Privacy Policy
Nairobi Incorporated (“we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website www.nairobilighting.com (the “Site”), use our mobile application (the “App”), or use our products and services, including our Hardware-as-a-Service (HaaS) subscriptions, software subscriptions, and professional services.
Please read this Privacy Policy carefully. If you do not agree with its terms, please do not access the Site, download or use the App, or use our services.
Nairobi Incorporated primarily serves business customers; however, individual consumers may also interact with our Site and services. This Privacy Policy applies to all users of the Site and App, regardless of whether you are accessing them on behalf of a business entity or as an individual.
We collect several types of information from and about users of our Site and App, including:
a) Account and Registration Information: When you create an account, we collect your name, business name, email address, postal address, phone number, job title, and account credentials.
b) Transaction and Financial Information: When you make a purchase or subscribe to our services, we collect information necessary to process your payment and fulfill your order. The specific financial data we collect depends on the payment processor used. When payment is processed by Stripe or Square, we collect billing name, billing address, and transaction amount; complete payment card numbers are not stored by Nairobi. When payment is processed by ACH bank transfer, we collect your bank routing and account numbers solely for the purpose of processing the transaction. See Section 6 for details on our payment processors.
c) Device and App Usage Information: When you use our App, we collect information about your mobile device, including device identifiers, operating system version, and App usage data.
d) Location Data: Our App collects precise location data to enable hardware control and management features. Collection of location data occurs only while the App is in use (foreground) unless you grant permission for background location access. You may disable location services through your device settings, but doing so will limit App functionality.
e) Hardware and Service Data: We collect data related to your use of Nairobi hardware and services, including device connectivity status, configuration settings, and service activity logs associated with your account.
f) Communications: We collect records of your communications with us, including support requests, inquiries, and email correspondence.
g) Online and Technical Information: We collect technical information about your use of our Site, including IP address, browser type, referring URLs, and general usage patterns through cookies and similar technologies as described in Section 9. Under applicable state privacy laws including CPRA, IP addresses are classified as personal information in the category of internet or other electronic network activity information.
Nairobi hardware may transmit operational data such as connectivity status, uptime, and performance diagnostics to Nairobi’s systems for product improvement and service reliability purposes. This operational data is collected on an anonymous basis and cannot be associated with any individual user, customer account, or personal information. It is therefore not subject to the personal information rights and obligations described in this Privacy Policy.
We collect information from you in several ways:
a) Direct Collection: Information you provide to us when you register for an account, make a purchase, subscribe to our services, contact customer support, sign up for our newsletter or marketing communications, or otherwise interact with our Site or App.
b) Automated Collection: Information collected automatically as you navigate through our Site or use our App, using technologies such as cookies, web beacons, and similar tracking technologies as described in Section 9.
c) App and Device Collection: Information collected through the App, including location data and device identifiers, as described in Section 2.
d) Hardware Collection: Information collected in connection with your use of Nairobi hardware and services associated with your account.
e) Third-Party Sources: We may receive information about you from third-party sources such as payment processors, business partners, and essential service providers, in accordance with their privacy policies.
We use the information we collect about you for the following purposes:
a) Providing, maintaining, and improving our Site, App, and services
b) Processing your transactions, fulfilling orders, and administering HaaS and software subscriptions
c) Managing and supporting your Nairobi hardware through the App
d) Sending you administrative communications, such as account notices, transaction confirmations, and updates to our Terms of Use or this Privacy Policy
e) Sending you marketing and promotional communications about Nairobi’s products and services, where you have consented or where otherwise permitted by applicable law. You may opt out of marketing communications at any time as described in Section 13
f) Responding to your comments, questions, and customer service requests
g) Analyzing how you use our Site and App to improve our services and user experience
h) Protecting our Site, App, and services against fraudulent, unauthorized, or illegal activity
i) Enforcing our Terms of Use and other agreements
j) Complying with applicable legal obligations
We adhere to the principles of data minimization and purpose limitation, collecting only the information necessary for the specified purposes.
