Jukwaa AI, Uploaded Content, and Platform Improvement Policy

1. Introduction

This AI, Uploaded Content, and Platform Improvement Policy explains how Jukwaa, available at https://Jukwaa.Africa, may use uploaded content, user activity, creator information, platform data, feedback, reports, and interaction data to operate, secure, improve, personalise, develop, and enhance the Platform, including through responsible use of artificial intelligence, automation, analytics, recommendation systems, moderation tools, search tools, content discovery tools, and anti-piracy systems.

Jukwaa is a product of Creative Digital Lab Limited, a company registered in Kenya.

This Policy should be read together with the Jukwaa Terms of Use, Privacy Policy, Creator Policy, Prohibited Content Policy, Anti-Piracy Policy, Takedown Policy, Payout Policy, and any creator, commercial, campaign, distribution, or partnership agreement issued by Jukwaa.

By creating an account, signing up, uploading content, publishing content, purchasing content, interacting with content, or otherwise using Jukwaa, you acknowledge and agree that Jukwaa may process and use certain data and content for the purposes described in this Policy, subject to your rights, preferences, lawful basis, and any opt-out or removal request available under this Policy and applicable law.

2. Purpose of This Policy

This Policy is intended to:

• explain how Jukwaa may use uploaded content and platform data to improve the Platform;
• explain how Jukwaa may use AI, automation, analytics, and recommendation systems;
• clarify what users and Creators consent to when signing up or uploading content;
• protect user privacy, creator rights, intellectual property, and confidential information;
• give users and Creators a clear process to request removal, restriction, or exclusion from certain data-use activities;
• support transparency, accountability, security, and lawful processing of data.

3. Definitions

For purposes of this Policy:

• “AI” means artificial intelligence, machine learning, automated systems, natural language processing, computer vision, recommendation systems, moderation tools, content classification tools, analytics systems, search-ranking tools, fraud detection tools, and similar technologies.
• “Uploaded Content” means any content uploaded, submitted, published, shared, sold, distributed, streamed, listed, or stored on Jukwaa, including videos, images, audio, scripts, articles, PDFs, e-books, posts, comments, subtitles, metadata, thumbnails, descriptions, trailers, and related files.
• “Platform Data” means information generated from use of Jukwaa, including views, searches, clicks, purchases, watch history, downloads, device/session logs, reports, ratings, comments, engagement, payment status, refund records, access logs, and technical performance data.
• “Improvement Purposes” means purposes connected to operating, securing, testing, improving, developing, personalising, moderating, analysing, and enhancing Jukwaa and related services.
• “User” means any person who accesses, registers, views, purchases, reports, comments, uploads, downloads, streams, subscribes, or otherwise uses Jukwaa.
• “Creator” means any person or entity that uploads, publishes, sells, promotes, distributes, or monetises content through Jukwaa.

4. General Consent on Sign-Up and Use

When you sign up for Jukwaa, create a Creator account, upload content, accept the Terms of Use, or continue using the Platform, you consent to Jukwaa processing Uploaded Content and Platform Data for legitimate Platform purposes, including:

• providing the Platform;
• delivering content to users;
• enabling search and discovery;
• recommending relevant content;
• improving user experience;
• improving creator tools;
• detecting fraud, piracy, spam, abuse, and prohibited content;
• improving moderation and safety systems;
• improving payment, refund, and payout workflows;
• testing and improving technical performance;
• analysing platform trends;
• improving accessibility, translation, captions, classification, and content organisation;
• supporting customer service and dispute resolution;
• complying with law, payment provider requirements, and platform policies.

This consent does not transfer ownership of Creator content to Jukwaa. Creators retain ownership of their content, subject to the licences granted under the Jukwaa Terms of Use, Creator Policy, and any applicable agreement.

5. Use of Uploaded Content for Platform Improvement

Jukwaa may review, analyse, process, classify, transform, index, summarise, tag, transcode, compress, secure, and otherwise use Uploaded Content for Improvement Purposes.

