Jukwaa Privacy Policy

1. Introduction

This Privacy Policy explains how Jukwaa, a product of Creative Digital Lab Limited, collects, uses, stores, shares, protects, and manages personal data when you access or use https://Jukwaa.Africa and related services.

In this Privacy Policy:

• “Jukwaa,” “the Platform,” “we,” “us,” or “our” means Jukwaa and Creative Digital Lab Limited.
• “User,” “you,” or “your” means any person who accesses, browses, registers, purchases, subscribes, uploads, sells, receives payouts, or otherwise uses the Platform.
• “Creator” means any individual, business, organisation, artist, filmmaker, writer, blogger, media owner, publisher, trainer, performer, or content owner who uses Jukwaa to publish, distribute, promote, or monetise content.
• “Personal data” means information relating to an identified or identifiable person.

Jukwaa is committed to protecting your privacy and handling personal data lawfully, fairly, transparently, and securely.

2. About Creative Digital Lab Limited and Jukwaa

Jukwaa is a digital content, creator, distribution, discovery, and monetisation platform owned and operated by Creative Digital Lab Limited, a company registered in Kenya.

Creative Digital Lab Limited provides ICT, software development, digital media, systems integration, cloud, hosting, analytics, and content management services.

For purposes of this Privacy Policy, Creative Digital Lab Limited may act as a data controller where it determines why and how personal data is processed, and as a data processor where it processes data on behalf of creators, partners, institutions, or other lawful controllers.

3. Scope of This Privacy Policy

This Privacy Policy applies to personal data processed through:

• the Jukwaa website;
• user accounts;
• creator accounts;
• content uploads;
• purchases and subscriptions;
• digital downloads;
• streaming access;
• payment and payout workflows;
• support requests;
• email, SMS, WhatsApp, or other communications;
• analytics and security logs;
• anti-piracy and takedown processes;
• creator onboarding and verification;
• platform marketing and notifications.

This Privacy Policy does not apply to third-party websites, payment providers, mobile money operators, social media platforms, or external services that are not owned or controlled by Creative Digital Lab Limited.

4. Personal Data We Collect

Jukwaa may collect different types of personal data depending on how you use the Platform.

4.1 Account registration data

When you create an account, we may collect:

• full name;
• username;
• email address;
• phone number;
• password or authentication details;
• country;
• profile picture;
• account type;
• login credentials;
• account preferences.

4.2 Creator onboarding data

If you apply to become a creator, publisher, seller, or monetisation partner, we may collect:

• full legal name;
• stage name, brand name, or creator name;
• business name;
• company registration details;
• national ID, passport, or business registration documents;
• KRA PIN or tax details, where applicable;
• address;
• phone number;
• email address;
• bank account details;
• mobile money number;
• payout account details;
• beneficial ownership information, where applicable;
• content ownership documents;
• copyright licences;
• performer releases;
• publisher agreements;
• portfolio links;
• social media links;
• verification documents.

4.3 Payment and transaction data

When you make or receive payments through Jukwaa, we may collect:

• transaction reference number;
• payment amount;
• currency;
• payment status;
• payment method;
• mobile money number or masked payment details;
• billing information;
• purchase history;
• subscription history;
• refund history;
• failed transaction logs;
• settlement and payout records;
• fraud or dispute indicators.

Jukwaa may use third-party payment providers, banks, mobile money operators, or payment aggregators to process payments. We do not necessarily store full payment credentials such as full card details.

4.4 Content and creator activity data

When you upload or interact with content, we may collect:

• uploaded content files;
• content title and description;
• content category;
• creator profile information;
• thumbnails, trailers, scripts, PDFs, articles, audio, video, or images;
• pricing settings;
• access settings;
• publishing history;
• user views;
• purchases;
• downloads;
• subscriptions;
• comments;
• ratings;
• likes;
• reports;
• takedown notices;
• copyright claims;
• moderation history.

4.5 Technical and usage data

When you use Jukwaa, we may automatically collect:

• IP address;
• device type;
• browser type;
• operating system;
• approximate location;
• language settings;
• pages visited;
• links clicked;
• referral source;
• login timestamps;
• session duration;
• error logs;
• security logs;
• device identifiers;
• cookie identifiers;
• streaming or download activity;
• access history.