We may share your information in the following circumstances:
a) Service Providers: With vendors and service providers who perform services on our behalf, including payment processing, data hosting, customer support, and email delivery. These service providers are contractually obligated to use your information only as necessary to provide services to us and in compliance with applicable law.
b) Business Transactions: In connection with a merger, acquisition, sale of assets, or other business transaction, your information may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your personal information.
c) Legal Compliance: To comply with applicable laws, regulations, legal processes, or enforceable governmental requests, or to protect the rights, property, or safety of Nairobi Incorporated, our customers, or others.
d) With Your Consent: With your consent or at your direction.
We do not sell your personal information to third parties. We do not share your personal information for third-party direct marketing purposes.
Nairobi Incorporated may use one or more of the following payment processors to process transactions made through our Site. Any processor may be used for any transaction type, including direct hardware purchases, Hardware-as-a-Service subscriptions, and accessories. When you make a purchase, your payment information is transmitted directly to the applicable processor and is subject to that processor’s privacy policy and security standards. Nairobi Incorporated does not store complete payment card numbers on its servers.
Stripe: Stripe, Inc. processes credit card, debit card, and other payment transactions. Stripe collects payment card details, billing address, and transaction data necessary to process your payment. Stripe is PCI-DSS compliant. Stripe’s privacy policy is available at https://stripe.com/privacy.
Square: Block, Inc. (Square) processes credit card, debit card, and other payment transactions. Square collects payment card details, billing information, and transaction data necessary to process your payment. Square is PCI-DSS compliant. Square’s privacy policy is available at https://squareup.com/us/en/legal/general/privacy.
ACH Bank Transfer: We may process Automated Clearing House (ACH) bank transfer payments through our banking institution and ACH network provider. ACH transactions require you to provide your bank routing number and account number. This information is transmitted securely to the ACH network and is subject to the privacy practices of our banking institution and the applicable ACH network operator. ACH transactions are governed by the NACHA Operating Rules and applicable federal banking regulations.
Each payment processor operates independently and is solely responsible for the security and privacy of the payment data it processes. We encourage you to review the applicable processor’s privacy policy before completing a transaction. Nairobi Incorporated is not responsible for the data practices of any payment processor.
Depending on your state of residence, you may have certain rights regarding your personal information. These rights are described in detail in Section 15 (State-Specific Privacy Rights). Generally, these rights may include:
a) The right to know what personal information we collect, use, and disclose about you
b) The right to access and receive a copy of your personal information
c) The right to correct inaccurate personal information
d) The right to delete your personal information, subject to certain exceptions
e) The right to data portability
f) The right to opt out of the sale or sharing of your personal information
g) The right to limit use and disclosure of sensitive personal information
h) The right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects
i) The right to withdraw consent where processing is based on consent
j) The right to non-discrimination for exercising your privacy rights
To exercise any of these rights, please contact us by email at legal@nairobilighting.com. We will respond to verified requests within the timeframe required by applicable law. We may need to verify your identity before processing your request. We will not discriminate against you for exercising any privacy rights available to you. Authorized Agent Requests. Under applicable state privacy laws including CPRA, you may designate an authorized agent to submit privacy rights requests on your behalf. To use an authorized agent, you must provide the agent with written permission to act on your behalf, and we may require you to verify your own identity directly with us before processing the request. We may deny a request from an authorized agent who does not submit proof of authorization.
We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, to administer your account and subscriptions, and as required or permitted by applicable law. When personal information is no longer needed, we will delete or anonymize it using reasonable measures to protect against unauthorized access or use. For individual consumers who make a one-time hardware purchase without an ongoing subscription or account, we retain personal information only as long as necessary to fulfill the transaction, honor applicable warranty obligations, and comply with legal requirements including tax and financial recordkeeping obligations. Consumers in this category retain all applicable privacy rights, including the right to request access to, correction of, or deletion of their personal information, regardless of whether an active account exists.
