Last Updated: 30 August 2026

1. Introduction

Revorray Limited (“Revorray”, “we”, “us”, or “our”) respects your privacy and is committed to protecting personal data entrusted to us.

This Privacy Policy explains how we collect, use, store, disclose, transfer and protect personal information when you:

visit or interact with our website;
request a quotation or information about our services;
communicate with us by email, telephone, messaging applications, online forms or social media;
engage us for interpretation, language translation, interpretation equipment rental, audio-visual, event or related services;
participate in an event, conference, meeting or assignment supported by Revorray;
work with us as an interpreter, translator, linguist, technician, consultant, contractor or supplier;
apply for employment or freelance opportunities with us; or
otherwise interact with Revorray.

This Privacy Policy is intended to explain our data-handling practices transparently and to help you understand your rights.

Revorray processes personal data in accordance with applicable data-protection legislation, including the Kenya Data Protection Act, 2019, the Data Protection (General) Regulations, 2021, and other applicable Kenyan laws.

Where the European Union General Data Protection Regulation (“GDPR”) or another applicable privacy law applies to particular processing activities, we will also process personal data in accordance with those requirements.

2. Who We Are

Revorray Limited provides professional language and event-related services, including:

simultaneous interpretation;
consecutive interpretation;
remote and online interpretation;
language translation;
interpretation equipment rental;
multilingual conference support;
audio-visual and technical event support; and
associated event and communication services.

For personal data collected for our own business purposes, Revorray will generally act as the data controller.

In certain circumstances, particularly where a client provides Revorray with documents, participant information, recordings or other personal information solely so that we can perform contracted interpretation, translation or event services, Revorray may act as a data processor on behalf of that client.

The exact role will depend on the circumstances and contractual relationship involved.

3. Scope of This Privacy Policy

This Privacy Policy applies to personal data processed through our website and business operations.

It may also apply to information received in connection with assignments performed for clients, subject to any separate data-processing agreement, confidentiality agreement, contract, privacy notice or instructions agreed between Revorray and the relevant client.

Where a client acts as the data controller and Revorray processes personal data solely on that client’s instructions, the client’s own privacy notice may also apply.

4. What Is Personal Data?

Personal data is information relating to an identified or identifiable natural person.

Depending on the circumstances, this may include information such as:

your name;
telephone number;
email address;
organisation;
job title;
physical or postal address;
identification information;
photographs or video images;
voice recordings;
payment or transaction information;
correspondence;
IP address;
device information;
online identifiers;
event registration information; and
information contained in documents submitted for interpretation or translation.

Some information may be considered sensitive personal data or a special category of personal data under applicable laws and may therefore receive additional protection.

5. Personal Data We May Collect

5.1 Contact and Identity Information

When you contact Revorray, request a quotation, submit an enquiry or engage our services, we may collect information including:

full name;
organisation or company name;
position or job title;
email address;
telephone number;
billing information;
physical or postal address; and
preferred method of communication.

5.2 Event and Project Information

When you request interpretation, translation, equipment rental or event services, we may process information including:

event name;
event date and location;
meeting schedules;
participant or delegate information;
speaker information;
organiser information;
language requirements;
interpreter assignments;
venue details;
travel and accommodation information where necessary;
access credentials;
event programmes;
presentations;
speeches;
agendas;
briefing documents;
terminology lists;
meeting materials; and
other information required to deliver the service.

5.3 Translation and Interpretation Content

Clients may provide Revorray with documents or content that contains personal information.

Examples may include:

reports;
contracts;
correspondence;
presentations;
certificates;
transcripts;
surveys;
interviews;
meeting documents;
research material;
employee information;
participant lists;
audio files;
video files; and
other materials requiring translation or interpretation.

The nature of this information depends entirely on the particular assignment.

We process such information only to the extent reasonably necessary to provide the requested service and fulfil our contractual, legal and professional obligations.

6. Sensitive Personal Data

Because of the nature of translation and interpretation work, materials provided by clients may occasionally contain sensitive personal information.

Depending on applicable law, this could include information concerning matters such as:

health;
biometric information;
family or private affairs;
ethnicity or racial origin;
religious or philosophical beliefs;
sexual life or sexual orientation;
political opinions;
financial information;
identification information; or
other legally protected information.

