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**Effective Date:** December 31, 2025 **1\. Introduction** -------------------- This Privacy Policy describes how **Lioneur PTY LTD** trading as **AfriBot** ("Company," "we," "us," or "our"), located at Pretoria, Gauteng, 0157, South Africa, collects, uses, discloses, stores, and protects your personal information when you use our AI content generation platform ("Platform"). **Afribot only offer services in South Africa.** **Contact Information:**Email: [email protected]: https://afribot.co.za This Privacy Policy is designed to comply with the **Protection of Personal Information Act 4 of 2013 (POPIA)** and other applicable data protection laws. By accessing or using the Platform, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described herein. Our Platform enables users to generate AI-powered content (including text, images, code, and chat interactions), collaborate in teams by sharing chats and resources, and participate in affiliate programs. We are committed to protecting your privacy, processing personal information lawfully, transparently, and in accordance with recognized data protection principles. **If you do not agree with any part of this Privacy Policy, you must not use the Platform.** **2\. Definitions** ------------------- For purposes of this Privacy Policy: * **"Personal Information"** means information relating to an identifiable, living, natural person, and where applicable, an identifiable, existing juristic person, as defined under POPIA * **"Processing"** means any operation or activity concerning personal information, including collection, receipt, recording, organization, collation, storage, updating, modification, retrieval, alteration, consultation, use, dissemination, merging, linking, restriction, degradation, erasure, or destruction * **"Special Personal Information"** means personal information concerning religious or philosophical beliefs, race or ethnic origin, trade union membership, political persuasion, health or sex life, biometric information, or criminal behavior * **"Data Subject"** means you, the person to whom personal information relates * **"Third Party"** means any person or entity other than you or us **3\. Personal Information We Collect** --------------------------------------- We collect various categories of personal information depending on how you interact with our Platform: ### **3.1 Account Information** When you create an account, we collect: * Full name * Email address * Password (stored in encrypted form) * Username or display name * Phone number (if provided) * Company name (if applicable) * Billing address * Tax identification information (if applicable) * Account preferences and settings ### **3.2 Payment and Transaction Data** When you make purchases or participate in our affiliate program, we collect: * Payment method details (credit/debit card information, bank account details) * Billing information and invoicing details * Transaction history and payment records * Purchase amounts and dates * Currency and payment processor information * Affiliate earnings and payout information * Tax documentation (if applicable for affiliate payments) **Important:** Payment card details are processed by third-party payment processors (PayStack, PayPal, Stripe) and are subject to their privacy policies. We do not directly store complete credit card numbers on our servers. ### **3.3 Usage Data and Platform Interactions** We automatically collect information about how you use the Platform: * IP address and geolocation data * Browser type, version, and language settings * Device information (type, operating system, unique device identifiers) * Date and time of access * Pages visited and features used * Referral URLs and clickstream data * AI model selections and preferences * Response times and error logs ### **3.4 AI Content Generation Data** When you use our AI services, we collect and process: * **Input prompts and queries** you submit to AI models * **AI-generated outputs** (text, images, code, chat responses) * **Conversation histories** including multi-turn chat interactions * **Generation parameters** (model settings, temperature, tokens used) * **Content preferences** and customization settings * **Feedback** on AI-generated content (ratings, corrections) * **Files uploaded** for processing (documents, images, data files) **Critical Privacy Notice:** Your prompts and AI-generated content may contain personal information, confidential business information, or sensitive data. You are solely responsible for what you input into the Platform. We strongly advise against inputting: * Personal identification numbers (ID numbers, passport numbers) * Financial account information * Health or medical information * Confidential business data or trade secrets * Personal information of third parties without their consent ### **3.5 Team Collaboration Data** If you use team features, we collect: * Team member names and email addresses * Role and permission settings * Shared chat histories and content * Team activity logs * Collaboration metadata (who shared what, when) * Any personal information voluntarily included in team communications **Team Privacy Notice:** Information you share with team members becomes accessible to all team members with appropriate permissions. Be cautious about sharing sensitive personal information in team environments. ### **3.6 Affiliate Program Data** If you participate in our affiliate program, we collect: * Affiliate referral links and tracking codes * Referral sources and marketing channels used * Conversion data and referred user information * Commission earnings and payment history * Bank account or payment details for payouts * Tax forms and identification documentation * Marketing materials and promotional content you create ### **3.7 Customer Support and Communications Data** When you contact