We implement a variety of security measures to maintain the safety of your personal information, including:
a) Encryption of sensitive data in transit and at rest using industry-standard protocols
b) Regular security assessments and vulnerability testing
c) Access controls and authentication mechanisms limiting access to authorized personnel
d) Employee training on data protection and security practices
e) Vendor management and contractual data protection requirements for service providers
We conduct privacy impact assessments for high-risk processing activities and maintain internal data protection policies and procedures. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security. If you have reason to believe that your interaction with us is no longer secure, please contact us immediately using the information in Section 19.
We use cookies and similar tracking technologies to operate and improve our Site and to hold certain information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent.
We use the following types of cookies:
a) Essential Cookies: Necessary for the Site to function properly. These cookies cannot be disabled without affecting core Site functionality.
b) Functionality Cookies: Used to recognize you when you return to our Site and to remember your preferences and settings.
We do not use targeting or advertising cookies. We do not use behavioral or cross-context advertising technologies on our Site or App.
Nairobi Incorporated honors Global Privacy Control (GPC) signals as required by applicable law, including the California Privacy Rights Act (CPRA) and similar state laws. If your browser or device transmits a GPC signal indicating that you wish to opt out of the sale or sharing of your personal information, we will treat that signal as a valid opt-out request.
Because Nairobi does not sell or share personal information for cross-context behavioral advertising purposes, GPC signals will not change the information we collect or the manner in which we use it. We will, however, record and honor GPC signals in our processing logs as required by applicable law.
We do not otherwise alter our data collection or use practices in response to browser Do Not Track (DNT) signals, as no uniform standard for DNT signals currently exists.
Our iOS mobile application (the “App”) enables you to manage and control Nairobi hardware. In connection with your use of the App, we collect the following:
a) Precise Location Data: The App collects precise geolocation data to enable hardware identification, control, and management features. You will be prompted to grant location permission when you first use relevant App features. You may revoke location permission at any time through your device settings, but doing so will limit your ability to use hardware control features.
b) Device Information: We collect device identifiers, operating system version, and App version information to provide and improve the App.
c) App Usage Data: We collect data about how you interact with the App, including features accessed and actions taken, to improve App performance and user experience.
d) Hardware Connectivity Data: The App collects data relating to the connectivity and status of paired Nairobi hardware associated with your account.
Location data collected through the App is used solely for hardware management purposes and is not used for advertising, profiling, or sold to third parties. Location data is associated with your account and is subject to the retention and security practices described in Section 8.
Under applicable state privacy laws, precise geolocation data is classified as sensitive personal information. You have the right to limit our use of your location data to purposes reasonably necessary for providing the App’s hardware management features. To exercise this right, contact us at legal@nairobilighting.com or adjust location permissions in your device settings.
With your consent or where otherwise permitted by applicable law, we may send you marketing and promotional emails about Nairobi’s products and services. For individual consumers, we will obtain your affirmative opt-in consent before sending marketing emails, as required by applicable state law including the California Consumer Privacy Rights Act and similar statutes.
a) Opt-Out: You may opt out of receiving marketing emails from us at any time by clicking the “Unsubscribe” link in any marketing email we send, or by contacting us at mark.svejda@nairobilighting.com. We will process your opt-out request promptly and within the timeframe required by applicable law. Please note that even if you opt out of marketing communications, you will continue to receive transactional and account-related communications from us.
b) CAN-SPAM Compliance: Our marketing emails comply with the federal CAN-SPAM Act. Each marketing email we send will: (i) identify itself as a commercial message; (ii) include our physical mailing address; (iii) provide a clear and conspicuous mechanism to opt out of future emails; and (iv) honor opt-out requests promptly.
c) Text Messages: Nairobi will not send marketing text messages to your mobile phone without first obtaining your prior express written consent as required by the Telephone Consumer Protection Act (TCPA), 47 U.S.C. § 227. If you provide your prior express written consent to receive marketing text messages from us, standard message and data rates may apply. You may revoke your consent and opt out of text messages at any time by replying STOP to any message we send. Consent to receive text messages is not a condition of any purchase.
