ZELORA PRIVACY POLICY
This Privacy Policy explains how Zelora, a product of Zalen Ltd (a company registered in Kenya) (“Zelora”, “we”, “us”, or “our”), collects, uses, stores, shares, and protects personal information when you access or use our website, applications, and related services (collectively, the “Services”).
Zelora provides a digital platform for memorials, eulogies, tributes, event information, symbolic interactions, and funeral-related contributions. We recognize the sensitive nature of this context and are committed to handling data respectfully and lawfully.
1. Data Controller & Contact Information
- Product Name: Zelora
- Legal Entity: Zalen Ltd (Kenya)
- Role: Data Controller
- Contact Email: myzelora.zelora@gmail.com
Zelora determines the purposes and means of processing personal data in connection with the Services.
2. Scope of This Privacy Policy
This Privacy Policy applies to all users of the Services, including:
- Account creators and memorial administrators
- Contributors (friends, family members, well-wishers)
- General visitors and viewers
It applies across our website, mobile applications, communications, integrations, and all current or future Zelora features.
3. Important Notice on Memorial Content & Public Visibility
- Zelora allows users to create memorial pages that may be public or private, depending on user settings.
- Public memorials may be accessible to anyone with a link or via the Zelora platform.
- Content on public memorials may be viewed, shared, or used by third parties beyond our control.
- Memorials may contain emotional, sensitive, or personal information.
Please use the Services at your own discretion. Zelora is not responsible for how third parties use information that is made publicly available by users.
4. Information We Collect
4.1 Personal Data of Living Users
We may collect and process the following information:
- Full name
- Email address
- Phone number
- Profile photo (optional)
- Location information
- Account authentication details (including OTP verification)
- Communication preferences
4.2 Information About Deceased Persons
Users may voluntarily provide information relating to deceased persons, including:
- Full name
- Date of birth and date of death
- Biography or life story
- Photos, videos, and audio
- Burial or memorial event details
- Cause of death
Information relating solely to deceased persons is not considered personal data under applicable data protection laws. However, any information relating to living individuals connected to memorials remains protected under this Policy.
4.3 Financial & Transactional Information
Zelora does not process or hold funds directly. Contributions are processed through third-party payment providers.
Zelora may store limited transaction metadata such as:
- Contributor phone number
- Transaction reference or ID
- Contribution amount
- Date and time of transaction
Contribution details are not publicly visible by default, and anonymous contributions are supported.
4.4 Feature-Specific Interactions (Candle Lighting & Tributes)
Zelora offers symbolic and interactive remembrance features, including virtual candle lighting.
- Candle lighting is visible to anyone with access to a public memorial link.
- Candles are lit through voluntary contributions.
- Displayed information may include contributor name (or anonymous status), timestamp, and associated memorial.
- We collect this interaction data solely to provide and display the feature as intended.
4.5 Technical & Usage Data
We may automatically collect:
- IP address
- Device and browser information
- Log data and access times
- Analytics and usage patterns
5. How We Collect Information
We collect information when you:
- Create or manage an account
- Create or administer a memorial
- Submit tributes, comments, or media
- Make or receive contributions
- Communicate with us
- Use or interact with the Services
6. Lawful Basis for Processing
We process personal data based on one or more of the following:
- Your consent
- Performance of a contract (to provide the Services)
- Compliance with legal obligations
- Legitimate interests, including fraud prevention, platform security, dispute handling, and service improvement
7. How We Use Your Information
We may use your information to:
- Create and manage accounts
- Provide memorial and contribution services
- Process transactions via third-party providers
- Send transactional communications
- Send marketing communications (with opt-out)
- Improve features and user experience
- Prevent fraud, abuse, or impersonation
- Moderate content and enforce platform rules
- Comply with legal or regulatory requirements
8. Marketing & Communications
Zelora may send:
- Transactional emails and SMS
- Marketing emails
- WhatsApp communications
You may opt out of marketing communications at any time. Transactional or service-related messages will still be sent where necessary.
9. Cookies & Analytics
We use cookies and similar technologies to:
- Improve functionality and security
- Analyze usage
- Enhance user experience
We may use third-party analytics tools such as Google Analytics and Hotjar. You can manage cookies through your browser settings.
10. Third-Party Services
We use trusted third parties for:
- Payment processing
- Hosting and infrastructure (e.g. AWS, Firebase)
- Analytics and communications
These providers process data under contractual obligations consistent with this Privacy Policy. Zelora does not sell personal data.
11. User-Generated Content, Verification & Responsibility
Users may create memorials and content without proof of kinship at the time of creation.
Where a user seeks to withdraw funds or manage contributions, Zelora may require additional verification, including:
- Government-issued identification; and/or
- Contact details of a relative or trusted representative.
Zelora may restrict access to financial features until verification is completed.
12. Admin Access & Platform Support
Zelora administrators may access user accounts in a limited and controlled manner for support, moderation, dispute resolution, security, or compliance purposes.
Administrators cannot initiate, approve, or execute withdrawals or financial transactions on behalf of users.
13. Reporting, Takedown & Disputes
- Content may be reported for being offensive, misleading, unlawful, or impersonating.
- Zelora reserves the right to remove, restrict, or disable content at its discretion and without prior notice.
- In the event of disputes between family members or contributors, Zelora remains neutral and may temporarily restrict actions until resolution.
14. Memorial Succession
If a memorial administrator is deceased, incapacitated, unreachable, or otherwise unable to manage a memorial, Zelora may reassign administrative control upon reasonable verification.
15. Data Retention & Deletion
Account & Memorial Deletion
- Upon deletion request, content is archived for up to 30 days.
- Archived content is not publicly accessible.
- Permanent deletion occurs within 30–60 days, unless retention is legally required.
Paid Memorials
- Retained for the duration of an active subscription.
- Archived and deleted after subscription expiry and archive period.
Legal & Financial Records
Certain data may be retained longer for legal compliance, fraud prevention, accounting, or dispute resolution.
16. Your Rights
Subject to applicable law, you have the right to:
- Be informed about data use
- Access your personal data
- Correct inaccurate data
- Request deletion
- Object to or restrict processing
- Withdraw consent
- Request data portability (where applicable)
Identity verification may be required before fulfilling requests.
17. International Data Transfers
Your data may be stored or processed outside Kenya. We take reasonable steps to ensure appropriate safeguards are in place.
18. Business Transfers
In the event of a merger, acquisition, restructuring, or sale of assets, user data may be transferred as part of the transaction, subject to continued protection under this Policy or an equivalent standard.
19. Security
We implement reasonable administrative, technical, and organizational measures to protect personal data. However, no system is completely secure, and absolute security cannot be guaranteed.
20. Updates to This Policy
We may update this Privacy Policy from time to time. Material changes will be communicated appropriately. Continued use of the Services constitutes acceptance of the updated Policy.
21. Contact Us
For questions, concerns, or requests regarding this Privacy Policy, contact:
Email: myzelora.zelora@gmail.com