Privacy Policy

Kwa-Heri by Zelora ("Kwa-Heri", "we", "our") is a funeral-coordination and digital-remembrance platform operated by Zalen Ltd, Kenya in Kenya. This policy applies to people who create or administer memorials, invited family collaborators, tribute authors, contributors, visitors, people contacting our team, and people whose personal information is included in memorial content.

It covers Funeral Announcements, Digital Eulogies, Anniversary Remembrance, Communal Memorials, the family dashboard and associated features that are actually available to users. Some features are optional or limited to particular plans.

We determine how information is used to provide and secure Kwa-Heri. Families and administrators also make decisions about the content they choose to submit or publish, and they must respect the privacy and rights of people mentioned in that content. Our precise legal roles for particular processing activities will depend on the service and the applicable law.

We collect only information needed for the relevant feature or a legitimate operational purpose. Depending on how you use Kwa-Heri, this may include:

Account and collaboration details. Your name, email, phone number, sign-in method, password credentials in protected form, account settings, invitation records and collaborator permissions. If you sign in through Google or Facebook, we receive the information permitted by that login service and your choices.

Memorial content. The deceased person's name, photograph, dates, announcement, biography, service and burial details, locations, family contacts, order of service, hymns, readings, tributes, pictures, videos, farewell memories and anniversary reflections provided by users. Some content may reveal beliefs, relationships, health information or details about living individuals; please share sensitive information only when necessary and appropriate.

Contributions and transactions. Where supported, names or display names, payment contact details, amounts, transaction references, payment status, memorial identifiers, contribution preferences, fees, payout information and information needed to resolve payment issues. We do not ask for your M-PESA PIN or store complete payment-card details.

Messages and support. Contact-form submissions, support emails, WhatsApp correspondence and information you choose to share when requesting help. Verification documents may be requested where necessary to investigate impersonation, fraud, disputed authority or a payment issue.

Technical information. Basic device, browser and connection information, IP address, login and security logs, error reports, and usage information. Any optional analytics, advertising technologies or third-party embeds must follow the choices and notice described in Section 7.

We process information to create and host memorials; communicate funeral details and updates; support authorized collaboration and moderation; display approved tributes and memories; handle payments and contribution records when enabled; answer support requests; protect accounts and prevent fraud; maintain the service; meet legal and accounting obligations; and improve the experience in ways permitted by law.

We rely on the appropriate lawful basis for each activity under applicable data protection law. These may include providing a service you request, complying with the law, consent where required, and legitimate interests that do not override people's rights. Consent for optional marketing or promotional use is separate from using Kwa-Heri. Withdrawing consent does not necessarily undo lawful processing that took place before withdrawal.

A memorial owner or authorized administrator selects the available visibility settings:

• Public: accessible publicly and eligible for discovery through Kwa-Heri's public directory or search engines, where enabled.

• Link-only: not intended for public directory discovery, but accessible to anyone who has the link; forwarding the link may widen access.

• Password-protected / restricted: requires the configured access step. Anyone granted access can still copy information or capture screenshots.

Families should check memorial content before publishing, especially telephone numbers, exact addresses, children’s photographs, financial details and sensitive family information. When privacy settings change, information already copied, indexed or shared by others may remain outside Kwa- Heri's control. We will apply available technical controls to limit further exposure where reasonably possible.

Memorials may mention or show people who are still alive. If you are creating or editing a memorial, please ensure that you have an appropriate basis or permission to publish their personal information, photographs and contact details. Share only what is necessary for the family’s purpose.

Extra care is required for children's information and images and for information revealing health, religion, family relationships or other sensitive details. Obtain appropriate parental or guardian authorization where required. A memorial about a deceased person can still contain protected information about living relatives and other people.

To raise a concern about information about you or a child in your care, contact us. We may need to contact the memorial administrator, restrict content while reviewing a complaint, or request reasonable proof of identity or authority.

A submitted tribute may include the author's name, relationship and message. The family decides whether tributes require approval before publication, where that control is enabled. Administrators can moderate the memorial according to their permissions.