us for support or communications, we collect: * Support ticket content and correspondence * Email communications with our team * Chat logs with customer service representatives * Phone call recordings (where permitted and disclosed) * Feedback, surveys, and review responses * Screenshots or diagnostic information you provide * Any personal information you voluntarily disclose in support requests ### **3.8 Cookies and Tracking Technologies Data** We collect information through cookies and similar technologies: * Session cookies for authentication and functionality * Persistent cookies for preferences and settings * Analytics cookies for usage patterns and performance * Marketing cookies for advertising (if applicable) * Local storage data * Device fingerprinting information For detailed information, see Section 11 (Cookies and Tracking Technologies). ### **3.9 Special Personal Information** We **do not intentionally collect** special personal information as defined by POPIA (race, ethnicity, religious beliefs, health data, biometric data, sexual orientation, criminal history) unless: * You voluntarily provide such information in your AI prompts or content * It is necessary for a specific, lawful purpose with your explicit consent * Required by law **If you include special personal information in your AI inputs, you do so at your own risk and responsibility.** ### **3.10 Information from Third Parties** We may receive personal information about you from: * Payment processors (PayStack, PayPal, Stripe) regarding transaction status * Third-party AI service providers (OpenAI, etc.) regarding API usage * Analytics services (Google Analytics, etc.) * Social media platforms if you connect accounts * Affiliate partners who refer you to our Platform * Public databases and identity verification services (for fraud prevention) **4\. How We Collect Personal Information** ------------------------------------------- Personal information is collected through the following methods: ### **4.1 Direct Collection** Information you provide directly by: * Creating an account and completing registration forms * Entering payment information for purchases * Submitting prompts and inputs to AI models * Uploading files or documents to the Platform * Participating in team collaborations and sharing content * Communicating with customer support * Completing surveys, feedback forms, or contests * Subscribing to newsletters or updates * Registering for our affiliate program ### **4.2 Automatic Collection** Information collected automatically through: * Cookies, web beacons, and similar tracking technologies * Server logs and access logs * Analytics tools and measurement services * Error reporting and diagnostic systems * Security monitoring and fraud detection systems * AI model interaction tracking ### **4.3 Third-Party Sources** Information received from: * Payment service providers completing transactions * AI service providers processing your requests * Marketing and analytics partners * Affiliate networks and referral partners * Publicly available sources (where legally permissible) * Identity verification and fraud prevention services **5\. Lawful Bases and Purposes for Processing** ------------------------------------------------ We process your personal information based on the following lawful grounds under POPIA and for the following purposes: ### **5.1 Consent** With your explicit consent, we process personal information to: * Send marketing communications and newsletters * Enable optional features or services * Share data with third parties for specific purposes * Process special personal information (if provided) * Use cookies and tracking technologies (where required) **You may withdraw consent at any time** by contacting [email protected], though withdrawal may affect your ability to use certain features. ### **5.2 Contractual Necessity** To perform our contract with you (Terms of Service), we process personal information to: * Create and manage your account * Provide AI content generation services * Process AI prompts and deliver outputs * Enable team collaboration features * Facilitate affiliate program participation * Process payments and manage subscriptions * Provide customer support and respond to inquiries * Enforce our Terms of Service and user agreements ### **5.3 Legal Obligations** To comply with legal requirements, we process personal information to: * Respond to lawful requests from authorities * Comply with court orders, subpoenas, or legal processes * Meet tax, accounting, and regulatory reporting obligations * Fulfill data retention requirements under applicable laws * Cooperate with law enforcement investigations * Comply with POPIA and other data protection regulations * Process affiliate tax documentation and reporting ### **5.4 Legitimate Interests** Based on our legitimate business interests (balanced against your rights), we process personal information to: * Improve and optimize the Platform and user experience * Develop new features, services, and AI capabilities * Conduct analytics and usage research * Maintain security and prevent fraud, abuse, or illegal activity * Debug, troubleshoot, and resolve technical issues * Manage business operations and internal administration * Exercise or defend legal claims * Protect our rights, property, and safety or that of others * Communicate important service updates and changes **You have the right to object to processing based on legitimate interests.