Revorray does not ordinarily request sensitive personal information unless it is genuinely required for a particular service or has been included in material provided by a client.

Where sensitive personal data is processed, we apply additional care and process it only where an appropriate lawful basis and safeguards exist.

Clients providing sensitive information to Revorray are responsible for ensuring that they have the authority and appropriate lawful basis to disclose such information to us.

7. Information Collected Through Our Website

When you visit our website, certain technical information may be collected automatically.

This may include:

IP address;
browser type;
device type;
operating system;
approximate geographic region;
pages visited;
referring website;
date and time of access;
session duration;
website interactions; and
technical diagnostic information.

This information may be collected through server logs, cookies or similar technologies.

We primarily use this information to maintain website security, understand website performance, improve user experience and evaluate how visitors use our website.

8. Information You Provide Through Forms

When you use a quotation, enquiry, contact or similar form on our website, we may collect the information entered into that form.

Depending on the form, this may include:

name;
email address;
telephone number;
company;
event location;
required language;
service required;
number of participants;
event date;
message or project description; and
documents or files you choose to upload.

Please avoid submitting unnecessary sensitive personal data through general website enquiry forms.

9. Information Received From Other Sources

We may receive personal information indirectly from:

our clients;
event organisers;
conference venues;
partner organisations;
professional interpreters or translators;
suppliers;
contractors;
publicly available professional sources;
organisations representing you;
booking or event-management systems; or
other parties involved in delivering a project.

For example, an organisation arranging an international conference may provide us with the names and contact information of speakers, interpreters, technicians or participants so that we can coordinate the event.

10. How We Use Personal Data

Revorray may use personal data to:

Provide our services

This includes planning, managing and delivering interpretation, translation, equipment rental, technical and event services.

Respond to enquiries

We use contact details and enquiry information to respond to questions, prepare quotations and discuss potential assignments.

Manage client relationships

We may use information to administer contracts, coordinate projects, communicate about assignments, maintain records and provide customer support.

Coordinate interpreters, translators and technical teams

Personal information may be used to identify, schedule, brief and communicate with professionals assigned to a project.

Process payments and financial records

We may process billing, transaction and related information for invoicing, accounting, taxation and financial administration.

Operate and improve our website

Technical information may be processed to monitor website performance, improve usability and diagnose problems.

Protect our systems

We may process technical and security information to prevent fraud, misuse, cyberattacks, unauthorised access and other security threats.

Meet legal obligations

We may retain or disclose information where reasonably necessary to comply with tax, accounting, regulatory, court, law-enforcement or other legal requirements.

Establish or defend legal claims

Information may be processed where necessary to establish, exercise or defend legal rights.

Improve our services

Where appropriate, we may analyse non-sensitive project and customer information to understand service performance and improve our operations.

Where possible, aggregated or anonymised information will be used for analytical purposes.

11. Our Lawful Bases for Processing Personal Data

Depending on the circumstances, Revorray may rely on one or more legally recognised grounds for processing personal information.

Contract

Processing may be necessary to perform a contract with you or take steps at your request before entering into a contract.

For example, we may need your event details to prepare an interpretation-services quotation.

Consent

Where required, we may ask for your consent before processing particular information.

Where processing depends on consent, you may withdraw that consent, subject to applicable law.

Withdrawal does not affect processing that was lawful before consent was withdrawn.

Legal Obligation

We may process personal data where necessary to comply with laws applicable to our business.

Legitimate Interests

We may process information where necessary for legitimate business interests, provided those interests do not unfairly override your rights and freedoms.

Examples may include:

administering our business;
protecting our systems;
preventing fraud;
improving our services;
managing professional relationships; and
establishing or defending legal claims.

Vital Interests

In exceptional circumstances, information may be processed where necessary to protect someone’s life or vital interests.

Other Lawful Grounds

Where applicable, we may rely on another lawful basis recognised under Kenyan or other applicable data-protection law.

12. Marketing Communications

Revorray may occasionally communicate with existing or prospective clients about relevant services, updates or opportunities where permitted by applicable law.

Where consent is required for direct marketing, we will seek appropriate consent.

