This document is designed as a clear operational policy. It should be reviewed periodically against changes in Kenyan law and the company’s actual practices.
Privacy at a glance
Top Prime Media (“TPM”, “we”, “us”) respects your privacy. This policy explains what personal data we process when you read, watch, listen, subscribe, create an account, enter a promotion, contact the newsroom, submit a tip, apply for work or advertise with us. It also explains your choices and rights under Kenya’s Data Protection Act, 2019 and applicable regulations.
1. Who is responsible for your data
Top Prime Media is the data controller for personal data collected through this website, our applications, newsletters, events and direct business relationships. Where a service provider processes information only on our instructions, it acts as our processor. Questions and rights requests may be sent to privacy@topprimemedia.co.ke.
2. Information we collect
Information you provide
- Identity and contact data, including name, email address, telephone number, postal address and account credentials.
- Newsletter preferences, saved topics, comments, competition entries, survey answers and event registrations.
- News tips, documents, photographs, recordings, correspondence and information about sources that you choose to share.
- Commercial information such as organisation, job title, campaign brief, billing details and transaction records.
- Recruitment information such as a CV, portfolio, qualifications, employment history and referee details.
Information collected automatically
- Device, browser, operating system, language, IP address, approximate location, referrer and advertising identifiers.
- Pages, articles, videos or audio selected; timestamps; session duration; scroll, click and playback events; error and security logs.
- Cookie and consent preferences. We do not seek precise location unless a feature clearly requests it and you consent.
3. Why we process information
Where we rely on legitimate interests, we balance those interests against your rights and reasonable expectations. Where processing requires consent, you may withdraw it without affecting earlier lawful processing.
4. Journalism, sources and public-interest material
News publishing can involve personal data. Editorial decisions are governed by law, professional journalism standards, the public interest and our Editorial Standards. Source confidentiality is treated seriously. Do not use ordinary web forms for information that could put you at risk; first ask the investigations desk for a secure channel.
5. Children
Our general news services are not directed at children under 18. We do not knowingly create marketing profiles for children. When reporting about a child or processing a child’s information, we apply heightened safeguards, minimise identification, consider the child’s best interests and obtain appropriate authority or rely on another lawful basis where permitted.
6. Sharing and service providers
We may share necessary data with hosting, security, analytics, newsletter, payment, customer-support, advertising and professional advisers under appropriate contractual safeguards. We may disclose information where required by law, a valid court or regulatory process, to protect life or safety, to investigate abuse, or in connection with a genuine corporate reorganisation. We do not sell a reader’s directly identifying personal data.
7. International transfers
Some providers may process data outside Kenya. Before a restricted transfer, we use a legally recognised safeguard, assess the destination and provider, limit the data, apply security controls and obtain consent where required. You may request information about the safeguard relevant to your data.
8. Retention
We retain personal data only as long as reasonably necessary for the stated purpose, legal obligations, disputes, security and legitimate archival needs. Account and subscriber records are reviewed after inactivity; unsuccessful recruitment records are normally removed after a reasonable recruitment period; security logs are kept for a limited operational period. Published journalism may be retained as part of the historical record, subject to corrections, legal obligations and proportionate rights review.
9. Security
We use role-based access, least privilege, encryption in transit, backups, logging, patching, vendor review and staff confidentiality measures appropriate to risk. No internet service can promise absolute security. If we identify a qualifying personal-data breach, we will assess, contain, document and notify the relevant authority and affected people as required.
10. Your rights
Subject to lawful limits, you may ask to be informed, access your data, object or restrict processing, correct inaccurate data, request deletion, receive portable data, withdraw consent, and seek review of a significant solely automated decision. We may need to verify identity and may decline or limit a request where a legal exemption applies, including protection of another person, source confidentiality, legal privilege or journalistic freedoms.
Send requests to privacy@topprimemedia.co.ke. State the right you wish to exercise and enough detail to locate the data. You may also lodge a complaint with Kenya’s Office of the Data Protection Commissioner.
11. Cookies, analytics and advertising
Essential technologies maintain security and preferences. Optional analytics and advertising technologies should operate according to your consent selection. See our Cookie Policy. Browser “do not track” signals are not uniformly standardised; use our consent controls for a reliable choice.
12. Automated tools and artificial intelligence
We may use automated tools to detect abuse, transcribe media, recommend content, support search or assist newsroom workflows. Material editorial decisions remain subject to human responsibility. We do not permit generative AI tools to use confidential source material or sensitive personal data unless specifically approved with appropriate safeguards.
13. Changes and contact
We will post material changes here and update the review date. If a change materially affects consent-based processing, we will seek a new choice where required. Contact: Privacy Lead, Top Prime Media, Kitengela, Kajiado County, Kenya; privacy@topprimemedia.co.ke.