** ### **5.5 Additional Specific Purposes** **For AI Content Generation:** * Process your prompts through third-party AI models * Store conversation histories for continuity * Improve AI output quality and relevance * Train and fine-tune AI models (only with anonymized data and your consent) **For Team Collaboration:** * Share content with designated team members * Manage team permissions and access controls * Facilitate real-time collaboration features **For Affiliate Program:** * Track referrals and attribute conversions * Calculate commissions and process payments * Prevent affiliate fraud and abuse * Communicate program updates and performance **For Platform Improvement:** * Analyze usage patterns and user behavior (anonymized where possible) * Conduct A/B testing and experiments * Monitor platform performance and uptime * Identify and fix bugs or technical issues **We will not process your personal information for purposes incompatible with those disclosed without obtaining your additional consent.** **6\. Disclosure and Sharing of Personal Information** ------------------------------------------------------ We share your personal information with third parties only as described below: ### **6.1 Service Providers and Business Partners** We share information with trusted third-party service providers who assist us in operating the Platform: **AI Service Providers:** * OpenAI and other AI model providers to process your prompts and generate content * Your prompts and generated outputs are subject to third-party provider terms and privacy policies * We do not control how third-party AI providers use data for their own purposes (e.g., model training) **Payment Processors:** * PayStack, PayPal, Stripe, and other payment gateways to process transactions * These providers receive billing information, payment details, and transaction data * Payment processors operate under their own privacy policies and security standards **Cloud and Hosting Providers:** * Infrastructure and hosting services to store data and run the Platform * May include Amazon Web Services (AWS), Google Cloud, Microsoft Azure, or similar providers **Analytics and Performance Services:** * Google Analytics and similar tools to analyze Platform usage * Performance monitoring and error tracking services * Heat mapping and user behavior analysis tools **Customer Support Tools:** * Help desk and ticketing systems to manage support requests * Live chat and communication platforms **Marketing and Communication Services:** * Email service providers for transactional and marketing emails * SMS providers for notifications (if applicable) * Advertising platforms and networks (if applicable) **Security and Fraud Prevention:** * Identity verification services * Fraud detection and prevention platforms * Security monitoring and threat intelligence providers All service providers are contractually obligated to: * Use personal information only for specified purposes * Maintain appropriate security measures * Comply with applicable data protection laws * Not disclose information to unauthorized parties ### **6.2 Team Members and Collaboration** Personal information is shared within teams according to permissions you configure: * Team administrators can view member information and activity * Team members can access shared chats, content, and resources * Collaboration features may expose your name, email, and contributions to other team members **You are responsible for managing team access and permissions appropriately.** ### **6.3 Affiliate Partners** If you participate in our affiliate program: * Your affiliate performance data may be shared with our affiliate management platform * Referred users may see your affiliate link or identifier * We may share commission data with payment processors for payouts ### **6.4 Legal and Regulatory Authorities** We may disclose personal information when required or permitted by law: * To comply with court orders, subpoenas, warrants, or legal processes * To respond to lawful requests from government authorities or law enforcement * To investigate potential violations of our Terms of Service * To protect against fraud, security threats, or illegal activity * To protect our rights, property, safety, or that of our users or the public * To enforce our legal rights and remedies * As required by tax, financial, or regulatory authorities ### **6.5 Business Transfers** In the event of: * Merger, acquisition, or sale of assets * Bankruptcy, insolvency, or restructuring proceedings * Corporate reorganization or business combination Your personal information may be transferred to the acquiring or successor entity. We will notify you of such transfers and any choices you may have. ### **6.6 With Your Consent** We may share personal information with other third parties when you provide explicit consent, such as: * Integrations with third-party applications you authorize * Social media sharing features you enable * Third-party services you connect to your account * Marketing partners for joint promotions (with opt-in) ### **6.7 Aggregated and Anonymized Data** We may share aggregated, anonymized, or de-identified data that cannot reasonably identify you: * Usage statistics and trends * Performance benchmarks and metrics * Research and analytics insights * Public reporting and marketing materials **This anonymized data is not considered personal information and is not subject to this Privacy Policy.** ### **6.8 Cross-Border Data Transfers** **Important Notice:** Some of our service providers and AI model providers are located outside South Africa, including in the United States, European Union, and other jurisdictions. **When we transfer personal information internationally, we ensure:** * The recipient country provides an adequate level of data protection as recognized by South African law, OR * Appropriate safeguards are in place, such as: * Standard contractual clauses approved by data protection authorities * Binding corporate rules * Certification schemes (e.g., EU-U.S. Privacy Shield successors) * Explicit consent for the specific transfer **Specific International Transfers:** * **OpenAI (United States):** AI prompts and outputs are processed in the U.S. under contractual protections * **PayPal (United States):** Payment data may be transferred to the U.S. subject to PayPal's privacy policy * **Cloud providers:** Data may be stored in data centers globally based on our hosting configuration **You consent to these cross-border transfers by using the Platform.