You can unsubscribe from marketing communications at any time by:

using the unsubscribe mechanism provided in the communication; or
contacting Revorray directly.

Opting out of marketing does not prevent us from sending necessary communications relating to an existing enquiry, quotation, contract, project, invoice or business relationship.

We may maintain a minimal suppression record after an opt-out so that we can respect your preference and avoid sending further marketing communications.

13. Cookies and Similar Technologies

Our website may use cookies and similar technologies.

A cookie is a small piece of information stored on a device when a user visits a website.

Cookies may be used for purposes including:

keeping the website functioning properly;
remembering user preferences;
maintaining security;
measuring website performance;
understanding visitor behaviour; and
supporting marketing activities where applicable.

Essential Cookies

These cookies are required for the basic operation, security or functionality of the website.

They may not require consent where they are strictly necessary.

Analytics Cookies

Where enabled, analytics cookies may help us understand how visitors interact with the website, including which pages are visited and how users navigate the site.

Where legally required, these cookies will be activated only after appropriate consent.

Functional Cookies

These may enable optional website features or remember choices made by visitors.

Marketing Cookies

If Revorray uses advertising or remarketing technologies, marketing cookies may be used to measure campaigns or deliver relevant advertisements.

Where required by law, marketing cookies will not be activated before obtaining consent.

Visitors should be provided with a mechanism to manage non-essential cookie preferences where applicable.

Browser settings may also allow users to block or delete cookies.

Disabling certain cookies may affect some website functionality.

14. Analytics and Third-Party Website Technologies

Revorray may use reputable technology providers to operate, secure, host, analyse or improve the website.

Depending on the technologies enabled on the website, these providers may process technical information such as IP addresses, device identifiers, browser information and usage statistics.

Before publishing this policy, Revorray should ensure that any analytics, advertising, embedded-video, chat, form, map, social-media or similar third-party technologies actually installed on the website are reflected accurately in its privacy and cookie disclosures.

15. Interpretation and Translation Confidentiality

Confidentiality is particularly important to Revorray because interpreters, translators and technical personnel may encounter private information while performing assignments.

Personnel and contractors who require access to confidential project information should receive only the level of access necessary to perform their responsibilities.

Where appropriate, Revorray may use:

confidentiality clauses;
non-disclosure agreements;
contractual confidentiality obligations;
limited-access systems;
controlled document sharing; and
project-specific confidentiality requirements.

Client materials should not be used for unrelated purposes.

16. Audio, Video and Event Recordings

Interpretation and event services may involve live audio, video conferencing, virtual-event platforms or other communication systems.

Audio or video should not be recorded by Revorray merely because interpretation services are being provided.

Where recording, transcription or storage forms part of an agreed service, the treatment of that information will depend on:

the client’s instructions;
contractual arrangements;
applicable laws;
participant notices or permissions where required; and
the technical platform used.

Clients are responsible for ensuring that participants receive any notices or provide any permissions legally required for recordings controlled by the client.

17. Remote Interpretation and Virtual Platforms

Online and hybrid interpretation may involve third-party conferencing, streaming or communication platforms.

Depending on the project, participants’ names, email addresses, voices, video feeds, chat messages, IP addresses or other technical information may be processed through those platforms.

Such third-party platforms may operate under their own privacy policies and terms.

Where a platform is selected by the client, the client remains responsible for evaluating the platform’s suitability for its intended use.

Revorray will take reasonable steps to protect information within the systems and processes under our direct control.

18. Interpretation Equipment

Some interpretation equipment, conference platforms or event technologies may generate technical logs or device information.

Where such information contains personal data, it will be handled in accordance with this Privacy Policy and used only where reasonably necessary for purposes such as:

operating the event;
troubleshooting;
security;
technical support; and
service administration.

19. Who We May Share Personal Data With

Revorray does not sell personal information.

Personal information may, however, be shared where reasonably necessary with organisations or individuals involved in delivering our services.

These may include:

professional interpreters;
translators;
linguists;
event technicians;
equipment suppliers;
subcontractors;
consultants;
conference venues;
logistics providers;
travel providers where applicable;
IT providers;
website hosting providers;
cloud-storage providers;
communications providers;
accounting professionals;
auditors;
legal advisers;
payment providers;
banks;
insurers;
professional advisers; and
regulatory or governmental authorities where legally required.

