ZUUP PRIVACY POLICY
Operated by KAWIWI International Limited
Last Updated: May 2026
KAWIWI International Limited ("KAWIWI," "ZUUP," "we," "us," or "our") respects your privacy and is committed to protecting your personal data.
This Privacy Policy explains how we collect, use, process, store, transfer, disclose, and protect your personal information when you use the ZUUP mobile application, website, APIs, and all related services.
By accessing or using ZUUP, you expressly consent to the collection and processing of your personal information as described in this Privacy Policy. If you do not agree, you must immediately discontinue use of the platform.
1. WHO WE ARE
ZUUP is a technology platform owned and operated by KAWIWI International Limited, a company incorporated under the laws of the Republic of Zambia.
KAWIWI provides a digital marketplace and technology infrastructure that connects users with independent third-party vendors, restaurants, pharmacies, riders, drivers, car owners, and other service providers.
For privacy-related inquiries, contact:
KAWIWI International Limited
Woodlands, Lusaka, Zambia
Email: business@kawiwi.net
Phone: +260 77 3922548
Website: www.kawiwi.net
2. INFORMATION WE COLLECT
We may collect the following categories of personal information:
2.1 Information You Provide
- Full name
- Mobile number
- Email address
- Password and login credentials
- Delivery and billing addresses
- GPS location details
- Payment information
- National registration card, passport, driver's licence, and business documents (where required)
- Profile photographs
- Customer support communications
- Ratings, reviews, and feedback
2.2 Information Collected Automatically
- Device model and operating system
- Unique device identifiers
- IP address
- Browser information
- App usage statistics
- Crash reports and diagnostic logs
- Cookies and similar technologies
- Real-time and historical location data
2.3 Information from Third Parties
- Payment processors
- Social login providers
- Vendors, riders, and drivers
- Fraud detection services
- Government and regulatory authorities
- Publicly available sources
3. SPECIAL CATEGORIES OF DATA
For pharmacy and healthcare-related services, users may voluntarily provide health-related information such as prescription details, medication names, and delivery instructions. Such information is used solely to facilitate the requested service and is handled with appropriate safeguards.
4. HOW WE USE YOUR INFORMATION
We use your personal data to:
- Create and manage accounts
- Process orders, deliveries, rentals, and bookings
- Facilitate payments and refunds
- Verify identity and eligibility
- Detect fraud and abuse
- Communicate updates and support messages
- Improve products and services
- Conduct analytics and business planning
- Comply with legal obligations
- Enforce our terms and policies
- Protect rights, property, and safety
- Send promotional communications where permitted
5. LEGAL BASIS FOR PROCESSING
We process personal data on the following legal grounds:
- Performance of a contract
- Legitimate business interests
- User consent
- Compliance with legal obligations
- Protection of vital interests
- Establishment, exercise, or defence of legal claims
6. SHARING OF INFORMATION
We do not sell your personal data. We may disclose information to:
- Vendors, restaurants, pharmacies, and merchants
- Riders, drivers, and couriers
- Car owners and rental partners
- Payment processors and financial institutions
- Cloud hosting and technology providers
- Analytics and communication providers
- Professional advisers and auditors
- Law enforcement and regulators
- Potential buyers or investors during business transactions
Each recipient receives only information reasonably necessary for the relevant purpose.
7. INTERNATIONAL DATA TRANSFERS
Your information may be processed or stored outside Zambia, including in countries with different privacy laws. By using ZUUP, you consent to such transfers and acknowledge that equivalent legal protections may not always be available.
8. LOCATION DATA
We may collect precise and background location data to:
- Match users with nearby service providers
- Provide live tracking and estimated arrival times
- Optimise dispatch and routing
- Prevent fraud and verify deliveries
Disabling location services may limit platform functionality.
