Privacy Notice

Last updated: November 7, 2026

1. Who this covers

LSL Group INC and LSL Group INC Limited ("we," "us") operate Overten Scout. This Privacy Notice explains how we handle personal data for Scout. It covers sellers, buyers, website visitors, and people whose public posts Scout finds. It adds to the Overten Privacy Policy (overten.ai/legal/privacy), which also applies. If they differ, this notice applies to Scout.

We are the controller of the personal data described here, which means we decide how and why it is used. Sellers are separately responsible for what they do with people's details once they receive them.

2. What we collect

2.1 Account details

Name, email address and phone number.
How you signed in, and the codes and sessions used to verify you.
Your acceptance of the terms, and the time of it.

2.2 WhatsApp conversations with Scout

Your WhatsApp number and profile name.
Messages, button taps, and photos you send.
What you asked for, including budget, place and preferences, and which listings you were shown.

2.3 Seller and business details

Business name, country, description, contact details and logo.
Products, prices, photos and videos.
Websites and social pages you give us, and posts read from them.
Connected accounts, within the permissions you grant.
Agents, search phrases, workflows, alerts, and how you mark potential buyers.

2.4 Public posts

The author's public name or handle, and profile link.
What they wrote, and the post's date and link.
Public details that indicate location or what they want.
The score, match and draft reply generated from it.

2.5 Payments

Credit purchases, balances, top-up references and amounts. Paystack processes payments, and we do not store full card or mobile money details.

2.6 Technical data

IP address, browser and device details, pages visited, logs, and error reports. We use cookies needed for sign-in and security. Section 15 has more detail.

2.7 Messages to us

What you send through the contact form, by email or to support, and your email address if you subscribe to Scout updates. You can unsubscribe at any time by emailing us.

3. If Scout found your public post

Scout searches public posts for people asking to buy something. If yours matches what a business sells, Scout may store it and show that business your public name or handle, your words, and a link to your post. The business may then choose to reply to you.

Scout itself does not contact you and does not post anything. We look only at what is public, or what a connected account owner has allowed. We use it because we have a legitimate interest in connecting people asking for something with those who sell it, balanced against your rights.

You can object at any time. To have your details removed and to ask that they are not used again, email info@lslgroupinc.com with a link to the post. Deleting a post on the network does not automatically remove copies we hold, so please tell us.

4. How we use data, and why

Where the law requires a legal basis, including the Data Protection Act, 2019 of Kenya and the GDPR, we rely on the following:

To provide Scout: accounts, conversations, listings, searches, matching, alerts and replies (contract, and legitimate interests).
To connect buyers and sellers, including passing a buyer's request to sellers (contract, and legitimate interests, or consent where the law requires it).
To find potential buyers from public posts (legitimate interests).
To read photos, websites and posts, score potential buyers and write drafts (contract, and legitimate interests).
To take payment and keep financial records (contract, and legal obligation).
To secure Scout and prevent fraud, spam and abuse (legitimate interests, and legal obligation).
To improve Scout, including improving a seller's scoring from that seller's own verdicts (legitimate interests).
To meet legal duties and to establish or defend legal claims (legal obligation, and legitimate interests).
To send service messages, and marketing only where allowed (contract, legitimate interests, or consent).

5. Automated scoring and AI

Scout uses automated systems, including AI models from third-party providers, to understand messages, photos and posts, and to produce scores and draft replies. A score estimates how likely a person is to want something, for the seller's use. Scores do not produce legal effects on anyone, and a seller decides whether to act on them.

Content may be sent to AI providers to produce these results. We do not use your content to train AI models for others, and we do not allow our providers to do so, as the Overten Privacy Policy describes.

6. When we share data

6.1 Between buyers and sellers

Buyers: sellers may receive what you asked for, your WhatsApp profile name, a link to your WhatsApp number, and any photo or note you sent. This happens when you tap I'm interested or ask to be connected, and it can also happen when your request matches a seller's listing.

