Privacy Policy

Data Centre 254 ("DC254", "we", "us") is an independent Kenyan educational and research platform explaining the physical infrastructure behind Kenya's digital economy. It is founded and published by Kevin Jonathan Otieno from Nairobi, Kenya.

This policy explains what personal data we collect when you visit data-centers-254.vercel.app, subscribe to our briefing, or contact us, and the rights you have over that data under the Kenya Data Protection Act, 2019.

Briefing subscriptions. When you subscribe to The Rack Report, our monthly intelligence briefing, we collect your email address, the page or campaign you subscribed from, and an optional, self-declared role descriptor (for example "investor" or "journalist") and organisation name you may choose to provide. Subscribing is a two-step, double opt-in process: your request is stored locally and a confirmation email is sent with a signed, single-purpose link - your address is only added to the briefing list after you follow that link, and only then is it shared with Resend, our email service provider. The role and organisation fields are entirely optional and are used only in aggregate, anonymised form to describe our audience to prospective sponsors. You can unsubscribe at any time using the link in every briefing email; unsubscribing erases the personal details in your subscription record (email, role, organisation, source) immediately, leaving only an anonymised placeholder so the same address is not counted twice.

Contact form messages. When you contact us through the contact form, we receive your name, email address, subject, and message. This is delivered to our email inbox through Resend and is used solely to respond to you.

Analytics and consent. We use Google Analytics 4 and Microsoft Clarity to understand aggregate site usage - pages visited, approximate location (country/city), device and browser type, and referring sources, plus Clarity's heatmaps and scroll-depth data. Neither tool loads until you agree through the consent banner shown on your first visit; your choice is stored on your device, applies across visits, and analytics stay off entirely if you decline. The site remains fully functional either way. GA4 may use cookies and collects IP addresses, which Google truncates/anonymises for GA4 properties. Clarity is cookieless, masks all text that visitors type, records no form entries or passwords, and sets no cookies.

We do not require accounts or logins, DC254 is a read-only publication. We do not collect names, phone numbers, or payment details through this website. We do not sell, rent, or trade your personal data to anyone, and we do not use your data for automated decision-making or profiling.

We rely on a small number of processors to run the site: Vercel (web hosting and content delivery), Resend (briefing contact storage and email delivery), Google Analytics 4 (aggregate audience analytics), and Microsoft Clarity (cookieless, masked usage analytics). Each processes data on our instructions under its own privacy terms.

The website itself sets no tracking cookies of its own, and no analytics of any kind runs before you consent through the on-site banner. Once you accept, the only cookies on this site come from Google Analytics, used to measure aggregate traffic; Microsoft Clarity, our other analytics tool, is cookieless and sets no cookies at all. You can block or delete analytics cookies through your browser settings, or withdraw consent by clearing this site's storage in your browser, without losing access to any part of the site.

Briefing contacts are kept until you unsubscribe or ask us to delete them; unsubscribing erases the personal details of the record immediately, leaving an anonymised placeholder. Unconfirmed (double opt-in) signup requests that are never verified are treated as abandoned and erased after 60 days. Contact form correspondence is kept for as long as needed to handle your enquiry and for our records. Analytics data, where consented to, is retained by Google according to its standard retention settings.

Under the Kenya Data Protection Act, 2019, you have the right to access the personal data we hold about you, to correct inaccurate data, to erasure, to withdraw consent, and to lodge a complaint with the Office of the Data Protection Commissioner (ODPC), Kenya.

To unsubscribe from the briefing, use the unsubscribe link in any briefing email - it takes effect immediately and erases your details from our records - or contact us directly. To change your analytics consent, clear this site's storage in your browser and the banner will reappear. For any data request, email elmaccommunicationslimited@gmail.com and we will respond within a reasonable timeframe.

We may update this policy as the platform grows. Material changes will be reflected on this page with a revised effective date. This policy was last revised on 19 September 2026.