4.6 Communications data

When you contact us, we may collect:

• your name;
• email address;
• phone number;
• message content;
• support request details;
• complaint details;
• attachments you send;
• call, email, SMS, WhatsApp, or chat history;
• feedback and survey responses.

4.7 Anti-piracy, safety, and compliance data

To protect creators, users, and the Platform, we may collect:

• access logs;
• device/session logs;
• watermarking records;
• suspicious download patterns;
• suspected account sharing data;
• content infringement reports;
• takedown request information;
• fraud indicators;
• payment dispute records;
• rights-holder correspondence;
• identity verification records;
• regulatory or law enforcement request records.

5. How We Collect Personal Data

We collect personal data in the following ways:

• Directly from you when you register, upload content, make payments, request support, submit documents, or communicate with us.
• Automatically when you browse or use the Platform.
• From creators or partners where they manage content, campaigns, access lists, or customer relationships.
• From payment providers when transactions are processed, confirmed, failed, reversed, refunded, or disputed.
• From third-party verification services where identity, business, fraud, or rights checks are required.
• From public sources where necessary for content verification, rights claims, fraud prevention, or compliance.
• From rights holders, regulators, law enforcement agencies, or complainants in relation to takedown, safety, or legal matters.

6. Why We Use Personal Data

Jukwaa may use personal data for the following purposes:

6.1 To provide the Platform

We use personal data to:

• create and manage accounts;
• allow users to browse and access content;
• allow creators to upload and manage content;
• provide paid content access;
• process subscriptions, purchases, rentals, donations, or payments;
• issue transaction confirmations;
• manage customer support;
• maintain user and creator dashboards;
• deliver platform features.

6.2 To process payments and payouts

We use personal data to:

• process user payments;
• confirm successful transactions;
• manage failed payments;
• process refunds;
• calculate creator earnings;
• process creator payouts;
• reconcile transactions;
• prevent duplicate payments;
• detect suspicious activity;
• comply with payment provider requirements.

6.3 To verify creators and protect the Platform

We use personal data to:

• verify creator identity;
• confirm business details;
• review ownership or licensing documents;
• assess creator eligibility;
• prevent fraud, piracy, and misuse;
• enforce creator obligations;
• conduct compliance checks;
• manage rights disputes.

6.4 To protect intellectual property

We use personal data to:

• receive and review copyright complaints;
• process takedown notices;
• contact creators about rights claims;
• identify infringing or pirated uploads;
• protect original creators and rights holders;
• support anti-piracy enforcement;
• maintain takedown records.

6.5 To improve and secure the Platform

We use personal data to:

• monitor platform performance;
• analyse usage trends;
• fix errors and bugs;
• improve features;
• personalise user experience;
• detect security threats;
• prevent unauthorised access;
• protect accounts;
• prevent scraping, bots, spam, and abuse.

6.6 To communicate with you

We may use your contact information to send:

• account notifications;
• transaction confirmations;
• payment updates;
• payout updates;
• refund updates;
• support responses;
• policy updates;
• security alerts;
• creator onboarding updates;
• marketing messages, where permitted;
• service announcements.

6.7 To comply with law and regulatory duties

We may use personal data to:

• comply with Kenyan law;
• comply with tax obligations;
• respond to lawful requests;
• comply with payment provider rules;
• maintain required records;
• prevent fraud, money laundering, and unlawful use;
• enforce our Terms of Use;
• defend legal claims.

7. Legal Basis for Processing

Jukwaa processes personal data where one or more lawful bases apply, including:

• Consent — where you have given consent, such as for marketing communications or optional features.
• Performance of a contract — where processing is necessary to provide services you requested, such as account access, purchases, subscriptions, uploads, or payouts.
• Legal obligation — where processing is required for tax, compliance, law enforcement, regulatory, or accounting obligations.
• Legitimate interests — where processing is necessary for platform security, fraud prevention, anti-piracy enforcement, service improvement, analytics, dispute resolution, or business operations.
• Protection of vital interests — where processing is necessary to protect life, safety, or serious harm.
• Public interest or lawful authority — where required by competent authorities or applicable law.