This may include using Uploaded Content to:

• generate thumbnails, previews, snippets, trailers, or content summaries;
• categorise content by genre, language, topic, audience, format, or age suitability;
• improve search results;
• improve content recommendations;
• improve content discovery and ranking;
• identify duplicate or pirated uploads;
• detect prohibited content;
• improve moderation workflows;
• improve anti-piracy systems;
• improve accessibility features, including captions, subtitles, alt text, or transcripts;
• improve technical delivery, streaming, compression, and device compatibility;
• improve creator dashboards and audience analytics;
• improve user support and dispute resolution;
• test new platform features before release.

Where possible, Jukwaa may use aggregated, anonymised, pseudonymised, or minimised data for platform improvement.

6. Use of AI and Automated Tools

Jukwaa may use AI and automated tools to support Platform operations, including:

• content moderation;
• copyright and piracy detection;
• duplicate upload detection;
• content classification;
• age-rating support;
• search and recommendations;
• fraud detection;
• payment risk monitoring;
• spam detection;
• harmful content detection;
• customer support triage;
• translation and captioning support;
• metadata generation;
• trend analysis;
• creator insights;
• platform security.

AI tools may assist human review but may not always be perfect. Jukwaa may use manual review, appeals, and correction processes where appropriate.

7. AI-Assisted Content Moderation

Jukwaa may use AI-assisted moderation tools to identify content that may violate Jukwaa policies, including content involving piracy, copyright infringement, harmful or prohibited content, child safety concerns, non-consensual intimate material, hate speech, incitement, violence, fraud, scams, spam, impersonation, malware, privacy violations, and payment abuse.

AI-assisted moderation may lead to content being flagged for review, temporarily restricted, age-gated, demonetised, removed, or escalated for manual review.

Creators and users may appeal certain moderation decisions under the relevant Jukwaa policy, unless appeal is unavailable due to legal, safety, payment, regulatory, or rights-holder risk.

8. AI-Assisted Recommendations and Personalisation

Jukwaa may use Platform Data to personalise user experience and recommend content.

Recommendations may be based on factors such as:

• content viewed;
• content purchased;
• searches;
• likes, ratings, or follows;
• subscriptions;
• language;
• category interests;
• location at country or regional level;
• device type;
• popularity of content;
• creator activity;
• platform campaigns;
• editorial curation;
• similar user behaviour;
• content metadata.

Users may request that Jukwaa limit certain personalisation or data-use activities where technically and legally feasible.

9. Use of Data for Analytics and Platform Insights

Jukwaa may use Platform Data to generate analytics and insights, including total views, watch time, purchases, conversion rates, user engagement, content performance, creator performance, revenue trends, refund trends, piracy signals, search behaviour, category popularity, geographic demand, device performance, platform errors, and user support trends.

Jukwaa may share aggregated or anonymised insights with Creators, partners, sponsors, institutions, or investors, provided such insights do not directly identify individual users unless lawful and appropriate.

10. Sharing of Uploaded Content for Platform Purposes

Jukwaa may share Uploaded Content, metadata, or related information with selected third parties where necessary for legitimate Platform purposes.

This may include sharing with:

• hosting providers;
• cloud service providers;
• content delivery networks;
• payment providers;
• anti-piracy vendors;
• AI, analytics, or moderation service providers;
• transcription, captioning, or translation providers;
• technical support providers;
• rights holders or authorised representatives;
• legal advisers;
• regulators, courts, or law enforcement agencies where required;
• commercial partners where the Creator has joined a campaign, showcase, distribution programme, or partnership.

Jukwaa will take reasonable steps to ensure that service providers process such content and data only for authorised purposes and subject to appropriate confidentiality, security, and data protection obligations.

11. Sharing of Content for Platform Promotion

Jukwaa may use Creator content, thumbnails, titles, descriptions, previews, snippets, trailers, creator names, profile images, and public metadata to promote the Platform and the Creator’s content.

This may include promotion through Jukwaa homepage, category pages, search results, newsletters, social media, digital adverts, creator showcases, partner campaigns, institutional presentations, pitch decks, app store previews, public relations materials, press releases, platform demonstrations, investor presentations, or partner presentations.

Jukwaa will not intentionally publish full paid content for free for promotional purposes unless the Creator has authorised it, the content is already public/free, or the use falls within the agreed platform licence and commercial arrangement.