9. DATA RETENTION
We retain information for as long as necessary to:
- Provide services
- Maintain records
- Resolve disputes
- Enforce agreements
- Comply with legal and tax obligations
Typical retention periods may include:
- Account records: up to 5 years after closure
- Financial records: at least 7 years
- Operational logs and location data: as operationally required
- Legal records: until final resolution of any dispute
We may retain anonymised or aggregated data indefinitely.
10. DATA SECURITY
We implement commercially reasonable administrative, technical, and physical safeguards.
However:
- No system is completely secure.
- Transmission over the internet is inherently risky.
- We cannot guarantee absolute security.
- Users are responsible for protecting their credentials and devices.
11. YOUR RIGHTS
Subject to applicable law, you may request to:
- Access your data
- Correct inaccurate data
- Delete data
- Restrict processing
- Object to certain processing
- Receive data in portable format
- Withdraw consent
Requests may be denied where retention is required by law or necessary to protect legitimate interests.
12. MARKETING COMMUNICATIONS
You may receive promotional messages if permitted by law or if you consent. You may opt out at any time using unsubscribe links or by contacting us.
13. COOKIES AND SIMILAR TECHNOLOGIES
We use cookies, SDKs, pixels, and related technologies to:
- Authenticate users
- Remember preferences
- Analyse performance
- Prevent fraud
- Deliver and measure advertising
Users may disable cookies through browser or device settings, though some features may not function properly.
14. CHILDREN'S PRIVACY
ZUUP is intended only for persons aged 18 and above. We do not knowingly collect data from minors.
15. THIRD-PARTY SERVICES
Our platform may contain links to or integrations with third-party services. We are not responsible for their privacy practices, security, or content.
16. BUSINESS TRANSFERS
In the event of a merger, acquisition, financing, restructuring, or sale of assets, personal data may be transferred as part of the transaction.
17. AUTOMATED DECISION-MAKING AND FRAUD SCREENING
We may use automated tools to:
- Detect suspicious activity
- Prevent fake orders
- Assess account risk
- Trigger verification steps
Such systems may result in temporary restrictions or additional checks.
18. SECURITY INCIDENTS
If a data breach occurs, we will take appropriate steps as required by applicable law, including investigation, mitigation, and notifications where legally necessary.
19. DISCLAIMERS AND LIMITATION OF LIABILITY
To the fullest extent permitted by law:
- Privacy controls and security measures are provided on an "as is" and "as available" basis.
- KAWIWI does not guarantee that unauthorised access, hacking, or data loss will never occur.
- KAWIWI shall not be liable for indirect, incidental, consequential, or punitive damages arising from data processing or security incidents.
- KAWIWI's total liability relating to privacy matters shall not exceed the total fees paid by the user to KAWIWI during the thirty (30) days preceding the event giving rise to the claim.
- If no fees were paid, KAWIWI's liability shall be zero to the maximum extent permitted by law.
20. CHANGES TO THIS PRIVACY POLICY
We may amend this Privacy Policy at any time. Updated versions become effective upon posting in the app, website, or other communication channels. Continued use of ZUUP constitutes acceptance of the revised policy.
21. GOVERNING LAW AND DISPUTE RESOLUTION
This Privacy Policy is governed by the laws of the Republic of Zambia, including the Data Protection Act No. 3 of 2021.
Disputes shall first be negotiated in good faith and, if unresolved, submitted to arbitration in Lusaka, Zambia. Courts in Lusaka shall have exclusive jurisdiction where arbitration is unavailable or enforcement is required.
22. CONTACT INFORMATION
KAWIWI International Limited
Woodlands, Lusaka, Zambia
Email: business@kawiwi.net
Phone: +260 77 3922548
Website: www.kawiwi.net
ACKNOWLEDGEMENT
By using ZUUP, you acknowledge that:
- You have read and understood this Privacy Policy.
- You consent to the collection and processing of your personal data as described herein.
- You understand that no digital platform can guarantee absolute security.
- You agree that KAWIWI International Limited's liability is limited to the maximum extent permitted by law.