Nairobi Incorporated does not sell your personal information to third parties, and does not share your personal information for cross-context behavioral advertising purposes, as those terms are defined under the California Privacy Rights Act (CPRA) and applicable state privacy laws.
Because we do not engage in the sale or sharing of personal information as defined by applicable law, we do not offer a formal “Do Not Sell or Share” opt-out mechanism at this time. If our data practices change, we will update this Privacy Policy and implement the required opt-out mechanisms before any such activities begin.
Our Site and App are not intended for children under the age of 13. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us immediately at legal@nairobilighting.com. We comply with the Children’s Online Privacy Protection Act (COPPA), 15 U.S.C. § 6501 et seq., and will promptly delete any inadvertently collected information from a child under 13 upon notice.
Depending on your state of residence, you may have additional privacy rights under applicable state law. Nairobi Incorporated is committed to complying with all applicable state privacy statutes in effect as of the date of this Privacy Policy.
a) California Residents (CPRA / California Privacy Rights Act):
California residents have the following rights under the California Privacy Rights Act (CPRA), which amended and expanded the California Consumer Privacy Act (CCPA), effective January 1, 2023:
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Right to Know: The right to request information about the categories and specific pieces of personal information we have collected about you, the sources of that information, our business or commercial purposes for collecting it, and the categories of third parties with whom we share it.
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Right to Access: The right to receive a copy of the specific personal information we have collected about you.
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Right to Correct: The right to request correction of inaccurate personal information we maintain about you.
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Right to Delete: The right to request deletion of your personal information, subject to certain exceptions.
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Right to Opt Out of Sale or Sharing: The right to opt out of the sale of your personal information or its sharing for cross-context behavioral advertising. We do not currently sell or share personal information as those terms are defined under CPRA.
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Right to Limit Use of Sensitive Personal Information: The right to direct us to limit our use and disclosure of sensitive personal information (including precise geolocation data) to purposes reasonably necessary to provide the requested services.
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Right to Non-Discrimination: We will not discriminate against you for exercising any of your CPRA rights.
Categories of personal information collected in the past 12 months: identifiers (name, email, address, account credentials); commercial information (transaction and subscription records); location data (precise geolocation through the App); device and internet or other electronic network activity information.
California’s “Shine the Light” law (Civil Code § 1798.83) gives California residents the right to opt out of our disclosure of personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties for their direct marketing purposes.
To exercise your California privacy rights, contact us at legal@nairobilighting.com. We will verify your identity before processing your request and respond within 45 days, with up to a 45-day extension where reasonably necessary.
b) Virginia Residents (VCDPA): Virginia residents have the right to access, correct, delete, and obtain a copy of their personal data; to opt out of the processing of personal data for targeted advertising, sale, or profiling; and to appeal our decisions regarding their requests. To exercise these rights, contact us at mark.svejda@nairobilighting.com.
c) Colorado Residents (CPA): Colorado residents have the right to access, correct, delete, and obtain a portable copy of their personal data; to opt out of the processing of personal data for targeted advertising, sale, or profiling; and to appeal our decisions. To exercise these rights, contact us at legal@nairobilighting.com.
d) Connecticut Residents (CTDPA): Connecticut residents have the right to access, correct, delete, and obtain a copy of their personal data; to opt out of the processing of personal data for targeted advertising, sale, or profiling; and to appeal our decisions. To exercise these rights, contact us at legal@nairobilighting.com.
e) Texas Residents (TDPSA): Texas residents have rights to access, correct, delete, and obtain a portable copy of their personal data and to opt out of the sale of personal data, targeted advertising, and profiling. To exercise these rights, contact us at legal@nairobilighting.com.