12. Content Used to Train or Improve AI Systems

Jukwaa may use Uploaded Content and Platform Data to improve Jukwaa’s internal tools, including search, classification, moderation, recommendation, fraud detection, anti-piracy, accessibility, translation, and analytics systems.

Where Jukwaa uses external AI service providers, Jukwaa will take reasonable steps to ensure that content and personal data are handled under appropriate contractual, security, confidentiality, and data protection safeguards.

Unless separately agreed, Jukwaa will not knowingly allow third-party AI vendors to publicly disclose Creator content or use confidential Creator content for unrelated public model training outside the purpose of providing or improving Jukwaa-related services.

Where legally or technically possible, Creators may request exclusion of specific content from certain AI improvement activities.

13. Public Content vs Private or Paid Content

Jukwaa may treat content differently depending on whether it is public, private, paid, restricted, draft, unpublished, or confidential.

13.1 Public content

Public content may be indexed, displayed, recommended, promoted, analysed, and used to improve Platform discovery and safety tools.

13.2 Paid or restricted content

Paid or restricted content may be processed for hosting, delivery, security, anti-piracy, moderation, search, recommendations, analytics, customer support, rights management, and platform improvement, but Jukwaa will not intentionally make full paid content publicly available without authorisation.

13.3 Draft or unpublished content

Draft or unpublished content may be processed for storage, technical checks, moderation readiness, creator tools, virus scanning, rights checks, and platform security, but will not normally be visible to the public unless published by the Creator or authorised representative.

13.4 Confidential content

Where content is marked confidential or submitted under a separate written agreement, Jukwaa will handle it according to the relevant confidentiality terms, subject to legal, safety, payment, and compliance requirements.

14. Creator Rights and Ownership

Creators retain ownership of their Uploaded Content unless otherwise agreed in writing.

This Policy does not transfer ownership of Creator content to Creative Digital Lab Limited or Jukwaa.

However, by uploading content to Jukwaa, the Creator grants Jukwaa the rights necessary to:

• host the content;
• deliver it to authorised users;
• process payments and payouts;
• protect against piracy;
• moderate and classify content;
• improve platform tools;
• promote the content and the Platform;
• comply with law and platform policies;
• provide user support;
• analyse platform performance.

These rights are subject to the Jukwaa Terms of Use, Creator Policy, and any specific creator or commercial agreement.

15. User Data and Personal Data Protection

Where Platform Data includes personal data, Jukwaa will process it in accordance with the Jukwaa Privacy Policy and applicable data protection law.

Jukwaa will apply reasonable safeguards, which may include data minimisation, access controls, encryption where appropriate, pseudonymisation where appropriate, aggregation where appropriate, confidentiality obligations, vendor controls, retention limits, security monitoring, deletion, or restriction processes where applicable.

Users and Creators should not upload personal data of others unless they have a lawful basis, consent where required, and appropriate rights to do so.

16. Sensitive Content and Sensitive Personal Data

Jukwaa may apply stricter controls to sensitive content or sensitive personal data.

This may include content involving minors, health information, biometric data, national identity information, financial information, political opinions, religious beliefs, ethnicity, sexual orientation, criminal allegations, non-consensual material, or private family or personal matters.

Sensitive content may be restricted, excluded from certain improvement activities, reviewed manually, or removed where it creates legal, safety, privacy, or reputational risk.

17. User and Creator Control

Users and Creators may request information about how their content or personal data is used for Platform improvement.

Subject to applicable law, technical feasibility, platform security, contractual obligations, and legitimate business needs, users and Creators may request:

• access to certain personal data;
• correction of inaccurate personal data;
• deletion of certain personal data;
• removal of specific content;
• restriction of certain processing activities;
• exclusion of specific content from certain AI improvement activities;
• withdrawal of consent where processing is based on consent;
• objection to certain processing activities;
• opt-out from certain marketing or personalisation activities.

Jukwaa may require identity verification before processing such requests.

18. Requesting Removal or Exclusion From AI/Data Improvement Use

A user or Creator may request that specific Uploaded Content or personal data not be used for certain Platform improvement, analytics, sharing, or AI-related purposes.

