KWAHERI BY ZELORA PRIVACY POLICY

Legal Entity: Zalen Ltd, Kenya
Product: Kwaheri by Zelora
Support Contact (Active): support@myzelora.com (Please direct all legal, support, and privacy queries here)

This Privacy Policy explains how Kwaheri by Zelora collects, uses, stores, protects, shares, and retains personal information.

Kwaheri is used to create digital memorials, mini-obituaries, e-eulogies, anniversary pages, tributes, contribution pages, candle lighting, memories, downloads, collaboration tools, and related remembrance experiences.

We understand the sensitive nature of memorial content and aim to handle information respectfully and lawfully.

1. Data Controller

Zalen Ltd is the data controller for personal data processed through Kwaheri.

This means Zalen Ltd determines how and why personal data is collected and used.

The ODPC identifies a data controller as the person or entity that determines how personal data is used.

2. Who This Policy Applies To

This Policy applies to:

• Account creators.
• Memorial Administrators.
• Collaborators.
• Editors.
• Moderators.
• Treasurers.
• Contributors.
• Visitors.
• People leaving tributes.
• People uploading photos, videos, memories, or candles.
• People making contributions.
• People requesting withdrawals.
• People contacting support.
• People interacting with Public or Private Memorials.

3. Important Notice About Memorial Content

Kwaheri Memorials may include:

• Deceased person details.
• Living family member details.
• Photos.
• Videos.
• Tributes.
• Funeral details.
• Contribution information.
• Locations.
• Contact people.
• Religious or cultural information.

Public Memorials may be visible to anyone with access to the link and may be indexed, cached, screenshotted, copied, or shared by third parties outside Kwaheri’s control.

Users should only publish content they are comfortable sharing and have authority to share.

4. Information We Collect

4.1 Account Information

We may collect:

• Full name.
• Email address.
• Phone number.
• Profile photo.
• Login method.
• Password or authentication details.
• OTP logs.
• Google/Facebook login details where used.
• Communication preferences.
• Account status.

4.2 Memorial Information

Users may provide:

• Full name of deceased.
• Preferred name or nickname.
• Date of birth.
• Date of death.
• Age at death.
• Family announcement.
• Biography.
• Life story.
• Cause or context of death, where provided.
• Photos.
• Videos.
• Voice notes.
• Funeral details.
• Burial details.
• Livestream links.
• Family member details.
• Tribute categories.
• Hymns.
• Order of service.
• Anniversary reflections.

4.3 Living Individual Information

Memorials may contain personal data of living people, including:

• Names of relatives.
• Photos or videos.
• Relationship details.
• Phone numbers.
• Locations.
• Funeral coordinators.
• Committee members.
• Religious leaders.
• Contributors.
• Visitors.
• Tribute authors.
• Family contacts.

Users are responsible for obtaining appropriate consent or authority before uploading information about living individuals.

4.4 Tribute, Candle, and Memory Information

We may collect:

• Tribute messages.
• Condolences.
• Candle messages.
• Memory captions.
• Names.
• Relationship to deceased.
• Location.
• Phone number or email where provided.
• Photos or media uploaded.
• Timestamp.
• Moderation status.
• Moderator actions.

4.5 Financial and Transaction Data

Where payment or contribution features are used, we may collect:

• Contributor name.
• Contributor phone number.
• Amount.
• Transaction reference.
• Payment status.
• Payment provider response.
• Contribution message.
• Timestamp.
• Memorial ID.
• Wallet metadata.
• Withdrawal requests.
• Payout destination.
• Refund request details.
• Package purchased.
• Platform fee details.
• Expense records.
• Vendor payment records.
• Receipt uploads.

We do not store mobile money PINs, bank passwords, or full card details.

4.6 Verification and KYC Data

For withdrawals, fraud prevention, disputes, or compliance, we may collect:

• Government-issued ID.
• ID images.
• Selfie or likeness verification.
• Proof of relationship.
• Proof of death.
• Burial documents.
• Trusted representative details.
• Payment destination verification.
• Supporting dispute documents.

4.7 Technical and Usage Data

We may collect:

• IP address.
• Device information.
• Browser type.
• Operating system.
• Referring links.
• Pages visited.
• Time spent.
• Clicks.
• Access logs.
• Session data.
• Error logs.
• Approximate location.
• Fraud signals.
• Device identifiers.
• Analytics events.

4.8 Communications

We may collect information from:

• Emails.
• WhatsApp messages.
• SMS.
• Support tickets.
• Contact forms.
• Calls.
• Concierge intake forms.
• Vendor or partner inquiries.

5. How We Use Information

We use information to:

• Create and manage accounts.
• Create, host, and display Memorials.
• Generate mini-obituaries, e-eulogies, anniversary pages, PDFs, QR codes, and downloads.
• Enable collaboration and role-based access.
• Process package payments.
• Facilitate contributions through third-party payment providers.
• Display contribution totals based on settings.
• Process withdrawal requests where available.
• Track expenses and budgets.
• Moderate tributes and content.
• Prevent fraud, impersonation, fake memorials, cybercrime, and unauthorized fundraising.
• Respond to support requests.
• Send transactional messages.
• Send anniversary reminders, renewal reminders, tribute alerts, and memorial updates.
• Improve the Platform.
• Analyze usage.
• Enforce our Terms.
• Comply with legal obligations.

6. Lawful Basis for Processing

We process personal data based on:

• Consent.
• Performance of a contract.
• Compliance with legal obligations.
• Legitimate interests, including fraud prevention, security, moderation, analytics, dispute handling, product improvement, and marketing of Public Memorials.

