Privacy Policy

Last updated 9 November 2026

How Cueline Media Limited handles personal information: what we collect, why, who we share it with, and the rights you have.

• Who we are
• Client files
• What we collect
• Sharing
• Transfers
• Security
• Your rights
• Complaints

Who we are

Cueline Media Limited is a company registered in Kenya (company number PVT-BB16WL8P). We provide transcription, subtitling, captioning and translation to businesses and professionals. We are registered with Kenya's Office of the Data Protection Commissioner as a data processor, registration number 859-0424-C351.

Our data protection officer can be reached at privacy@cuelinemedia.com. For anything else, write to contact@cuelinemedia.com.

Two roles: our own records and our clients' files

• Our own records. For this website, enquiries, client contacts, invoices and editor applications, we decide how personal information is used. This policy covers that information.
• Client files. The recordings and documents clients send us are processed only on our clients' instructions, under a written data processing agreement. The client decides why that information is processed, and its own privacy notice applies. If you appear in a recording and want to use your rights, please contact the organisation that made it. If you contact us instead, we pass your request to them promptly.

What we collect, why, and for how long

The legal bases below are those of the EU and UK GDPR. Kenyan and South African law recognise similar grounds.

You do not have to give us any information. But without contact and billing details we cannot quote, deliver or invoice, and without a KRA PIN we cannot pay an editor.

We do not make decisions about people by automated means alone. We do not sell personal information or share it for advertising.

Who we share it with

• Secure third-party processing infrastructure: cloud email and file storage, website hosting (our host stores requests sent through the quote form until we delete them), a social media scheduling service, and, where a client allows it, automated speech-recognition services that prepare first drafts, which our editors then check against the recording. These providers act only on our instructions under written contracts. Where a provider offers a setting that would let it use files to improve its own products, we switch it off.
• Our contracted editors, who work under written confidentiality and data protection agreements and never use consumer AI tools with client files.
• Banks and payment providers, to receive and make payments.
• Professional advisers, such as lawyers and accountants, under a duty of confidentiality.
• Authorities, such as the Kenya Revenue Authority, courts and regulators, when the law requires it.

Clients receive the names and locations of our subprocessors with our data processing agreement, and can ask for the current list at any time.

International transfers

We are based in Kenya. Our infrastructure providers store information in the United States and, for clients who ask for EU storage, in Germany. We protect these transfers with written contracts and, where the law requires them, with recognised safeguards:

• For personal data from the EU or UK, the European Commission's standard contractual clauses and the UK International Data Transfer Addendum.
• For transfers out of Kenya, the safeguards required by the Data Protection Act, 2019. Sensitive personal data is processed outside Kenya only with the consent of the person concerned and confirmed safeguards.

You can ask us for a copy of the safeguards at privacy@cuelinemedia.com.

How we protect it

• Multi-factor sign-in on every account, encryption in transit and at rest, and full-disk encryption on every work device.
• Access to client files only for the people working on them, under signed confidentiality agreements.
• Client files deleted 30 days after delivery, unless the client instructs otherwise. Copies may remain in our providers' backups for up to 90 days after deletion, until those backups expire.
• No client files in consumer AI chat tools, ever.

Your rights

Depending on where you live, data protection law, including Kenya's Data Protection Act, 2019, the EU and UK GDPR and South Africa's POPIA, gives you the right to:

• be told how your information is used, and get a copy of it;
• have inaccurate or misleading information corrected or deleted;
• object to, or ask us to restrict, how we use it;
• have it deleted, or receive it in a portable format, in the cases the law allows;
• withdraw consent at any time, where we rely on consent;
• not be subject to decisions based only on automated processing.

Write to privacy@cuelinemedia.com. We may ask you to confirm your identity. We reply within one month at the latest, or sooner where local law requires, and we do not normally charge a fee.

Complaints

Please contact us first at privacy@cuelinemedia.com. We acknowledge every complaint within 30 days and tell you what we will do. You can also complain to a data protection authority:

• Kenya: the Office of the Data Protection Commissioner, odpc.go.ke
• United Kingdom: the Information Commission (formerly the Information Commissioner's Office), ico.org.uk
• European Union: the data protection authority in the country where you live or work, listed at edpb.europa.eu
• South Africa: the Information Regulator, inforegulator.org.za
• Elsewhere: the data protection authority where you live.

Children

Our website and services are for businesses and professionals, not children. Information about children reaches us only when it appears in a client's recording, which we process on the client's instructions.

Changes to this policy

We will update this page when our practices change, and show the date at the top. We tell clients about significant changes by email.