Privacy Policy

1. Information We Collect

1.1 Personal Information

We collect information you provide directly, including:

• Name, email address, and contact information
• Employment details and professional background
• Financial information (for payment processing)
• Profile photographs and identification documents
• Communications you send to us

1.2 Automatically Collected Information

When you access our platform, we automatically collect:

• IP address and device identifiers
• Browser type and settings
• Usage data and interaction patterns
• Cookies and similar tracking technologies
• System logs and performance metrics

2. Legal Basis for Processing

Under the GDPR and Zambia Data Protection Act, we process your data based on:

• Consent: You have given clear consent for us to process your data
• Contract: Processing is necessary for a contract we have with you
• Legal Obligation: We must process your data to comply with the law
• Legitimate Interests: Processing is necessary for our legitimate interests (balanced against your rights)
• Vital Interests: To protect someone's life

3. How We Use Your Information

We use your information to:

• Provide, maintain, and improve our services
• Process transactions and send related information
• Send technical notices and support messages
• Communicate about products, services, and events
• Protect against fraud and unauthorized access
• Comply with legal obligations
• Analyze usage patterns and optimize user experience

4. Data Sharing & Third Parties

We may share your information with:

• Service Providers: Companies that perform services on our behalf (payment processors, cloud hosting, analytics)
• Business Partners: When you consent or direct us to share
• Legal Authorities: When required by law or to protect rights
• Affiliates: Companies under common ownership

We do not sell your personal information to third parties.

5. Data Retention

We retain your information for as long as your account is active or as needed to provide services. We will also retain and use your information to comply with legal obligations, resolve disputes, and enforce agreements.

Specific retention periods:

• Account data: Duration of account + 7 years (legal compliance)
• Transaction records: 7 years (tax and audit requirements)
• Communications: 3 years after last interaction
• Analytics data: 26 months (anonymized)

6. Your Rights

You have the right to:

• Access: Request copies of your personal data
• Rectification: Request correction of inaccurate data
• Erasure: Request deletion of your personal data ("right to be forgotten")
• Restrict Processing: Request limitation on how we use your data
• Data Portability: Receive your data in a machine-readable format
• Object: Object to processing based on legitimate interests
• Withdraw Consent: Withdraw consent at any time (where processing is consent-based)

To exercise these rights, contact us at privacy@mankuca.com

7. Cookies & Tracking

We use cookies and similar technologies to enhance your experience. See our Cookie Policy for detailed information.

8. International Data Transfers

Your information may be transferred to and processed in countries other than Zambia. We ensure appropriate safeguards are in place, including:

• Standard contractual clauses approved by regulatory authorities
• Adequacy decisions by relevant data protection authorities
• Binding corporate rules for intra-group transfers

9. Security Measures

We implement industry-standard security measures:

• Encryption in transit (TLS 1.3) and at rest (AES-256)
• Regular security audits and penetration testing
• Access controls and authentication mechanisms
• Continuous monitoring and incident response procedures
• Employee training on data protection

10. Children's Privacy

Our services are not directed to individuals under 18. We do not knowingly collect personal information from children. If we learn we have collected data from a child, we will delete it promptly.

11. Changes to This Policy

We may update this Privacy Policy periodically. We will notify you of material changes by:

• Posting the new policy on our platform
• Sending email notifications
• Displaying prominent notices

12. Compliance Frameworks

This policy aligns with:

• GDPR (General Data Protection Regulation - EU)
• Zambia Data Protection Act No. 3 of 2021
• CCPA (California Consumer Privacy Act)
• ISO 27001 Information Security Standards
• Google Play & App Store privacy requirements