8. Cookies and Similar Technologies

Jukwaa may use cookies, pixels, tags, local storage, and similar technologies to:

• keep you logged in;
• remember preferences;
• secure accounts;
• detect fraud;
• analyse usage;
• improve performance;
• measure content engagement;
• support advertising or marketing where applicable.

You may be able to control cookies through your browser settings. However, disabling certain cookies may affect Platform functionality.

Jukwaa may use analytics tools to understand how users interact with the Platform. Where possible, analytics data may be aggregated or anonymised.

9. Sharing Personal Data

Jukwaa may share personal data with selected third parties where necessary and lawful.

9.1 Payment providers and financial partners

We may share data with payment processors, banks, mobile money operators, payment gateways, aggregators, settlement providers, and fraud prevention providers to process transactions, confirm payments, manage refunds, and support payouts.

9.2 Hosting, cloud, and technology providers

We may share data with hosting providers, cloud infrastructure providers, database providers, email services, SMS services, security vendors, analytics tools, and technical service providers.

9.3 Creators and content partners

Where necessary, we may share limited user information with creators or content partners to support access control, digital delivery, customer support, reporting, analytics, licensing, or legal compliance.

9.4 Rights holders and complainants

Where a copyright, piracy, impersonation, or legal complaint is raised, we may share relevant information with rights holders, authorised representatives, affected parties, or legal advisers.

9.5 Regulators, courts, and law enforcement

We may disclose personal data where required by law, court order, regulator request, law enforcement request, tax authority request, or other competent authority.

9.6 Professional advisers

We may share data with lawyers, auditors, accountants, consultants, insurers, or compliance advisers where necessary for business, legal, financial, or regulatory purposes.

9.7 Business transfers

If Jukwaa or Creative Digital Lab Limited is involved in a merger, acquisition, restructuring, investment, asset sale, partnership, or transfer of business, personal data may be shared as part of that transaction, subject to appropriate safeguards.

10. International Data Transfers

Jukwaa may use service providers, cloud infrastructure, payment partners, or technical systems located outside Kenya.

Where personal data is transferred outside Kenya, we will take reasonable steps to ensure that the transfer is lawful and protected through appropriate safeguards, including contractual protections, security measures, and compliance with applicable data protection requirements.

11. Data Retention

We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer period is required by law, payment provider rules, tax obligations, accounting rules, dispute resolution, anti-fraud requirements, or rights enforcement.

Different data may be retained for different periods:

• account data: while the account remains active and for a reasonable period after closure;
• transaction records: for legal, accounting, tax, payment, and audit purposes;
• creator verification records: for compliance and fraud prevention purposes;
• takedown records: for legal and rights-management purposes;
• support records: for service quality and dispute resolution;
• security logs: for fraud, cybersecurity, and platform integrity;
• marketing data: until consent is withdrawn or the data is no longer needed.

Where possible, we may anonymise or aggregate data so that it no longer identifies a specific person.

12. Data Security

Jukwaa uses reasonable technical and organisational measures to protect personal data against unauthorised access, loss, misuse, alteration, disclosure, or destruction.

These measures may include:

• access controls;
• password protection;
• encryption where appropriate;
• secure hosting;
• monitoring and logging;
• staff access restrictions;
• payment security controls;
• anti-fraud monitoring;
• backup procedures;
• incident response processes;
• vendor due diligence.

However, no online platform can guarantee absolute security. Users and creators are responsible for keeping their login credentials secure and reporting suspected account compromise immediately.

13. Your Data Protection Rights

Subject to applicable law, you may have the right to:

• be informed about how your personal data is processed;
• access your personal data;
• request correction of inaccurate or incomplete data;
• request deletion of personal data where lawful;
• object to processing of your personal data;
• withdraw consent where processing is based on consent;
• request restriction of processing;
• request data portability;
• object to direct marketing;
• challenge certain automated decisions;
• lodge a complaint with the Office of the Data Protection Commissioner.

To exercise your rights, contact us using the contact details in Section 23.

We may need to verify your identity before responding to your request.

14. Children and Minors

Jukwaa is not intended for use by children without appropriate parental or guardian consent.