Authorized collaborators may see or edit the memorial sections associated with their assigned roles. Memorial owners should invite only trusted people and review access when roles change.

Contribution information is shown to the family and other viewers according to the feature's settings and the disclosures presented when someone contributes. Do not assume that a contributor's name, amount or message will be public. Any public recognition should be explained at the point of contribution, with an anonymous or private option where offered. Sensitive transaction and payout details must not be shown on public memorial pages.

Necessary technologies may be used to keep you signed in, secure the website, remember your settings and complete transactions. If we use optional analytics, marketing cookies or pixels that require consent, we will provide the required notice and choice before they are activated. Browser controls may also be available, but they are not a substitute for a consent mechanism where one is required.

A Digital Eulogy may include a YouTube livestream link supplied by the family or its media team. Opening or playing embedded content may involve a third-party service and its privacy practices. Wherever practicable, give visitors a clear choice before loading nonessential third-party content.

We may share information with service providers only as needed for their work, including hosting and database providers, authentication services, payment and mobile-money partners, email or messaging providers, security tools, customer support providers and suppliers involved in optional services that a family requests. They should be subject to appropriate contractual and security protections.

Information may also be shared with authorized memorial collaborators, the relevant family or recipient of a contribution, and third parties to whom a visitor chooses to send a memorial link. We may disclose information where lawfully required, or where necessary and proportionate to investigate fraud, protect users or respond to legal proceedings.

We do not sell personal information to data brokers. If we introduce sponsored vendor listings, they will be identified appropriately; a listing does not give a vendor access to private memorial or contribution data.

Making a memorial public does not automatically give Kwa-Heri permission to use its photographs, names, family messages or tributes in advertisements, promotional posts, investor materials or case studies. We will seek separate, appropriate permission from the people who have the necessary rights before identifiable memorial content is used for those purposes.

Families may ask us to stop future promotional use of content for which they have given permission. A previously shared item may remain in third-party caches or material we cannot reasonably retrieve, but we will address material under our control as required by law and any permission terms.

We may demonstrate the product with clearly labelled sample content that we have permission to use.

Relatives and friends may access Kwa-Heri from outside Kenya. Our service providers may also process information in other countries. Where a transfer outside Kenya occurs, we will use the safeguards or other conditions required by applicable data protection law. Before publication, confirm actual hosting countries and provider arrangements and describe them accurately.

We keep information for as long as it is needed for the purpose for which it was collected, to provide the memorial's disclosed access arrangement, or to satisfy legal, accounting, security and dispute requirements.

A memorial may remain viewable after its paid editing period ends, as described in the applicable package and Terms. Read-only access does not mean that we guarantee hosting forever. The family may be able to request deletion, change visibility or export content where those features are offered. Necessary transaction records may be retained separately after a memorial is removed.

We use appropriate technical and organizational measures designed to protect information, including access controls, authentication, encrypted connections and restricted administrative access. We review access when necessary for support, security, fraud prevention or compliance. No online service can promise absolute security. Please protect your login credentials, OTPs, devices and mobile-money PIN.

If we become aware of a personal-data breach, we will investigate and make any notifications required by applicable law.

Subject to applicable law, you may have rights to be informed about processing, access personal data, object to processing, seek correction or deletion of inaccurate or misleading information, and exercise other rights provided by law, including withdrawing consent where processing is based on consent.

Write to support@myzelora.com with a description of your request and, if relevant, the memorial link. We may ask for reasonable verification before disclosing or changing information. We will explain any lawful reason we cannot meet a request in full.

You may also raise a complaint with Kenya's Office of the Data Protection Commissioner (ODPC): https://www.odpc.go.ke/.

We may update this policy to reflect changes to Kwa-Heri, our providers or legal requirements. We will show the date of the new version and give appropriate notice of material changes. Where a new use of information requires consent, we will ask for it rather than treating continued use as consent.

For privacy questions, content concerns, requests about your information or support, contact support@myzelora.com or use the Contact Kwa-Heri page. Registered entity and service address: support@myzelora.com