Kenya’s data protection framework recognizes lawful processing requirements and data subject rights, which is why Kwaheri should maintain clear privacy notices, consent controls, and retention practices.

7. Marketing Use of Public Memorials

If a Memorial is Public, we may use publicly visible content from that Memorial for:

• Marketing.
• Social media.
• Product demos.
• Case studies.
• Investor materials.
• Website examples.
• Educational materials.
• Business development.

This may include:

• Public screenshots.
• Public mini-obituary examples.
• Public e-eulogy examples.
• Public anniversary examples.
• Public tribute excerpts.
• Public design layouts.

Private Memorials will not intentionally be used for marketing without explicit written consent.

You may request that we stop future promotional use by contacting our active channel at support@myzelora.com.

8. Public Visibility and Search Engines

Public Memorials may be:

• Viewed by anyone.
• Shared through WhatsApp, Facebook, X, email, SMS, or other platforms.
• Indexed by search engines.
• Cached by third parties.
• Screenshotted.
• Archived.
• Reposted.

Kwaheri cannot control third-party use of information users make public.

9. Contribution Visibility

Contribution information is private by default unless the Memorial Administrator changes visibility settings.

Depending on settings, visitors may see:

• Total raised.
• Goal progress.
• Contributor names.
• Contribution amounts.
• Anonymous contributions.
• Candle messages.
• Recent support activity.

10. Sharing Information With Service Providers

We may share information with service providers needed to run Kwaheri, including:

• Payment processors.
• Mobile money providers.
• Banks.
• Cloud hosting providers.
• Database providers.
• Email/SMS/WhatsApp providers.
• Analytics providers.
• Fraud prevention tools.
• Customer support tools.
• Printing or fulfillment providers where requested.
• Concierge support vendors.
• Domain or hosting providers.

We do not sell personal data to data brokers.

11. Law Enforcement and Fraud Disclosure

Where we suspect fraud, impersonation, false death claims, unauthorized fundraising, cybercrime, suspicious transactions, or legal violations, we may preserve and disclose information to:

• Law enforcement.
• Directorate of Criminal Investigations.
• Cybercrimes Unit.
• Courts.
• Regulators.
• Payment providers.
• Mobile money providers.
• Banks.
• Legal advisers.

Information disclosed may include:

• Names.
• Phone numbers.
• Email addresses.
• IP addresses.
• Device data.
• Access logs.
• Transaction records.
• Memorial content.
• Uploaded documents.
• Contribution records.
• Withdrawal records.
• Verification documents.

12. Cookies and Analytics

We may use cookies, analytics tools, pixels, and similar technologies to:

• Keep users logged in.
• Improve performance.
• Understand usage.
• Detect fraud.
• Remember preferences.
• Improve product design.
• Monitor errors.

Users may manage cookies through browser settings.

13. Communications

We may send:

• Account messages.
• OTP/login messages.
• Memorial activity updates.
• Tribute notifications.
• Contribution confirmations.
• Payment alerts.
• Withdrawal updates.
• Anniversary reminders.
• Renewal reminders.
• Concierge follow-ups.
• Product updates.
• Marketing messages where allowed.

Users may opt out of marketing messages, but transactional, security, payment, legal, and service-related messages may still be sent.

14. Data Retention

We retain data only as long as needed for service, legal, accounting, fraud prevention, security, or dispute reasons.

Account and Memorial Data

Deleted accounts or Memorials may be archived for up to 30 days before permanent deletion.

Permanent deletion may take 30 to 60 days, unless longer retention is legally required.

Paid Memorials

Paid Memorials may be retained for the active package, hosting period, renewal period, or archive period.

Financial Records

Payment, contribution, withdrawal, fee, invoice, and verification records may be retained for up to 7 years or longer where needed for legal, tax, fraud, accounting, or regulatory purposes.

Public Content

Content publicly shared may remain available through third-party caches, screenshots, search engines, or shares after deletion from Kwaheri.

15. Security

We use reasonable security measures, including:

• SSL/TLS encryption.
• Role-based access controls.
• Secure hosting.
• Audit logs.
• Monitoring.
• Authentication controls.
• Restricted admin access.

No digital system is completely secure.

Users are responsible for protecting passwords, devices, SIM cards, OTPs, email accounts, and mobile money credentials.

16. Children and Minors

Kwaheri is not intended for account creation or Memorial administration by persons under 18.

If we learn that a minor has created an account without adult supervision, we may restrict or delete the account.

17. International Access

Kwaheri may be accessed outside Kenya.

Information may be stored or processed in Kenya or other jurisdictions where our service providers operate.

We take reasonable steps to use appropriate safeguards where required.

18. Your Rights

Subject to applicable law, you may have rights to:

• Access personal data.
• Correct inaccurate data.
• Request deletion.
• Object to processing.
• Restrict processing.
• Withdraw consent.
• Request portability where applicable.
• Complain to the relevant data protection authority.

We may require identity verification before responding.

Some requests may be limited where we need to retain data for legal, accounting, fraud prevention, security, or dispute reasons.

19. Business Transfers

If Zalen Ltd, Zelora, Kwaheri, or relevant assets are involved in a merger, acquisition, restructuring, financing, or sale, user information may be transferred as part of that transaction subject to appropriate safeguards.

20. Updates to This Policy

We may update this Privacy Policy from time to time.

Material changes may be communicated through the Platform, email, WhatsApp, SMS, or other appropriate channels.

Continued use after updates means you accept the updated Policy.

21. Contact Information

For questions, concerns, or requests regarding this Privacy Policy, please contact us:
Support Inbox: support@myzelora.com (Please direct all support, legal, and privacy messages here)

View Terms of Service · View Refund & Cancellation Policy