1. Who We Are

Viktorum (“Viktorum,” “we,” “us,” or “our”) is a specialized digital marketing agency headquartered at 237 Garden City, Nairobi, Kenya, 00618. We provide brand strategy, website design, SEO & GEO, social media management, direct booking growth architecture, and paid advertising for safari operators, tour providers, and hospitality businesses.

Viktorum is the Data Controller responsible for the personal data collected and processed under this Privacy Policy.

Privacy Contact Details:

• Email: hello@viktorum.com

• Phone: +40 744 621 250

• Postal Address: 237 Garden City, Nairobi, Kenya, 00618

This policy applies to visitors of viktorum.com, safari and tour business operators who submit marketing enquiry forms or request a digital marketing audit, individuals contacting us via WhatsApp, and prospective or existing clients whose data we process in connection with our Services.

2. Applicable Data Protection Laws

Because Viktorum is headquartered in Kenya and serves safari and tour operators targeting international travellers across Europe, North America, the UK, the Middle East, and beyond, we operate in compliance with cross-border privacy regulations:

• The Kenya Data Protection Act, 2019 (KDPA), overseen by the Office of the Data Protection Commissioner (ODPC).

• The UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, overseen by the Information Commissioner’s Office (ICO).

• The EU General Data Protection Regulation (EU GDPR), overseen by European Union member state supervisory authorities.

Where these laws impose differing standards, we apply the strictest data protection measures to safeguard your personal information.

3. What Personal Data We Collect

We collect personal data through your interactions with our Site, communication platforms, and services:

A. Contact & Audit Request Forms

When you fill out a form on our Site (e.g., requesting a safari website audit, direct booking growth consultation, or strategy call), we may collect:

• Your full name, job title, and company name (e.g., safari operator, lodge, tour company).

• Email address and telephone/WhatsApp contact number.

• Website URL and social media profiles.

• Current monthly marketing/advertising budget range.

• Specific details regarding your business challenges, direct booking goals, or enquiry details.

B. WhatsApp Communications

If you communicate with us via WhatsApp for sales inquiries, audit follow-ups, or ongoing marketing project management, we collect your mobile number, profile display name, and message history, subject to WhatsApp’s own terms and privacy policy.

C. Website Analytics & Usage Data

We use analytics tools (such as Google Analytics and Metricool) to understand visitor interactions with our Site. This includes:

• IP address (shortened or anonymized where applicable).

• Device characteristics, operating system, and browser type.

• Pages viewed, time spent per page, and referral sources (e.g., organic search, social media, or ads).

• Approximate location data.

D. Tracking Pixels & Ad Metrics

We use tracking technologies like the Meta Pixel (Facebook/Instagram) and Google Ads Tag to analyze campaign efficiency and deliver relevant marketing content to prospective clients who have visited our Site. These tools collect cookie IDs, device identifiers, and page interaction events.

E. Client & Operational Data

For safari and tour operators who partner with us, we collect business, technical, and campaign data necessary to deliver our Services (e.g., access credentials for ad accounts, analytics setups, CRM data, or aggregate booking figures shared for campaign performance measurement).

Note: We do not intentionally collect special categories of sensitive personal data (e.g., health data, biometric data, or religious beliefs) through our Site.

4. Legal Basis for Processing (UK / EU / Kenya Data Laws)

We process personal data based on the following legal grounds:

• Consent: When you opt in to non-essential cookies, target marketing, or newsletter subscriptions. You can withdraw consent at any time.

• Contractual Obligation: When processing is necessary to execute a service proposal, SOW, or agency agreement with your safari business.

• Legitimate Interests: To evaluate marketing audit requests, respond to business inquiries, optimize website security, and conduct direct marketing to business contacts where permitted by law.

• Legal Obligation: To comply with tax, corporate, or regulatory record-keeping laws in Kenya and relevant international jurisdictions.

5. How We Use Your Data

We utilize the collected data to:

• Evaluate website health, search ranking, and conversion bottlenecks for your safari business upon request.