** If you do not consent to international transfers, you should not use the Platform, as such transfers are essential to our services. **7\. Data Security Measures** ------------------------------ We take the security of your personal information seriously and implement reasonable technical and organizational measures to protect against unauthorized access, loss, destruction, alteration, or disclosure. ### **7.1 Technical Security Measures** * **Encryption:** Data is encrypted in transit using TLS/SSL protocols and at rest where feasible * **Access Controls:** Role-based access controls limit employee and system access to personal information * **Authentication:** Strong password requirements and multi-factor authentication options * **Firewalls:** Network security measures including firewalls and intrusion detection systems * **Monitoring:** Continuous security monitoring and logging of access to sensitive systems * **Vulnerability Management:** Regular security assessments, penetration testing, and patch management * **Secure Development:** Security-focused software development practices and code reviews ### **7.2 Organizational Security Measures** * **Employee Training:** Regular privacy and security training for all personnel * **Confidentiality Obligations:** Employees and contractors sign confidentiality agreements * **Need-to-Know Access:** Personal information access is limited to authorized personnel only * **Vendor Management:** Third-party providers are vetted for security practices * **Incident Response:** Documented procedures for detecting and responding to security incidents * **Data Minimization:** Collection and retention of only necessary personal information * **Regular Audits:** Periodic security and compliance audits ### **7.3 Security Limitations** **Despite our efforts, no security measures are 100% effective.** We cannot guarantee absolute security of your personal information. Risks include: * Unauthorized access by hackers or malicious actors * Technical failures or system vulnerabilities * Human error or insider threats * Third-party breaches affecting our service providers **You are responsible for:** * Maintaining the confidentiality of your account credentials * Using strong, unique passwords * Enabling multi-factor authentication where available * Not sharing your account with others * Logging out of your account when using shared devices * Promptly notifying us of any suspected unauthorized access ### **7.4 Data Breach Notification** In the event of a data breach that is likely to result in a high risk to your rights and freedoms: * We will notify you **without undue delay** via email or prominent notice on the Platform * We will notify the **Information Regulator** as required by POPIA * Notification will include: * Nature of the breach and categories of data affected * Number of data subjects impacted (if known) * Likely consequences of the breach * Measures taken or proposed to mitigate harm * Recommended actions you should take **Report suspected security issues to:** [email protected] with subject line "Security Concern" **8\. Your Rights as a Data Subject** ------------------------------------- Under POPIA, you have the following rights regarding your personal information: ### **8.1 Right to Access (Section 23)** You have the right to: * Request confirmation of whether we hold personal information about you * Request access to your personal information * Receive information about how your data is processed **How to exercise:** Email [email protected] with subject "Access Request" and include: * Your full name and account email * Specific information you wish to access * Proof of identity (copy of ID document) **Response time:** We will respond within a reasonable period, typically within 30 days. ### **8.2 Right to Correction (Section 24)** You have the right to: * Request correction of inaccurate or incomplete personal information * Update your account details directly through Platform settings **How to exercise:** * Update information directly in your account settings, OR * Email [email protected] with subject "Correction Request" ### **8.3 Right to Deletion/Destruction (Section 26)** You have the right to request deletion of your personal information when: * It is no longer necessary for the purpose collected * You withdraw consent (where consent was the lawful basis) * You object to processing and no overriding legitimate grounds exist * Processing is unlawful * Required by legal obligation **Limitations:** We may retain certain information where: * Required by law (e.g., tax records, transaction history) * Necessary for legal claims or defense * Needed to protect our rights or those of others * Anonymized for research or analytics **How to exercise:** Email [email protected] with subject "Deletion Request" or delete your account through Platform settings. **Note:** Account deletion is permanent and cannot be reversed. All associated data, including AI conversation histories and generated content, will be deleted. ### **8.4 Right to Object (Section 25)** You have the right to object to processing based on: * **Legitimate interests:** You may object to processing for our legitimate interests * **Direct marketing:** You may object to receiving marketing communications at any time **How to exercise:** * Click "unsubscribe" in marketing emails * Email [email protected] with subject "Objection to Processing" * Adjust communication preferences in account settings ### **8.5 Right to Restrict Processing** You may request restriction of processing when: * You contest the accuracy of personal information (during verification) * Processing is unlawful but you don't want deletion * We no longer