X1X Privacy policy

X1X

Operating as Baselayer X1X Limited

Last updated: Feb 22 , 2026

1. Introduction

X1X is operated by Baselayer X1X Limited, a company registered in Kenya.

We are committed to protecting your personal data in accordance with the Kenya Data Protection Act, 2019.

This Privacy Policy explains how we collect, use, store, and protect your information when you interact with our website, products, and PAYGO services.

2. Information We Collect

A. Personal Information

Full name
Phone number
Email address
National ID number (for financing)
Physical address

B. Financial & Application Information

Employment and income details
M-PESA statements (when voluntarily submitted)
Credit assessment information
Payment history

C. PAYGO & Device Information

For PAYGO-enabled devices:

Device serial number
Device activation status
Payment compliance status
K-Lock system communication data

K-Lock communication is limited to system integrity, payment compliance, and operational functionality.

We do not access personal files, documents, photos, browsing history, or private content stored on your device.

D. Website & Technical Information

IP address
Browser type
Device type
Usage data
Cookies and analytics data

3. How We Use Your Information

We use personal data to:

Process PAYGO applications
Perform credit evaluation
Deliver and manage devices
Operate and enforce PAYGO agreements
Provide customer support
Improve services and infrastructure
Comply with legal obligations

We do not sell your personal data.

4. Device Monitoring & K-Lock

PAYGO devices may periodically communicate with our servers to:

Verify payment compliance
Confirm activation status
Maintain system integrity

If payment obligations are not met, device access may be restricted in accordance with your PAYGO agreement.

Monitoring does not include access to personal content.

5. Data Storage & International Transfers

Your data is stored on secure cloud infrastructure operated by Amazon Web Services (AWS).

AWS servers may be located outside Kenya.

By using our services, you acknowledge that your personal data may be transferred and stored outside Kenya in jurisdictions with different data protection laws.

We implement reasonable safeguards to ensure your data remains protected.