The request should include:

• full name;
• account email;
• phone number, where applicable;
• Creator name, where applicable;
• content title or URL;
• specific data or content concerned;
• the type of use being objected to;
• reason for the request;
• whether the request is for removal, restriction, opt-out, or deletion;
• supporting evidence, where applicable.

Requests should be sent to:

Creative Digital Lab Limited Product: Jukwaa Website: https://Jukwaa.Africa Company Website: https://creativelab.co.ke Email: [email protected] Nairobi, Kenya

19. How Jukwaa Will Handle Opt-Out or Removal Requests

After receiving a request, Jukwaa may:

• acknowledge the request;
• verify the requester’s identity or authority;
• identify the relevant content or data;
• assess the legal basis for processing;
• assess technical feasibility;
• restrict future use where appropriate;
• remove content where appropriate;
• delete or anonymise data where lawful and feasible;
• stop certain marketing or personalisation use;
• exclude specific content from certain AI improvement activities where technically possible;
• explain why the request cannot be fully granted.

Jukwaa may decline or limit a request where continued processing is necessary for contract performance, payment processing, payout calculation, refund handling, fraud prevention, anti-piracy enforcement, content moderation, legal compliance, tax and accounting records, dispute resolution, security, rights-holder claims, regulatory obligations, court obligations, law enforcement obligations, or legitimate platform operation.

20. Effect of Opting Out

Where a user or Creator opts out of certain data-use activities, some Platform features may be limited or unavailable.

For example:

• content may be less discoverable;
• recommendations may be less personalised;
• creator analytics may be reduced;
• certain promotional features may not be available;
• some AI-assisted tools may not work fully;
• some moderation, anti-piracy, and security processing may still continue where necessary.

Opting out of optional AI improvement or marketing use does not automatically opt a user or Creator out of essential processing required to operate, secure, deliver, moderate, monetise, or legally protect the Platform.

21. Aggregated and Anonymised Data

Jukwaa may continue to use aggregated, anonymised, or de-identified data for Platform improvement, analytics, reporting, research, investor reporting, partner reporting, trend analysis, and business planning.

Aggregated or anonymised data does not directly identify a specific user or Creator.

Requests for deletion or opt-out may not apply to data that has already been irreversibly anonymised or aggregated.

22. Data Sharing With Creators and Partners

Jukwaa may provide Creators and approved partners with analytics related to content performance.

This may include:

• number of views;
• number of purchases;
• watch time;
• audience regions;
• device types;
• engagement metrics;
• refund patterns;
• conversion data;
• general demographic or audience insights where available and lawful.

Jukwaa will aim to avoid sharing personal user data with Creators or partners unless necessary, lawful, consented to, contractually required, or required for support, delivery, legal, compliance, or dispute-resolution purposes.

23. Data Sharing With AI, Analytics, and Technical Providers

Jukwaa may use external vendors to support AI, analytics, hosting, moderation, transcription, translation, security, anti-piracy, search, recommendations, customer support, and other technical services.

Where such vendors process Uploaded Content or personal data, Jukwaa will take reasonable steps to ensure:

• the vendor is used for authorised purposes;
• confidentiality obligations apply;
• security safeguards are in place;
• access is limited to what is necessary;
• personal data is handled according to applicable law;
• vendor use is consistent with the Jukwaa Privacy Policy and this Policy.

24. Human Review and Appeals

Where AI or automated systems affect content visibility, moderation, monetisation, payout review, or account status, Jukwaa may provide human review where appropriate and feasible.

A user or Creator may request review where they believe an automated decision was wrong.

Jukwaa may not provide appeal or restoration where action was required by law, regulator instruction, court order, payment provider rules, child safety risk, serious fraud risk, piracy risk, or urgent safety concerns.

25. Accuracy and Limitations of AI Systems

AI and automated systems may produce errors, false positives, false negatives, inaccurate classifications, incomplete summaries, or imperfect recommendations.

Jukwaa does not guarantee that AI systems will always correctly identify piracy, prohibited content, user preferences, fraud, copyright ownership, or content suitability.

Users and Creators should report errors, incorrect classifications, or unfair restrictions to Jukwaa for review.

26. Creator Use of AI-Generated Content

Creators may use AI-generated or AI-assisted content only where lawful and compliant with Jukwaa policies.