need the data but you need it for legal claims * You have objected to processing (pending verification of our legitimate grounds) **How to exercise:** Email [email protected] with subject "Restrict Processing Request" ### **8.6 Right to Data Portability** You have the right to: * Receive personal information you provided in a structured, commonly used format * Transmit that information to another controller (where technically feasible) **How to exercise:** Email [email protected] with subject "Data Portability Request" ### **8.7 Right to Withdraw Consent** Where processing is based on consent, you may withdraw consent at any time by: * Adjusting settings in your account * Clicking "unsubscribe" in emails * Emailing [email protected] **Note:** Withdrawal does not affect the lawfulness of processing before withdrawal. Some services may become unavailable if you withdraw necessary consent. ### **8.8 Right to Lodge a Complaint** You have the right to lodge a complaint with the Information Regulator if you believe your rights have been violated: **Information Regulator (South Africa)**SALU Building, 316 Thabo Sehume StreetPretoria, 0002Email: [email protected]: https://www.justice.gov.za/inforeg/ **You may also contact us first at [email protected] to resolve concerns.** ### **8.9 Exercising Your Rights** **General Requirements:** * Requests must be in writing (email acceptable) * Proof of identity may be required to prevent unauthorized disclosure * Requests must be specific and clearly state which right you're exercising * We may request additional information to verify and process your request **Response Obligations:** * We will acknowledge receipt of your request promptly * We will respond substantively within a reasonable period (typically 30 days) * We may extend this period for complex requests (with notification) * We will provide reasons if we decline your request **Fees:** * Access requests are generally free for the first request per year * We may charge a reasonable fee for: * Excessive or repetitive requests * Requests requiring disproportionate effort * Provision of additional copies * Fees will be communicated before processing **Verification:** To protect your privacy, we may require verification of identity before processing requests. This may include: * Government-issued ID document * Verification of account ownership * Additional authentication steps **9\. User Responsibilities and Prohibited Data Sharing** --------------------------------------------------------- ### **9.1 Your Obligations** To ensure the security, integrity, and legal compliance of our Platform, **you must not:** * **Share confidential information:** Do not input proprietary business information, trade secrets, confidential financial data, or any other confidential information into AI prompts or team chats * **Share personal data of others:** Do not input personal information of third parties (employees, customers, contacts) without their explicit consent and a lawful basis * **Share intellectual property you don't own:** Do not input copyrighted material, patented information, or other intellectual property belonging to others without authorization * **Share sensitive personal information:** Avoid inputting health data, financial account numbers, government ID numbers, passwords, or other highly sensitive data * **Share illegal content:** Do not input or generate content that violates laws or regulations ### **9.2 Consequences of Violations** **We are not responsible for:** * Any loss, damage, or legal consequences arising from your violation of these responsibilities * Data breaches or unauthorized access resulting from your inappropriate data sharing * Third-party claims related to data you improperly share on the Platform * Regulatory fines or penalties resulting from your non-compliance with data protection laws ### **9.3 Indemnification** By using AfriBot, you agree to: * Comply with all user responsibilities outlined in this section * Indemnify and hold harmless Lioneur PTY LTD against any claims, damages, losses, or expenses (including legal fees) arising from: * Your violation of these data sharing restrictions * Improper disclosure of confidential or personal information * Third-party claims related to data you shared on the Platform * Your failure to obtain necessary consents or authorizations ### **9.4 Best Practices** **To protect privacy and security:** * Remove or anonymize personal identifiers before inputting data into AI prompts * Use generic examples rather than actual confidential information * Do not include full names, email addresses, phone numbers, or other identifiers in prompts * Be mindful of what you share in team collaborations * Regularly review team permissions and remove access when no longer needed * Avoid saving sensitive information in conversation histories **We strongly recommend conducting a privacy impact assessment before using the Platform for any business-critical or sensitive data processing.** **10\. Data Retention** ----------------------- We retain personal information only as long as necessary for the purposes outlined in this Privacy Policy or as required by law. ### **10.1 Retention Periods** **Account Data:** * Retained for the duration of your active account * Retained for up to 12 months after account deletion for legal and operational purposes * Some data may be retained longer if required by law **AI Conversation Histories and Generated Content:** * Retained for the duration of your active account * May be retained for up to 90 days after account deletion for backup and recovery purposes * Permanently deleted after retention period expires **Payment and Transaction Records:** * Retained for at least 5 years as required by South African tax and financial regulations * May be retained longer for legal compliance, accounting, or dispute resolution **Affiliate Program Data:** * Retained