• Schedule, prepare, and conduct strategy consultation calls.

• Execute and report on website design, SEO/GEO, paid ad campaigns, and direct booking growth strategies.

• Communicate progress updates, performance reports, and client account information.

• Analyze website performance, ad performance, and content engagement.

• Prevent fraud, unauthorized access, or cyber threats on our digital properties.

We do not sell or rent your personal data to third parties.

6. Data Sharing and Third-Party Processors

We share personal data only with trusted service providers, tools, and vendors necessary to conduct our business operations:

• Hosting & Infrastructure: WordPress / Web server hosting providers.

• Analytics & Performance: Google Analytics, Metricool.

• Advertising & Marketing: Meta (Facebook/Instagram Ads), Google Ads.

• Communication & Sales: WhatsApp Business, Google Workspace (Gmail/Drive).

• Legal & Professional Advisors: Legal counsel, accountants, and auditors when necessary.

• Regulatory & Statutory Authorities: When required by applicable law, court order, or subpoena.

All third-party vendors process data pursuant to data protection agreements and privacy commitments consistent with this policy.

7. International Data Transfers

Viktorum operates out of Nairobi, Kenya, and utilizes secure cloud software and infrastructure hosted internationally (including in the European Union and the United States).

For users based in the UK, EU, or North America, your data may be transferred outside your home country. Where international transfers occur, we implement appropriate safeguards, such as:

• Relying on adequacy decisions where recognized.

• Implementing Standard Contractual Clauses (SCCs) or UK International Data Transfer Addendums with our software providers.

8. Data Retention Schedule

• Enquiry & Marketing Audit Data: Retained for up to 24 months from your last contact with us to follow up on your enquiry, after which it is securely deleted or anonymized.

• WhatsApp Communications: Retained for the duration of the active business relationship and up to 3 years thereafter for record-keeping.

• Client Engagement & Financial Records: Retained for 7 years following contract termination to comply with statutory Kenyan tax and auditing laws.

• Analytics & Pixel Data: Retained according to default tool configurations (typically 14 to 26 months).

9. Your Data Protection Rights

Depending on your location, you hold specific rights regarding your personal data:

• Right of Access: Request a copy of the personal data we hold about you.

• Right to Rectification: Request corrections to inaccurate or incomplete data.

• Right to Erasure (“Right to be Forgotten”): Request deletion of your data, subject to statutory record-keeping mandates.

• Right to Restrict or Object: Object to direct marketing or limit our processing activities.

• Right to Data Portability: Request a structured transfer of your personal data to another controller.

• Right to Withdraw Consent: Revoke consent at any time without affecting past lawful processing.

To exercise any of these rights, contact our team at hello@viktorum.com. We respond to valid requests within the statutory timeframe (typically 30 days).

Right to Lodge a Complaint

If you believe your privacy rights have been infringed, you have the right to lodge a complaint with the appropriate regulatory body:

• Kenya: Office of the Data Protection Commissioner (ODPC) — www.odpc.go.ke

• United Kingdom: Information Commissioner’s Office (ICO) — www.ico.org.uk

• EU: Your national Data Protection Authority (DPA).

10. Security Measures

We deploy strict administrative, technical, and physical safeguards to prevent unauthorized access, loss, alteration, or disclosure of your data. These include SSL encryption across our Site, multi-factor authentication, secure cloud storage, and restricted staff access.

11. Children’s Privacy

Our Site and Services are intended exclusively for business operators and adults aged 18 or older. We do not knowingly collect personal data from children under 18.

12. Changes to This Privacy Policy

We may revise this Privacy Policy periodically to reflect changes in our operational procedures or privacy legislation. The updated revision date at the top of this document indicates when changes take effect.

13. Contact Us

For questions regarding this Privacy Policy or your personal data:

Viktorum

237 Garden City, Nairobi, Kenya, 00618

Email: hello@viktorum.com

Phone: +40 744 621 250