Creators must not upload AI-generated content that:

• infringes copyright;
• impersonates another person;
• misuses a person’s voice, face, name, image, or likeness;
• creates deceptive deepfakes;
• fabricates endorsements;
• misleads users about authorship or authenticity;
• violates privacy or publicity rights;
• contains prohibited content;
• uses unlawfully obtained training material;
• breaches third-party platform or software terms.

Jukwaa may require disclosure that content is AI-generated or AI-assisted where necessary for user trust, legal compliance, safety, or platform integrity.

27. Confidentiality and Commercially Sensitive Content

Creators should not upload confidential, unreleased, commercially sensitive, or third-party confidential content unless they have authority to do so and accept the associated risk.

Where a Creator uploads confidential content for private review, campaign review, distribution review, or pre-release purposes, the Creator should clearly mark it as confidential and notify Jukwaa in writing.

Jukwaa will take reasonable steps to protect confidential content but may still process it for hosting, security, moderation, technical support, legal compliance, and agreed Platform purposes.

28. Security and Anti-Abuse Processing

Jukwaa may process Uploaded Content and Platform Data to detect and prevent:

• account takeover;
• unauthorised access;
• piracy;
• fake accounts;
• bot activity;
• fraud;
• payment abuse;
• malware;
• spam;
• scraping;
• harmful content;
• illegal transactions;
• policy evasion.

This security-related processing may continue even if a user or Creator opts out of optional personalisation or improvement uses.

29. Retention of Uploaded Content and Platform Data

Jukwaa may retain Uploaded Content and Platform Data for as long as necessary to provide services, comply with legal obligations, resolve disputes, process payments and payouts, handle refunds, enforce rights, prevent fraud, support anti-piracy, improve the Platform, and maintain business records.

Retention periods may vary depending on account status, content status, transaction history, legal requirements, tax and accounting obligations, rights disputes, takedown claims, fraud investigations, payment provider rules, and user or Creator requests.

Jukwaa may delete, anonymise, or archive content and data when it is no longer required.

30. Withdrawal of Consent

Where Jukwaa relies on consent to process certain data, a user or Creator may withdraw consent by contacting Jukwaa.

Withdrawal of consent does not affect processing that occurred before withdrawal.

Withdrawal also does not affect processing based on other lawful grounds, including contract performance, legal obligations, legitimate interests, fraud prevention, payment processing, anti-piracy, security, or dispute resolution.

31. Platform Improvement Without Personal Identification

Where possible, Jukwaa may improve the Platform using data that does not directly identify users.

This may include:

• aggregated content performance data;
• anonymised search trends;
• general category performance;
• technical error rates;
• anonymised fraud patterns;
• general user engagement trends;
• content delivery performance;
• platform-level revenue and usage summaries.

Such data may be used to improve Jukwaa and may be shared with partners, investors, Creators, institutions, or service providers in a non-identifying form.

32. No Sale of Personal Data Without Lawful Basis

Jukwaa does not sell personal data in the ordinary sense of selling individual user identity records to third parties for unrelated commercial exploitation.

Where Jukwaa shares data, it does so for Platform operation, service delivery, payment processing, analytics, compliance, security, anti-piracy, legal, creator reporting, or approved partnership purposes, subject to applicable law and this Policy.

33. Changes to This Policy

Jukwaa may update this AI, Uploaded Content, and Platform Improvement Policy from time to time.

Where changes are material, Jukwaa may notify users or Creators through the Platform, email, dashboard notice, or website update.

Continued use of Jukwaa after the updated Policy takes effect means you accept the updated Policy, subject to your rights under applicable law.

34. Contact Information

For questions about AI use, uploaded content use, platform improvement, data sharing, opt-out requests, removal requests, or privacy-related concerns, contact:

Creative Digital Lab Limited Product: Jukwaa Website: https://Jukwaa.Africa Company Website: https://creativelab.co.ke Email: [email protected] Nairobi, Kenya

35. Acceptance

By signing up, creating an account, uploading content, publishing content, purchasing content, interacting with content, monetising content, or otherwise using Jukwaa, you confirm that you have read, understood, and agreed to this AI, Uploaded Content, and Platform Improvement Policy.