Users below 18 years should use Jukwaa only with the involvement and consent of a parent or legal guardian.

Creators must not upload content that exploits, sexualises, endangers, targets, or harms children or minors.

If we become aware that personal data of a child has been collected without appropriate consent or lawful basis, we may delete or restrict that data.

15. Marketing Communications

We may send you marketing messages about Jukwaa features, creator opportunities, content releases, events, offers, subscriptions, campaigns, or platform updates where permitted by law.

You may opt out of marketing communications at any time by:

• using the unsubscribe link, where available;
• changing your account settings, where available;
• contacting us directly.

Even if you opt out of marketing, we may still send you essential service messages, including payment confirmations, security alerts, policy updates, account notices, and legal notices.

16. User-Generated Content and Public Information

Some information you provide may be visible to other users, such as:

• creator name;
• profile photo;
• bio;
• content title;
• content description;
• public posts;
• comments;
• ratings;
• public links;
• portfolio information.

Do not post personal data that you do not want to be publicly visible.

Creators are responsible for ensuring that any personal data included in uploaded content, profiles, credits, interviews, images, videos, or documents has been lawfully collected and published.

17. Creator Responsibilities for Personal Data

Creators using Jukwaa must comply with applicable data protection laws where they collect, upload, process, or share personal data through the Platform.

Creators must ensure that:

• they have lawful authority to upload any personal data contained in content;
• persons appearing in videos, images, interviews, recordings, or publications have given necessary consent or releases;
• content does not unlawfully disclose private information;
• they do not upload private documents, identity records, phone numbers, addresses, medical records, financial records, or sensitive personal data without lawful basis;
• they respond promptly to privacy-related complaints involving their content.

Jukwaa may remove or restrict content that appears to violate privacy rights.

18. Sensitive Personal Data

Jukwaa may process sensitive personal data only where necessary and lawful.

Sensitive personal data may include information relating to:

• race or ethnicity;
• health;
• religion;
• political opinions;
• biometric data;
• children;
• sexual orientation;
• financial information;
• precise location;
• criminal allegations or convictions.

Creators should avoid uploading sensitive personal data unless they have a clear lawful basis, consent where required, and appropriate safeguards.

Jukwaa may reject, remove, or restrict content containing sensitive personal data where it creates legal, safety, reputational, or compliance risk.

19. Anti-Fraud, Compliance, and Payment Monitoring

To protect users, creators, and payment systems, Jukwaa may monitor accounts, transactions, and platform activity for:

• suspected fraud;
• payment abuse;
• duplicate payments;
• refund abuse;
• fake accounts;
• bot activity;
• suspicious login patterns;
• money laundering risk;
• terrorist financing risk;
• piracy;
• unauthorised content distribution;
• platform manipulation;
• prohibited content.

This may involve automated and manual review.

Where suspicious activity is detected, Jukwaa may suspend accounts, delay payouts, request verification, reverse access, remove content, notify payment providers, or report matters to relevant authorities where required.

20. Data Breaches

If a personal data breach occurs and is likely to result in risk to affected persons, Jukwaa will take reasonable steps to investigate, contain, remediate, and notify affected users or competent authorities where required by applicable law.

Users should immediately report suspected account compromise, unauthorised access, suspicious transactions, or privacy incidents to Jukwaa.

21. Third-Party Links and Services

Jukwaa may contain links to third-party websites, creator pages, social media platforms, payment pages, streaming services, advertisers, partners, or external tools.

We are not responsible for the privacy practices, security, content, or policies of third-party services.

You should review the privacy policies of third-party services before using them.

22. Changes to This Privacy Policy

Jukwaa may update this Privacy Policy from time to time.

Where changes are material, we may notify you by email, account notice, website notice, or platform notification.

The updated Privacy Policy will apply from the effective date stated at the top of the document.

Your continued use of Jukwaa after changes take effect means you acknowledge the updated Privacy Policy.

23. Contact Information

For privacy questions, data requests, account issues, complaints, or data protection concerns, contact:

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

24. Acceptance

By accessing, registering for, uploading to, purchasing from, selling through, or otherwise using Jukwaa, you acknowledge that you have read and understood this Privacy Policy.