for at least 5 years for tax reporting and audit purposes * Commission records retained in accordance with financial regulations **Support and Communications:** * Support tickets retained for up to 3 years for quality assurance and issue tracking * May be retained longer for ongoing disputes or legal matters **Usage and Analytics Data:** * Anonymized analytics retained indefinitely for business intelligence * Identifiable usage logs retained for up to 12 months **Legal and Compliance Records:** * Data related to legal claims, investigations, or regulatory matters retained until resolved plus applicable limitation periods * Compliance records retained as required by specific regulations ### **10.2 Deletion and Anonymization** Upon expiration of retention periods: * Personal information is **permanently deleted** from active systems * Backups are **overwritten** according to our backup retention schedule (typically within 90 days) * Data may be **anonymized** rather than deleted if used for legitimate research or analytics purposes ### **10.3 Exceptions** We may retain personal information beyond stated periods when: * Required by law, regulation, or legal process * Necessary for pending or potential legal claims * Needed to enforce our Terms of Service * Required to protect rights, property, or safety ### **10.4 User-Initiated Deletion** You may request early deletion of your personal information at any time (subject to legal retention requirements) by: * Deleting your account through Platform settings * Emailing [email protected] with a deletion request **Note:** Deletion is permanent and irreversible. We cannot recover deleted data. **11\. Cookies and Tracking Technologies** ------------------------------------------ We use cookies and similar tracking technologies to enhance your experience, analyze usage, and improve our Platform. ### **11.1 What Are Cookies?** Cookies are small text files stored on your device by your web browser. They enable websites to remember your preferences, authenticate your session, and collect usage information. ### **11.2 Types of Cookies We Use** **Essential Cookies (Required):** * Session management and authentication * Security and fraud prevention * Platform functionality and features * Load balancing and performance optimization **These cookies are necessary for the Platform to function and cannot be disabled.** **Performance and Analytics Cookies (Optional):** * Google Analytics and similar tools * Error tracking and debugging * Usage patterns and feature engagement * Performance monitoring and optimization * A/B testing and experimentation **Functional Cookies (Optional):** * User preferences and settings * Language and region selection * Customization and personalization * Remember login status **Marketing and Advertising Cookies (Optional, if applicable):** * Targeted advertising and retargeting * Conversion tracking * Affiliate attribution * Social media integration ### **11.3 Other Tracking Technologies** In addition to cookies, we may use: * **Web beacons/pixels:** Small images that track email opens and link clicks * **Local storage:** HTML5 local storage for offline functionality * **Session storage:** Temporary storage cleared when browser closes * **Device fingerprinting:** Combining device characteristics for identification * **SDKs and APIs:** Third-party software development kits in mobile apps (if applicable) ### **11.4 Managing Cookie Preferences** **Browser Settings:** Most browsers allow you to: * View and delete existing cookies * Block all cookies or third-party cookies * Receive notifications when cookies are set * Configure exceptions for specific sites **Opt-Out Tools:** * Google Analytics Opt-out: https://tools.google.com/dlpage/gaoptout * Industry opt-out pages: * http://www.aboutads.info/choices/ * http://www.youronlinechoices.eu/ **Platform Settings:** You may adjust cookie preferences in your account settings (where available). **Consequences of Disabling Cookies:** Blocking essential cookies will prevent you from using the Platform. Disabling optional cookies may: * Limit personalization and customization * Affect performance and functionality * Require repeated login * Reduce our ability to improve the Platform ### **11.5 Do Not Track Signals** Some browsers offer "Do Not Track" (DNT) signals. We currently do not respond to DNT signals as there is no industry consensus on how to interpret them. ### **11.6 Cookie Retention** * Session cookies expire when you close your browser * Persistent cookies remain until expiration date or manual deletion * Our cookies typically expire within 1-2 years unless refreshed ### **11.7 Third-Party Cookies** Third-party service providers (Google Analytics, payment processors, etc.) may set their own cookies. We do not control these cookies, which are subject to the third party's privacy policy. **12\. Children's Privacy** --------------------------- ### **12.1 Age Restrictions** Our Platform is **not intended for children under 18 years of age.** We do not knowingly collect personal information from minors without verifiable parental or guardian consent. ### **12.2 Verification and Consent** If you are under 18 years old: * You must obtain consent from a parent or legal guardian before using the Platform * A parent or guardian must create the account and agree to these terms on your behalf * The parent/guardian is responsible for supervising usage and monitoring content ### **12.3 Discovery of Underage Users** If we become aware that we have collected personal information from a child under 18 without proper parental consent: * We will take immediate steps to delete such information * We will terminate the associated account * We will notify the parent/guardian if contact information is available ### **12.4 Parental Rights** Parents and guardians have the right to: * Review personal information collected from their child * Request correction or deletion of such information * Refuse further collection or use of their child's information * Exercise all rights described in Section 8 on behalf of their child ### **12.5 Reporting Underage Accounts** If you believe a child under 18 is using the Platform without proper consent, please report it immediately to [email protected] with subject line "Underage Account Report." **13\. Changes to This Privacy Policy** --------------------------------------- ### **13.1 Right to Modify** We reserve the right to update, modify, or replace this Privacy Policy at any time at our sole discretion to reflect: * Changes in our data practices or Platform features * Legal, regulatory, or compliance requirements * Industry best practices and standards * User feedback and evolving privacy expectations ### **13.2 Notification of Changes** **For material changes that significantly affect your rights or how we process personal information:** * We will notify you via email to your registered email address * We will post a prominent notice on the Platform * We will update the "Effective Date" at the top of this Policy * We may require your explicit consent for certain changes **For minor or non-material changes:** * We will update the Policy and the "Effective Date" * We will post a notice on the Platform (may not be prominent) * Email notification may not be provided ### **13.3 Acceptance of Changes** Your continued use of the Platform after changes become effective constitutes your acceptance of the revised Privacy Policy. **If you do not agree with changes, you must:** * Stop using the Platform immediately * Delete your account * Contact us to exercise your data deletion rights ### **13.4 Review Responsibility** It is your responsibility to periodically review this Privacy Policy for changes. We recommend checking this page regularly, especially before providing new personal information. ### **13.5 Prior Versions** Previous versions of this Privacy Policy may be available upon request for comparison purposes. Contact [email protected] to request historical versions. **14\. International Users and Data Transfers** ----------------------------------------------- ### **14.1 South African Jurisdiction** Our Platform is operated from South Africa and is subject to South African law, including POPIA. By using the Platform from outside South Africa, you acknowledge that: * Your information may be transferred to and processed in South Africa * South African data protection laws will apply * You consent to such transfer and processing ### **14.2 European Economic Area (EEA) Users** If you are located in the EEA, you have additional rights under the General Data Protection Regulation (GDPR). We provide similar protections under POPIA, but you may contact us for GDPR-specific information. ### **14.3 California Residents** If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA). Please contact us for information specific to your rights. ### **14.4 Other Jurisdictions** Users in other jurisdictions may have additional rights under local laws. We will comply with such laws to the extent they apply to our operations. **15\. Third-Party Services and Links** --------------------------------------- ### **15.1 Third-Party AI Providers** Our Platform integrates with third-party AI services (including OpenAI and others). When you use AI features: * Your prompts and data are transmitted to these providers * Third-party providers process data according to their own privacy policies * We do not control third-party data practices * Third parties may use data to improve their models (per their policies) **Important Links:** * OpenAI Privacy Policy: https://openai.com/policies/privacy-policy * \[Other AI provider policies as applicable\] ### **15.2 Payment Processors** Payment information is processed by: * **PayStack:** https://paystack.com/privacy * **PayPal:** https://www.paypal.com/privacy * **Stripe:** https://stripe.com/privacy We do not store complete payment card information on our servers. ### **15.3 Third-Party Websites** Our Platform may contain links to third-party websites, services, or resources. We are not responsible for: * Privacy practices of third-party sites * Content or accuracy of third-party sites * Third-party data collection or processing **We encourage you to review privacy policies of any third-party sites you visit.** ### **15.4 No Endorsement** Links to third-party sites do not constitute an endorsement of their privacy practices or content. **16\. Business Transfers and Corporate Changes** ------------------------------------------------- In the event of a merger, acquisition, reorganization, bankruptcy, or sale of assets: * Your personal information may be transferred to the acquiring or successor entity * The transferee will be bound by this Privacy Policy (or provide equivalent protections) * We will notify you of such transfers via email and/or prominent notice on the Platform * You will have the opportunity to delete your account before transfer (subject to legal requirements) * You may exercise your data rights with the new entity **17\. Automated Decision-Making and Profiling** ------------------------------------------------ ### **17.1 Limited Automated Decisions** We may use automated decision-making in limited circumstances: * Fraud detection and prevention * Account security and access control * Content moderation and filtering * Personalization of AI model recommendations ### **17.2 Your Rights** You have the right to: * Request human review of automated decisions that significantly affect you * Express your point of view regarding automated decisions * Contest automated decisions ### **17.3 No High-Stakes Automated Decisions** We do not use solely automated decision-making for decisions that produce legal effects or similarly significantly affect you (such as credit decisions, employment, etc.). **18\. Contact