Sellers: buyers and the public can see what you publish, including your business name, listings, prices, photos and the contact details you provide.

6.2 Service providers

We use providers to run Scout, under contract to protect data and use it only for us. They include Meta (WhatsApp), Google (hosting, database, sign-in and email delivery infrastructure), Apify (reading public posts and websites), Paystack (payments), Telegram where you choose it, and AI providers. Overten's list of sub-processors is at overten.ai/subprocessors.

6.3 Legal reasons and business changes

We may disclose data where the law, a court or an authority requires it, or to protect rights, safety or property, or to investigate fraud. If we are part of a merger, acquisition, financing or sale of assets, data may transfer as part of it, and we will tell you of any resulting change.

6.4 No sale of personal data

We do not sell personal data, and we do not use your conversations for third-party advertising.

7. How long we keep data

Account, business and product data: while your account is active, then deleted within 30 days of account deletion, unless the law requires otherwise.
Conversations with Scout: for as long as needed to provide Scout and keep a record of what was offered, and deleted on request where the law gives you that right.
Potential buyers: while they are useful to the seller's account. Those held for credits may be dropped after 3 days.
Billing records: for the period tax and accounting law requires, typically up to 7 years.
Support messages and logs: up to 24 months, for quality and security.

We may keep limited data for longer where we need it to resolve disputes, prevent abuse or meet the law, for example a record that you asked not to be contacted.

8. Security

We use technical and organizational measures designed to protect data, including encryption in transit and at rest, access controls and monitoring. No system is completely secure. Keep your phone, WhatsApp and email safe.

If a breach affects your personal data, we will notify you and the relevant authority where the law requires it, without undue delay.

9. International transfers

We are based in the United States and Kenya, and our providers operate in other countries. Your data may be transferred to and processed in the United States and elsewhere, including countries with different data protection laws. Where the law requires it, we use appropriate safeguards, such as contractual protections.

10. Your rights

Subject to the law where you live, you may have the right to:

Be told how your data is used.
Access the data we hold about you.
Correct data that is wrong or misleading.
Delete data that we no longer need or have no right to keep.
Object to processing, including of your public posts and for direct marketing.
Restrict processing.
Receive your data in a portable format.
Withdraw consent, where we rely on it.
Not be subject to decisions based solely on automated processing that significantly affect you.

To use a right, email info@lslgroupinc.com. We will respond within 30 days or the time the law requires, and may need to verify your identity. You can also complain to your data protection authority.

11. If you are in Kenya

Your rights come from the Data Protection Act, 2019, and its regulations. You can complain to the Office of the Data Protection Commissioner of Kenya. Our Kenyan entity is LSL Group INC Limited, Viewpark Towers, 12146, Nairobi 00400.

12. If you are in the EEA, UK, Switzerland or California

The Overten Privacy Policy (overten.ai/legal/privacy) sets out the additional rights that apply to you, and how to use them.

13. Children

Scout is not for anyone under 16, and we do not knowingly collect their data. If you believe a child has given us data, email info@lslgroupinc.com and we will delete it.

14. Sellers' own use of data

Sellers are independent of us. If a seller has your details, you can ask them directly how they use them. Tell us if a seller misuses your details, and we may act on their account.

15. Cookies

The Scout website uses cookies and similar storage that are needed to keep you signed in, protect your account and resume a chat. We do not currently use advertising cookies on Scout. The Overten Privacy Policy has more about cookies and your choices.

16. Changes to this notice

We may update this notice. We will change the date on this page and tell you about material changes.

17. Contact

Email: info@lslgroupinc.com

United States: LSL Group INC, 1111B S Governors Ave STE 20111, Dover DE 19904, USA.

Kenya: LSL Group INC Limited, Viewpark Towers, 12146, Nairobi 00400, Kenya.

Overten Scout is a product of LSL Group INC.