do not check in, and contacting emergency services where we believe someone is at serious risk of harm.

4. Automated Processing

Matching. Our matching engine ranks people for you using the information both of you provide, your own interactions, mutual fit, activity, responsiveness and fairness measures. It never uses intents marked as private that you have not chosen yourself. Matching only orders suggestions: it does not produce decisions with legal or similarly significant effects on you, and you can always browse, filter, pass or knock as you choose.

Safety screening. Photos are checked automatically, on our own servers, for nudity, missing faces and images already used by another member; a person makes every decision to approve a profile photo. Profile text, notes and table posts are scanned on our servers, and private messages are checked inside the sender's own browser before they are encrypted, for patterns associated with scams, the sale of sex and possible involvement of minors. For private messages, only the kind of concern is sent to us, never the words; matches result in a caution to the reader or a report to a moderator, and never in automatic punishment. A profile that is the subject of a report that the member may be under 18, or of reports from several members, may be withheld from discovery until a person has reviewed it.

Country estimate. We estimate your country from your IP address using an IP-to-country database stored on our own server (provided by DB-IP under a Creative Commons Attribution 4.0 licence), or from a country header added by our network provider. This lets the globe start from where you are and pre-fills your country at sign-up. The address is not sent to any third party for this purpose and is not stored for it.

You have the right to object to automated processing and to request human review of any decision that affects you, by contacting us.

5. Encryption of Private Messages

Your messaging key is created in your browser and locked with your password before a locked copy is stored with us, so you can use it on other devices. We never receive your password in a form that could unlock it. If you reset a forgotten password, your old key cannot be unlocked, and messages sent before the reset cannot be opened again. If you report a message, your browser sends us the words you report together with a proof, so our moderators can confirm that the sender really wrote them. Photos sent in chats are not end-to-end encrypted, so that they can be screened for nudity and blurred; they are stored privately and shown only to the two people in the conversation.

6. Who Can See Your Information

Other members see only what you choose to put on your profile, and only if they are allowed to see you: you must want to meet each other, you must not have blocked each other, and your visibility choices (hiding your profile, blurring photos until a match, hiding details, showing activity, accepting only verified members) are always respected. Your date of birth is never shown; only your age is, unless you choose to hide it.
Matches can see your full photos (if you blur them for others) and your conversation with them.
Our moderators can see the information needed to review photos, selfies, reports and tables, under strict confidentiality. Staff access to administrative areas requires two-step authentication, and actions are logged.
Your trusted contact receives only the details of a Date Safety plan you chose to share, and an alert if you do not check in.

We do not sell, rent or trade your personal data, and we do not share it for advertising. We disclose personal data only to:

Service providers acting on our instructions under contracts that require confidentiality and security, including our payment processor (Paystack Payments Limited and the card and mobile money networks it uses), our email delivery provider, and our hosting and infrastructure providers;
Authorities, where required by law or a valid court order, or where we believe in good faith that disclosure is necessary to prevent serious harm, to protect a child, or to investigate fraud or a crime; and
A successor in the event of a merger, acquisition or sale of all or part of the Service, subject to this Policy.

8. International Transfers

Some of our service providers may store or process data outside Kenya. Where we transfer personal data outside Kenya, we do so only in accordance with Part VI of the Data Protection Act, 2019, including by ensuring that appropriate safeguards are in place for the security and protection of the data, and, for sensitive personal data, with your consent.

9. How Long We Keep Data

We keep personal data only for as long as necessary for the purposes described in this Policy. In particular:

Your Account and profile: until you delete your Account.
Accounts whose email is never confirmed: deleted after fourteen (14) days.
Verification selfies: deleted as soon as a person has reviewed them.
Rejected photos: deleted after thirty (30) days.
Conversations you unmatch: hidden immediately, and deleted after ninety (90) days, so that either person can still report abuse.
Profile views: ninety (90) days. Notifications: one hundred and twenty (120) days. Passes: one (1) year.
Date Safety plans: thirty (30) days after the date.
Sent emails: thirty (30) days, with any links removed as soon as each email is sent.
Payment records: as long as tax and accounting law requires, generally up to seven (7) years. When you delete your Account, these records are kept against an anonymised Account.
Reports and safety records: as long as necessary to protect members and to comply with the law; details are cleared when the reported Account is deleted.

10. Security

We protect personal data with appropriate technical and organisational measures, including: encryption in transit (HTTPS with HSTS); hashing of passwords; encryption of stored payment provider keys and two-step secrets; private storage of all member photos, served only after an access check on every request; removal of image metadata; strict content security and cookie policies; rate limits and lockouts against password guessing and scraping; email alerts for new-device logins and changes to your password or email; the option to log out on every device; two-step authentication and audit logging for staff; and minimisation and automatic deletion of data we no longer need. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

If a personal data breach occurs that is likely to result in a real risk of harm to you, we will notify the Data Commissioner and, where required, you, in accordance with section 43 of the Data Protection Act, 2019.

11. Your Rights

Subject to the conditions in the law, you have the right to:

be informed of the use to which your personal data is to be put;
access your personal data, which you can do at any time by downloading your data from My account;
object to the processing of all or part of your personal data, including to processing for direct marketing;
correct false or misleading data, most of which you can do yourself in your profile and account settings;
delete false, misleading or unnecessary data, or your whole Account, which you can do yourself in My account;
receive your data in a structured, commonly used and machine-readable format (data portability);
withdraw consent at any time; and
lodge a complaint with the Office of the Data Protection Commissioner (www.odpc.go.ke).

To exercise a right we cannot provide through the Service, contact us. We may need to verify your identity, and we will respond within the period required by law.

12. Emails and Notifications

We send emails necessary to provide the Service, such as confirmation, security, payment and safety emails. You can choose in your profile whether we email you about matches, messages, knocks and our weekly note. Every weekly note and news email contains a one-click link to stop them. Notification emails never contain the words of your conversations.

13. Children

The Service is strictly for adults aged 18 and over. We do not knowingly collect personal data from anyone under 18. If we learn that we have done so, we will suspend the Account and delete the data, except where we must retain it to report a concern to the authorities. Please see our Child Safety Standards.

14. Changes to This Policy

We may update this Policy from time to time. If we make material changes, we will notify you by email or on the Service before they take effect. The "Last updated" date above shows when this Policy was last revised.

15. Contact

If you have any questions about this Policy or our handling of your personal data, please contact us through our Contact page or at the support email address shown there.