PRIVACY POLICY

1. Introduction

Zanora Collective ("we," "us," or "our") operates the Zanora mobile application (the "App"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our App.

Company Details:

• Legal Name: Zanora Collective
• Business Registration: BN-RRS3LKOW
• Address: Astrol Offices, Thika Road, Kenya
• Contact: support@zanora.app

By using Zanora, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with our policies and practices, do not use our App.

2. Information We Collect

2.1 Customer Information

When you use Zanora as a customer, we collect:

• Phone Number: Used for account creation, login via OTP (one-time password), and communication about bookings
• Location Data: Your real-time GPS location to show nearby therapists and enable service delivery
• Booking Information: Details of your massage bookings including type, duration, date, time, and service address
• Payment Information: M-Pesa phone number and transaction details processed through Safaricom's M-Pesa API
• Full Name: Shared with your therapist only after you complete a booking
• Device Information: Device type, operating system, and app version for technical support

2.2 Therapist Information

When you register as a therapist on Zanora, we collect:

• Personal Details: Full name, phone number, and email address
• Identification: ID number and photo of your national ID card
• Professional Information: Massage therapy license number and years of experience
• Photos: Two professional photos of you in work attire (scrubs)
• Bank Details: Bank account information for weekly payouts
• Location Data: Real-time GPS location during active sessions to ensure customer safety and service delivery tracking
• Work History: Session completion records, ratings, and earnings data

2.3 Automatically Collected Information

• Usage Data: How you interact with the App, including features used and time spent
• Technical Data: IP address, device ID, crash reports, and performance data for app improvement

3. How We Use Your Information

3.1 Service Delivery

• Match customers with nearby therapists
• Process bookings and payments via M-Pesa
• Enable communication between customers and therapists after booking confirmation
• Provide navigation and real-time tracking during active sessions
• Calculate distances and estimated arrival times

3.2 Safety and Security

• Verify therapist identities through ID verification
• Track therapist location during active sessions for customer safety
• Maintain booking records for dispute resolution
• Detect and prevent fraudulent activity

3.3 Account Management

• Create and maintain user accounts
• Process payments and payouts
• Send booking confirmations and service updates via SMS
• Provide customer support

3.4 App Improvement

• Analyze usage patterns to improve app functionality
• Fix technical issues and optimize performance
• Develop new features based on user needs

We DO NOT:

• Use your data for marketing or promotional purposes
• Share your data with third parties for advertising
• Sell your personal information to anyone

4. Information Sharing and Disclosure

4.1 Between Users

Before Booking: Customers can see therapist photos, ratings, years of experience, and approximate distance. Therapists see booking requests with service type and distance only.

After Booking: Customers receive therapist's full name, phone number, and real-time location. Therapists receive customer's full name, phone number, exact address, and service details.

4.2 Third-Party Service Providers

We share necessary information with:

• Safaricom M-Pesa: For processing payments securely
• SMS Provider: For sending OTP verification codes and booking notifications
• Google Maps: For location services and navigation
• Cloud Storage Provider: For secure storage of photos and documents

These providers are contractually obligated to protect your data and use it only for specified purposes.

4.3 Legal Requirements

We may disclose your information if required by law, court order, or government request, or to:

• Comply with legal obligations
• Protect our rights and property
• Prevent fraud or security issues
• Protect user safety

4.4 Business Transfers

If Zanora Collective is involved in a merger, acquisition, or sale of assets, your information may be transferred. We will notify you before your information becomes subject to a different privacy policy.

5. Data Security

We implement appropriate technical and organizational measures to protect your information, including:

• Encryption of sensitive data in transit and at rest
• Secure authentication systems (OTP verification)
• Regular security audits and updates
• Restricted access to personal data on a need-to-know basis
• Secure third-party payment processing via M-Pesa

However, no method of electronic storage or transmission is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

6. Location Tracking

6.1 Customer Location

We collect your location to:

• Show nearby available therapists
• Enable therapists to navigate to your address
• Calculate accurate distances and arrival times

You can disable location services in your device settings, but this will prevent you from using the App's core features.

6.2 Therapist Location

We track therapist location in real-time only during active sessions to:

• Provide customers with accurate arrival times
• Ensure service delivery and customer safety
• Verify session completion at the correct location

Location tracking stops automatically when a session is marked complete.

7. Data Retention

• Booking History: We retain all booking records indefinitely for accounting, dispute resolution, and service quality purposes
• Account Data: Active account information is retained as long as your account remains active
• Deleted Accounts: When you request account deletion, we deactivate your account immediately and schedule complete data deletion within 3 months. Some information may be retained longer if required by law or for legitimate business purposes (e.g., financial records)
• Verification Documents: Therapist ID photos and professional documents are retained permanently for regulatory compliance and safety verification

8. Your Rights and Choices

8.1 Access and Correction

You can view and update your profile information directly in the App at any time.

8.2 Account Deletion

To delete your account, email us at support@zanora.app with your request. Include your registered phone number. We will:

• Deactivate your account immediately
• Schedule complete data deletion within 3 months
• Confirm deletion via email once complete

Note: Some data may be retained as required by law or for legitimate business purposes.

8.3 Data Portability

Currently, we do not offer automated data export functionality. For specific data requests, contact support@zanora.app.

8.4 Limitations

• Therapists cannot request removal of verification documents (ID photos) as these are required for ongoing regulatory compliance and user safety
• Booking history cannot be deleted as it is necessary for accounting and dispute resolution

9. Children's Privacy

Zanora is intended for users aged 16 and above. We do not knowingly collect information from children under 16. If you believe we have collected information from a child under 16, contact us immediately at support@zanora.app, and we will delete such information promptly.

10. International Data Transfers

Zanora operates exclusively in Kenya. Your data is stored on servers located in Kenya or within the East African region. We do not transfer data outside Kenya except to trusted service providers with adequate data protection measures.

11. Cookies and Tracking Technologies

The App may use cookies and similar tracking technologies to enhance user experience, analyze usage patterns, and provide technical support. You can manage cookie preferences through your device settings.

12. Third-Party Links

Our App may contain links to third-party websites or services (e.g., payment processors). We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of significant changes by:

• Posting the updated policy in the App
• Sending a notification via SMS or in-app alert
• Updating the "Last Updated" date at the top of this policy

Your continued use of the App after changes indicates acceptance of the updated Privacy Policy.

14. Data Protection Officer

For questions about data protection or to exercise your rights, contact our Data Protection Officer:

• Email: support@zanora.app
• Subject Line: Data Protection Inquiry
• Response Time: We aim to respond within 7 business days

15. Compliance

This Privacy Policy complies with:

• Kenya Data Protection Act, 2019
• Kenya Data Protection (General) Regulations, 2021
• Industry best practices for data protection

16. Your Consent

By using Zanora, you consent to:

• Collection and use of your information as described
• Real-time location tracking during active sessions (therapists only)
• Sharing of contact information after booking confirmation
• Processing of payments through third-party providers
• Retention of booking records indefinitely

17. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices:

• Zanora Collective
• Astrol Offices, Thika Road
• Nairobi, Kenya
• Email: support@zanora.app
• Business Registration: BN-RRS3LKOW

Effective Date: This Privacy Policy is effective as of October 31, 2025, and applies to all users of the Zanora application.

By continuing to use Zanora, you acknowledge that you have read, understood, and agree to this Privacy Policy.