Recipients should receive only information reasonably necessary for the relevant purpose.

Where an external provider processes personal information on our behalf, appropriate contractual and data-protection arrangements should be established where required.

20. Client-Provided Personal Data

A client may provide personal information concerning employees, speakers, delegates, customers, research participants, contractors or other individuals.

Where Revorray processes that information solely to perform services on behalf of the client, the client is generally responsible for establishing the appropriate lawful basis for collecting and providing the information.

Revorray will process such information in accordance with:

the client’s lawful instructions;
applicable contractual obligations;
applicable confidentiality requirements; and
applicable data-protection law.

We encourage clients to avoid sending personal information that is unnecessary for completion of the relevant assignment.

21. Interpreters, Translators, Contractors and Suppliers

Where you work with or provide services to Revorray, we may collect information including:

contact details;
professional qualifications;
languages;
experience;
CV or professional profile;
availability;
identification information where necessary;
payment details;
tax information;
assignment history;
performance information;
references; and
contractual records.

This information may be used to evaluate suitability, allocate assignments, communicate about projects, process payments, maintain professional records and satisfy contractual or legal requirements

22. Recruitment

If you apply for employment, internship, freelance work or another opportunity with Revorray, we may process information contained in:

CVs;
application letters;
qualification documents;
professional profiles;
references;
correspondence;
interview records; and
other application material.

We use this information to evaluate applications, communicate with candidates and manage recruitment.

Information relating to unsuccessful applications will not be retained indefinitely and will be deleted or anonymised when no longer reasonably required, subject to applicable law and legitimate business needs.

23. Payment Information

Where payments are made to Revorray, financial transactions may be processed through banks, mobile payment providers, payment-service providers or other financial institutions.

Revorray may maintain transaction information necessary for:

confirming payments;
issuing invoices or receipts;
reconciliation;
accounting;
taxation;
fraud prevention; and
legal compliance.

We do not intentionally collect or store complete payment-card credentials where payment processing is handled by an external authorised payment provider.

Third-party financial institutions process information according to their own legal and privacy obligations.

24. International and Cross-Border Data Transfers

Revorray operates in a business environment where clients, interpreters, translators, technology providers and project participants may be located in different countries.

Personal data may therefore sometimes need to be transferred, accessed or stored outside Kenya.

For example, international transfers may arise through:

cloud-hosting services;
email services;
remote interpretation platforms;
international clients;
overseas interpreters or translators; or
global technology providers.

Where personal data is transferred outside Kenya, Revorray will take steps required by applicable law to establish an appropriate lawful basis and level of protection.

Depending on the circumstances, this may include:

appropriate contractual safeguards;
transfers to jurisdictions offering adequate protection;
transfers necessary for the performance of a contract;
another legally recognised necessity; or
the data subject’s consent where applicable.

Additional safeguards may be applied for sensitive personal data.

25. How Long We Keep Personal Data

Revorray does not intend to retain identifiable personal data indefinitely.

Retention depends on the type of information, the reason it was collected, contractual obligations, applicable laws and legitimate business requirements.

For example:

Website enquiries

Enquiry records may be retained for a reasonable period after the last meaningful communication in case the prospective client returns or the communication is required for business records.

Client and project records

Contracts, quotations, project correspondence and service records may be retained for the duration of the client relationship and for an appropriate period afterwards to address contractual, legal, accounting or dispute-related requirements.

Financial information

Invoices, transaction records and accounting information may be retained for the period required under applicable financial, accounting and tax law.

Translation and project materials

Source documents, translated material and temporary working files should be retained only for the period reasonably required to provide the service, conduct quality assurance, address agreed revisions or meet contractual or legal requirements.

Particularly sensitive project material may be subject to shorter project-specific retention arrangements.

Marketing information

Marketing contact information may be retained while a person remains subscribed or while another appropriate lawful basis exists.

Recruitment information

Candidate records may be retained for a reasonable period following recruitment unless longer retention is agreed or legally required.