f) Oregon Residents (OCPA): Oregon residents have rights to access, correct, delete, and obtain a portable copy of their personal data and to opt out of the processing of personal data for targeted advertising, sale, or profiling. To exercise these rights, contact us at legal@nairobilighting.com.
g) Montana Residents (MCDPA): Montana residents have rights to access, correct, delete, and obtain a portable copy of their personal data and to opt out of the sale of personal data, targeted advertising, and profiling. To exercise these rights, contact us at legal@nairobilighting.com.
h) Other State Residents: Residents of Delaware, Iowa, Indiana, Kentucky, Maryland, Minnesota, Nebraska, New Hampshire, New Jersey, Tennessee, and other states that have enacted comprehensive privacy legislation may have similar rights. We are committed to complying with all applicable state privacy laws. To exercise any applicable rights, contact us at legal@nairobilighting.com.
For all state privacy rights requests, we will: (i) verify your identity or authorization before processing the request; (ii) respond within the timeframe required by applicable law; (iii) provide an appeal mechanism if we decline to take action on your request; and (iv) not discriminate against you for exercising your rights.
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Nevada residents have the right to opt out of the sale of their personal information under Nevada Revised Statutes Chapter 603A. We do not currently sell personal information as defined by Nevada law. If this changes, we will update this policy and provide a mechanism for opting out.
In the event of a data breach that is likely to result in a risk to the rights and freedoms of affected individuals, we will notify affected individuals and relevant state authorities without undue delay and within the timeframes required by applicable state breach notification laws. Arizona’s data breach notification law (A.R.S. § 18-551 et seq.) requires notification to affected Arizona residents in the most expedient manner possible following discovery of a breach involving personal information. We will comply with all applicable state breach notification requirements.
We take steps to ensure that our vendors and service providers who may have access to your personal information comply with applicable data protection requirements. This includes conducting reasonable due diligence on service providers and entering into appropriate data processing agreements or contractual arrangements requiring them to protect your personal information and use it only as directed by us.
We may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or for other operational, legal, or regulatory reasons. We will notify you of any material changes by posting the updated Privacy Policy on this page and updating the “Last Updated” date at the top of this Privacy Policy. Where required by applicable law, we will provide additional notice of material changes.
You are advised to review this Privacy Policy periodically for any changes. Your continued use of the Site or App after the posting of changes constitutes your acceptance of those changes.
Nairobi Incorporated operates exclusively online. If you have any questions about this Privacy Policy or our privacy practices, or to exercise any rights described in this Privacy Policy, please contact us by email at:
Nairobi Incorporated
14747 N. Northsight Blvd., Suite 111-467
Scottsdale, Arizona 85260
Email: mark.svejda@nairobilighting.com
We will respond to all privacy-related inquiries and requests within the timeframe required by applicable law.
h) Rhode Island Residents (DTPPA): Rhode Island’s Data Transparency and Privacy Protection Act (R.I. Gen. Laws § 6-48.1-1 et seq.), effective January 1, 2026, grants Rhode Island residents the right to access, correct, delete, and obtain a portable copy of their personal data; to opt out of the processing of personal data for targeted advertising, sale, or profiling; and to appeal our decisions regarding their requests. To exercise these rights, contact us at mark.svejda@nairobilighting.com.
By using our Site or App, you acknowledge that you have read and understood this Privacy Policy and agree to its terms.
i) Other State Residents: Residents of Delaware, Iowa, Indiana, Kentucky, Maryland, Minnesota, Nebraska, New Hampshire, New Jersey, Rhode Island, Tennessee, and other states that have enacted comprehensive privacy legislation may have similar rights. We are committed to complying with all applicable state privacy laws. To exercise any applicable rights, contact us at mark.svejda@nairobilighting.com.
For all state privacy rights requests, we will: (i) verify your identity or authorization before processing the request; (ii) respond within the timeframe required by applicable law; (iii) provide an appeal mechanism if we decline to take action on your request; and (iv) not discriminate against you for exercising your rights.