unauthorised image/photo use, lack of consent, unlawful data disclosure, failure to respond to erasure request, obstruction of data commissioner, failure to conduct dpia, unlawful processing, failure to register with odpc, failure to implement security measures
The ODPC upheld a complaint against Suo Motu Worldcoin Foundation Tools For Humanity Tools For Humanity Gmbh concerning unauthorised image/photo use, lack of consent, unlawful data disclosure. The determination considers s.21 DPA 2019, s.22 DPA 2019, s.23 DPA 2019, s.25 DPA 2019. An enforcement notice was issued against the respondent.
ODPC (Kenya), ODPC Complaint No. 1394 of 2023, investigation of 6 September 2023. African Data Protection Enforcement Tracker, Law Lab Africa Research, https://research.lawlab.africa/tracker/kenya/odpc/2023/suo-motu-worldcoin-foundation-tools-for-humanity-tools-for-h/ (accessed 22 July 2026).