Information and Data Protection Officer** -------------------------------------------------------- ### **18.1 General Inquiries** For questions, concerns, or requests regarding this Privacy Policy or our data practices: **Lioneur PTY LTD (AfriBot)**Pretoria, Gauteng, 0157South Africa **Email:** [email protected]**Website:** https://afribot.co.za ### **18.2 Data Subject Rights Requests** To exercise your rights under POPIA (access, correction, deletion, objection, etc.): * Email: [email protected] * Subject line: Include the specific right you're exercising (e.g., "Access Request") * Include: Your name, account email, and proof of identity ### **18.3 Security Concerns** To report security vulnerabilities or data breaches: * Email: [email protected] * Subject line: "Security Concern" or "Data Breach Report" * Include: Detailed description and any relevant evidence ### **18.4 Response Timeframes** We will respond to your inquiries: * Acknowledgment within 3-5 business days * Substantive response within 30 days (may be extended for complex requests) **19\. Complaints and Dispute Resolution** ------------------------------------------ ### **19.1 Internal Complaints** We encourage you to contact us first to resolve any privacy concerns: * Email: [email protected] * Subject line: "Privacy Complaint" * Include: Detailed description of your concern We will investigate and respond within a reasonable timeframe. ### **19.2 Information Regulator** If you are unsatisfied with our response, you may lodge a complaint with: **Information Regulator (South Africa)**SALU Building316 Thabo Sehume StreetPretoria, 0002South Africa **Phone:** +27 (0) 12 406 4818**Email:** [email protected]**Website:** https://www.justice.gov.za/inforeg/ ### **19.3 Alternative Dispute Resolution** We are committed to resolving disputes amicably. We may engage in mediation or alternative dispute resolution before litigation. **20\. Consent and Acknowledgment** ----------------------------------- By creating an account, accessing, or using the AfriBot Platform, you acknowledge and confirm that: 1. **You have read and understood** this Privacy Policy in its entirety 2. **You consent to the collection, use, processing, and disclosure** of your personal information as described herein 3. **You understand the nature of AI services** and the data processing involved 4. **You consent to cross-border data transfers** to third-party AI providers and service providers outside South Africa 5. **You understand your responsibilities** regarding the types of data you input into the Platform 6. **You agree to receive communications** from us as described in this Policy 7. **You understand your rights** under POPIA and how to exercise them 8. **You acknowledge the limitations** of our liability regarding data security and third-party services **If you do not consent to these terms, you must not use the Platform.** **21\. Definitions and Interpretation** --------------------------------------- ### **21.1 POPIA-Specific Terms** Terms used in this Privacy Policy have the meanings assigned in POPIA unless otherwise defined herein. ### **21.2 Interpretation** * Headings are for convenience only and do not affect interpretation * Singular includes plural and vice versa * References to "including" are not limiting * References to laws include amendments and replacements ### **21.3 Language** This Privacy Policy is provided in English. In case of translation, the English version prevails. **22\. Severability and Waiver** -------------------------------- ### **22.1 Severability** If any provision of this Privacy Policy is found invalid or unenforceable, such provision shall be modified to the minimum extent necessary to make it valid and enforceable. If modification is not possible, the provision shall be severed, and the remainder of the Policy shall remain in full effect. ### **22.2 No Waiver** Our failure to enforce any provision of this Privacy Policy does not constitute a waiver of that provision or our right to enforce it in the future. **23\. Entire Agreement** ------------------------- This Privacy Policy, together with our Terms of Service and any other policies referenced herein, constitutes the entire agreement between you and Lioneur PTY LTD regarding privacy and data protection on the Platform. **Summary of Key Points** ------------------------- **For your convenience, here is a summary of the most important points (this summary does not replace the full Privacy Policy):** ✅ **What We Collect:** Account information, payment data, AI prompts and outputs, usage data, team collaboration content, affiliate program data ✅ **Why We Collect It:** To provide AI services, process payments, enable collaboration, run affiliate program, improve the Platform, comply with laws ✅ **Who We Share With:** AI providers (OpenAI, etc.), payment processors (PayStack, PayPal, Stripe), cloud hosting, analytics services, team members you authorize ✅ **International Transfers:** Your data may be transferred to the U.S. and other countries with appropriate safeguards ✅ **Your Rights:** Access, correction, deletion, objection, data portability, withdraw consent, lodge complaints ✅ **Security:** We use encryption, access controls, and security measures, but no system is 100% secure ✅ **Retention:** Data retained as long as necessary for purposes or as required by law (typically months to years depending on data type) ✅ **Cookies:** We use essential cookies (required) and optional cookies for analytics and marketing (you can manage preferences) ✅ **Your Responsibilities:** Don't input confidential, sensitive, or third-party data without proper authorization ✅ **No Refunds:** Related to payments - see Terms of Service ✅ **Contact:** [email protected] for any privacy questions or to exercise your rights **Last Updated:** December 31, 2025 **By using AfriBot, you agree to this Privacy Policy.**