KULA BOX APP DATA PRIVACY STATEMENT

1.0 Introduction

Your privacy is important to us. This privacy statement explains the personal data KulaBox App collects, how KulaBox App processes it, and for what purposes. This statement should be read together with the End User Agreement for the Kula Box App. Where there is a conflict, this statement will prevail. This statement applies to all customers, suppliers, agents, merchants, dealers and all visitors frequenting any of KulaBox’s websites.

2.0 Definitions

“You” means:

• Customer – the person who subscribes, uses or places orders for food, groceries, or other items from local businesses and has them delivered to their specified location using this App.

3.0 Statement Details

3.1 Collection of Information

We collect your personal information with your knowledge and consent when you do any of the following (not exhaustive):

• Place orders for food, groceries, or other items from local businesses and have them delivered to your specified location.
• Respond to or participate in surveys or marketing activities.
• Visit, access or use KulaBox App or third-party websites.
• Interact with us as a supplier, agent, or dealer.

3.2 What Information is Collected?

• Your identity details including name, address, location, phone number, email address, age, and gender.
• Your credit or debit card information.
• Your transaction information when you pay via Mpesa service.
• Your product preferences.
• Your contact with us (calls, interactions during orders).
• A register of callers.

3.3 Use of Your Information

We may use and analyze your information for purposes such as:

• Processing products that you have bought through KulaBox App.
• Billing you for products you have ordered.
• Responding to your queries or concerns.
• Informing you about new products and promotions (unless you opt out).
• Complying with legal or regulatory requirements.
• Quality control and effective operations.
• Understanding and improving our services.
• Preventing and detecting fraud or other crimes.
• Research, statistics, and surveys.
• Providing aggregated (non-identifiable) data to third parties.
• Administering our platforms.

3.4 Categories of Data

We may process categories of Personal Data as defined in the Data Protection Act of Kenya, depending on the products you use.

3.5 Lawful Basis for Processing

• Performance of a service agreement with you.
• Compliance with legal obligations.
• Consent you provide.
• Public interest.
• Your vital interests.

3.6 Retention of Information

We will only retain your personal data as long as necessary for the purposes collected, including legal, tax, accounting, or reporting obligations. Data may be retained longer in case of complaints or potential litigation. Anonymized data may be kept indefinitely.

3.7 Disclosure of Information

We may disclose your information to:

• Law enforcement, regulators, or courts when lawfully required.
• Subsidiaries, partners, software developers, or agents delivering your products.
• Fraud prevention, anti-money laundering, and credit reference agencies.
• Government databases for identity verification.
• Debt collection agencies.
• Survey agencies working on our behalf.
• Any other legitimate recipients.

We will not release information outside of the law and will obtain your express consent for direct marketing purposes.

We do not onboard minors (under 18) unless registered by a parent/guardian. If a child uses our services, their personal information may be collected as described.

4.0 Use of Cookies

We may store cookies on your device to recognize you during subsequent visits. These collect non-personal information such as IP address, visit times, and pages viewed. You can disable cookies in your browser, but some site features may not work properly.

5.0 Use of Hyperlinks

Our website may contain links to external sites. We are not responsible for their content, policies, or practices.

6.0 Access to and Updating Your Information

You can update your information anytime at https://kulabox.co.ke.

7.0 Safeguarding and Protection of Information

KulaBox App has implemented technical and operational measures such as access control, encryption, and monitoring to safeguard your data.

8.0 Your Rights

You have rights under data protection laws, including:

• Right to be informed of data collection.
• Right to access and request information on processing.
• Right to correction of inaccurate data.
• Right to request deletion (subject to legal obligations).
• Right to object or withdraw consent.
• Right to restrict processing.
• Right to request transfer of your data in electronic format.

To exercise your rights, contact us at: contact@kulabox.co.ke.

9.0 How to Contact Us

Email us at contact@kulabox.co.ke or submit a request via our platform.

10.0 Right to Lodge Complaint

You may lodge a complaint with the relevant Data Protection Authority in Kenya.

11.0 Non-Compliance

KulaBox App may terminate any agreement with you for failure to comply with this policy.

12.0 Amendments

KulaBox may amend this statement at any time. The most current version will always be accessible on our website.

Statement Effective Date:9/20/2023