Privacy Policy

Last updated: August 2026

1. Introduction

This Privacy Policy describes how Kwacha Kulture B.V. (“Kwacha Kulture”, “we”, “us”), a company incorporated in the Netherlands, handles personal information across our websites, applications, and services (together, the “Platforms”). By using our Platforms, you agree to the practices described here.

Data controller. Kwacha Kulture B.V., registered with the Netherlands Chamber of Commerce (Kamer van Koophandel) under number 42111800, at 's-Gravenweg 657, Rotterdam, Zuid Holland, Netherlands, is the controller of the personal information described in this policy. You can reach us at privacy@kwachakulture.com during business hours (Mon–Fri, 09:00–17:00 CET).

Because our controlling entity is established in the European Union, we apply the EU General Data Protection Regulation (GDPR) to our processing of personal information, wherever in the world you use our Platforms.

2. Information we collect

We collect information in a few ways:

• Information you give us — such as your name, username, email address, and profile details when you create an account or contact us.
• Content you create — the posts, media, listings, messages, and other content you choose to share on our Platforms.
• Transaction information — records of purchases, payouts, and other activity needed to provide our services. Payment card and banking details are handled by our payment providers, not stored by us.
• Usage and device information — basic technical information your browser or device shares automatically, such as general location, device type, and how you interact with our Platforms, used to keep them secure and working well.

3. Information collected through our mobile apps

Our mobile apps collect the categories below. These are the same categories we declare in the Google Play Data safety form and in Apple’s App Privacy details.

• Personal info — name, username, email address, profile photo, and your user ID.
• Photos and videos — on Tunzela, the videos and images you upload, together with their captions, thumbnails, and any metadata you add. Uploaded video is stored on our infrastructure so it can be played back to the audience you choose.
• Audio — audio contained in the video you upload, and audio tracks you select for it.
• App activity — in-app actions such as views, likes, follows, comments, shares, searches, and screens visited, used to run feeds and recommendations and to measure how features perform.
• Financial info — your purchase history and your Tova balance (the virtual currency you buy and spend in-app) and Mavu balance (the earnings you can withdraw), together with the transaction records behind them. We do not collect or store card numbers.
• App info and performance — crash logs, diagnostics, and performance data.
• Device or other IDs — a device or installation identifier, and a push notification token where you enable notifications.
• Approximate location — derived from your IP address, for security, fraud prevention, and region-appropriate content. We do not collect precise GPS location unless you explicitly grant it for a feature that needs it.
• Camera, microphone, and contacts — only where you grant the permission, and only to let you record or upload content or find people you already know. We do not upload your contact list in the background.

We do not sell this information, and we do not use it for third-party advertising.

4. Analytics, push notifications, and third-party SDKs

Our apps include software development kits (SDKs) from third parties that process limited information on our behalf:

• Push notifications — Firebase Cloud Messaging (Google) delivers notifications to your device. It processes a push token tied to your app installation. You can turn notifications off in your device settings at any time, which revokes the token.
• Analytics and crash reporting — Firebase Analytics and Crashlytics (Google), alongside our own self-hosted analytics, record app usage, crashes, and performance so we can find and fix problems. Our self-hosted analytics keeps that data on our own infrastructure.
• Payments — our payment providers process the details needed to take a payment or make a payout, under their own privacy terms.

These providers act as our processors and may only use the data to provide their service to us. Where a provider is outside the European Economic Area, the transfer safeguards described below apply.

5. How we use your information

• To provide, operate, and improve our Platforms and features.
• To create and manage your account and process your transactions and payouts.
• To personalise content and recommendations relevant to you.
• To communicate with you about updates, security, and support.
• To keep our Platforms safe, prevent fraud and abuse, and comply with the law.

6. Legal bases for processing

Where the GDPR applies, we process personal information on the basis of your consent, to perform our contract with you, to pursue our legitimate interests in operating and improving our Platforms, and to comply with our legal obligations. You may withdraw consent at any time where processing is based on it.

7. How we share information

We do not sell your personal information. We share it only as needed:

• Service providers — trusted third parties that help us operate, such as payment, hosting, communications, and analytics providers, who may only use it to provide services to us.
• Other users — content and profile details you choose to make public are visible to others, as you would expect on a social or marketplace platform.
• Legal and safety — where required by law, or to protect the rights, safety, and security of our users and Platforms.
• Business transfers — in connection with a merger, acquisition, or reorganisation, subject to this policy.

8. Payments

Payments and payouts are processed by established third-party payment providers. We do not store full card numbers or banking credentials. Those providers process your payment information under their own privacy terms.

9. Cookies and similar technologies

We use cookies and similar technologies to keep you signed in, remember your preferences, keep our Platforms secure, and understand how they are used. You can control cookies through your browser settings; disabling some may affect how the Platforms work.

10. Data retention

We keep personal information only for as long as needed to provide our services, comply with legal obligations, resolve disputes, and enforce our agreements. When it is no longer needed, we delete or anonymise it.

11. Your rights

Depending on where you live, you may have the right to:

• Access the personal information we hold about you.
• Correct information that is inaccurate or incomplete.
• Delete your information, subject to legal limits.
• Object to or restrict certain processing, and request portability of your data.
• Withdraw consent and lodge a complaint with your local data protection authority — in the Netherlands, the Autoriteit Persoonsgegevens.

To exercise any of these rights, contact us using the details below.

12. International transfers

We operate across borders, so your information may be processed in countries other than your own. Where we transfer data internationally, we take steps to ensure it remains protected in line with applicable law.

13. Security

We use appropriate organisational and technical measures to protect your information. Sensitive details such as payment credentials are protected by our payment providers. No system is perfectly secure, but we work continuously to safeguard your data.

14. Children’s privacy

Our Platforms are not directed to children under the age required by local law to consent to online services, and we do not knowingly collect their personal information. If you believe a child has provided us information, please contact us and we will take appropriate steps.

15. Changes to this policy

We may update this policy from time to time. When we make material changes, we will update the date above and, where appropriate, notify you. Continued use of our Platforms means you accept the updated policy.

16. Contact us

Questions about this policy or your personal information? Contact Kwacha Kulture B.V., KvK 42111800, 's-Gravenweg 657, Rotterdam, Zuid Holland, Netherlands — or email privacy@kwachakulture.com. We answer during business hours, Mon–Fri, 09:00–17:00 CET.