When personal data is no longer reasonably required, we may securely delete, destroy, anonymise or pseudonymise it as appropriate.

26. Data Security

Revorray recognises that no organisation can guarantee absolute security of information.

We nevertheless seek to implement technical and organisational safeguards appropriate to the nature and sensitivity of personal information being processed.

Depending on the relevant system and risk, safeguards may include:

controlled access to information;
authentication measures;
password protection;
encryption where appropriate;
secure website connections;
access limitation based on responsibilities;
confidentiality obligations;
secure backups;
software and system updates;
protection against malware and unauthorised access;
controlled sharing of project files;
secure deletion procedures; and
staff or contractor awareness of confidentiality and privacy requirements.

Our security measures are reviewed and adjusted where appropriate to address changes in technology and risk.

27. Personal Data Breaches

A personal data breach may include the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of or access to personal information.

Where Revorray becomes aware of a personal data breach, we will investigate the incident and take reasonable steps to contain and address it.

Where notification is required by applicable data-protection law, we will notify the appropriate data-protection authority and/or affected individuals in accordance with the applicable legal requirements.

28. Your Data Protection Rights

Depending on the circumstances and applicable law, you may have rights concerning your personal data.

These may include the right to:

Be informed

You have a right to understand how your personal information is collected and used.

Access your personal information

You may request confirmation of whether we hold personal information about you and request access to that information.

Correct inaccurate information

You may ask us to correct information that is inaccurate, outdated, incomplete or misleading.

Request deletion

You may request deletion of personal data where Revorray no longer has an appropriate reason or legal authority to retain it.

This right may be subject to legal, contractual or other permitted retention requirements.

Object to processing

You may object to certain processing of your personal information, subject to applicable legal grounds.

Request restriction of processing

In applicable circumstances, you may request that processing of your information be temporarily or permanently restricted.

Data portability

Where applicable, you may request eligible personal information in a structured, commonly used and machine-readable form or request transfer to another organisation where technically feasible.

Withdraw consent

Where processing relies on your consent, you may withdraw that consent.

Withdrawal will not make previous lawful processing invalid.

Object to direct marketing

You may object to the use of your personal information for direct marketing.

Rights relating to automated decision-making

Where applicable, you may have rights concerning decisions based solely on automated processing that significantly affect you.

Revorray does not currently intend to make significant decisions about clients or website visitors based solely on automated profiling.

29. Exercising Your Rights

To exercise a privacy right, contact Revorray using the contact information provided at the end of this Privacy Policy.

Please clearly describe:

who you are;
the information concerned; and
what action you would like us to take.

We may request reasonable information to confirm your identity before providing access to or changing personal information.

This helps prevent information from being disclosed to an unauthorised person.

We will respond within the period required by applicable law.

Some requests may be subject to lawful limitations, particularly where disclosure would adversely affect another person’s rights, conflict with legal obligations or compromise confidential information.

30. Complaints

If you believe Revorray has processed your personal information improperly, please contact us first so that we can investigate and attempt to resolve the concern.

You may also have the right to submit a complaint to the Office of the Data Protection Commissioner of Kenya (ODPC) or another competent supervisory authority where applicable.

The ability to complain to a regulatory authority does not prevent you from contacting Revorray directly.

31. Children’s Privacy

Revorray’s website and commercial services are primarily intended for businesses, organisations and adult professionals.

We do not knowingly seek personal data directly from children through our general website services.

However, events or documents handled for clients may occasionally contain information relating to children.

Where personal data relating to a child must be processed, appropriate safeguards and legally required parental or guardian consent should be applied.

Where Revorray processes children’s data solely on behalf of a client, the client is responsible for ensuring that it has the appropriate lawful authority and notices required for the processing.

If you believe a child has provided personal information directly to us without appropriate authorisation, please contact us.

32. Third-Party Websites

Our website may contain links to third-party websites or services.

Revorray does not control the privacy practices, security or content of independent third-party websites.

Clicking an external link may allow another organisation to collect information about you.

You should review the privacy policy of the relevant third-party website before providing personal information.

33. Social Media

Revorray may maintain accounts on social-media platforms.

When you interact with our social-media pages, both Revorray and the relevant platform may process information about your interaction.

Social-media platforms operate under their own terms and privacy policies.

Information you voluntarily make public on social-media services may be visible to other users.

We recommend avoiding publication of confidential or sensitive information through public comments.

34. Business Transfers

If Revorray undergoes a merger, acquisition, restructuring, financing, sale of assets or similar corporate transaction, relevant business records may form part of that transaction.

Where personal information is involved, appropriate confidentiality and data-protection safeguards will be applied as required by law.

35. Disclosure Required by Law

Revorray may disclose personal information where we reasonably believe disclosure is required to:

comply with applicable law;
comply with a lawful court order;
respond to a lawful regulatory or governmental request;
investigate suspected fraud or unlawful activity;
protect the rights, property or safety of Revorray, our clients or others;
establish, exercise or defend legal claims; or
fulfil another legally recognised obligation.

We will seek to disclose only information reasonably necessary for the relevant purpose.

36. Automated Decision-Making

Revorray does not currently intend to use automated systems to make decisions that produce legal or similarly significant effects on website visitors or clients without meaningful human involvement.

If this changes, appropriate notices, safeguards and rights will be provided as required by applicable law.

We may use ordinary automated technologies for purposes such as spam detection, security, website analytics, email routing or administrative efficiency.

37. Data Minimisation

We seek to collect and process only information reasonably necessary for the relevant service or purpose.

Clients and website users are encouraged not to send unnecessary personal or sensitive information.

Where practical, project materials may be anonymised, redacted or limited before they are provided to interpreters, translators, technicians or other personnel.

38. Accuracy of Information

We take reasonable steps to keep personal information accurate and up to date where accuracy is relevant to the purpose for which the information is processed.

You may help us by notifying Revorray if your contact details or other personal information change.

39. Confidentiality Obligations

Employees, contractors, interpreters, translators and other professionals working with Revorray may be subject to confidentiality obligations appropriate to their role.

Access to confidential client information should be restricted to individuals who reasonably need the information to deliver the relevant service.

Confidential information received during interpretation or translation assignments should not be disclosed or used for unrelated purposes.

40. Changes to This Privacy Policy

Revorray may update this Privacy Policy periodically to reflect:

changes in our services;
changes in technology;
changes in our website;
new business processes;
regulatory guidance; or
changes in applicable law.

The updated version will be published on our website with a revised “Last Updated” date.

Where changes materially affect how personal information is processed, we may provide additional notice where appropriate.

We encourage website visitors and clients to review this Privacy Policy periodically.

41. Governing Data Protection Framework

Revorray is established in Kenya and primarily operates under Kenyan law.

Our personal-data handling practices are therefore principally governed by applicable Kenyan privacy and data-protection legislation, including the Data Protection Act, 2019 and regulations made under it.

Where our activities are subject to privacy laws in another jurisdiction, including the GDPR, applicable provisions of those laws will also be observed to the extent required.

42. Contact Revorray About Privacy

Questions, concerns or requests relating to this Privacy Policy or the processing of personal information may be addressed to:

Revorray Limited
Privacy / Data Protection Contact

Email: privacypolicy@revorray.com

Telephone: +254 708 819 576

Postal / Physical Address:
Gifan Plaza, Miriams Rd. KItengela. Kajiado County. Kenya

Website: www.revorray.com

Please include “Data Protection Request” in the subject line where appropriate so that your request can be directed to the relevant person promptly.

43. Complaints to the Office of the Data Protection Commissioner

Individuals in Kenya also have the right, where applicable, to raise concerns regarding personal-data processing with the:

Office of the Data Protection Commissioner (ODPC)
Kenya

Current contact information and complaint procedures are available through the official ODPC website.

Individuals located outside Kenya may also have the right to contact the competent data-protection authority in their country or region where applicable.

44. Acceptance and Use of Our Services

This Privacy Policy provides information regarding Revorray’s personal-data practices.

Where consent is the lawful basis for a particular processing activity, Revorray will obtain consent in the manner required by applicable law rather than treating general website use as blanket consent to all forms of personal-data processing.

Specific services may also be subject to contracts, service agreements, event notices, consent forms, data-processing agreements, confidentiality agreements or other terms that supplement this Privacy Policy.