🛡️ Privacy Policy — Medueti

Last updated: November 25, 2025

Table of Contents

1. Introduction
2. Data Controller Identity
3. Data We Collect
4. How We Use Your Data
5. Legal Basis for Processing (GDPR)
6. Data Sharing and Third-Party Services
7. Advertising and Personalization
8. Device Permissions
9. Cookies and Tracking Technologies
10. Data Security
11. Data Retention
12. Your Rights
13. International Data Transfers
14. Children's Privacy
15. User-Generated Content
16. Account Verification
17. Payment Processing
18. California Privacy Rights (CCPA)
19. Changes to This Policy
20. Contact Us

1. Introduction

Welcome to Medueti, the super-app connecting the African diaspora worldwide through a rich social network featuring communities, marketplace (Afroshop), money transfers, events, local services, shipping logistics, and more.

The protection of your personal data is our priority. This Privacy Policy explains how we collect, use, store, share, and protect your information when you use the Medueti application ("the App") on mobile devices or web platforms.

By downloading, installing, or using Medueti, you acknowledge that you have read and understood this Privacy Policy and agree to the practices described herein.

If you do not agree with this policy, please do not use our services.

2. Data Controller Identity

For any privacy-related inquiries, including exercising your data protection rights, please contact us at privacy@medueti.com.

3. Data We Collect

Medueti collects data necessary to provide and improve our services. We collect information in the following categories:

3.1 Account Registration Data

When you create an account, we collect:

3.2 Profile Information

3.3 User-Generated Content

3.4 Transaction & Financial Data

⚠️ Important: We do not store credit/debit card numbers. All payment card data is processed securely by our payment provider, Stripe.

3.5 Device & Technical Data

3.6 Location Data

📍 Location data is collected only when you grant permission and can be disabled at any time in your device settings.

3.7 Usage & Analytics Data

3.8 Communication Data

4. How We Use Your Data

We use collected data for the following purposes:

4.1 Service Provision

• Create and manage your user account
• Provide social networking features (feed, profiles, following)
• Enable messaging and real-time communication
• Operate the marketplace (products & services)
• Process event creation and ticketing
• Manage shipping and logistics services
• Provide portfolio and gallery features

4.2 Personalization

• Recommend content, services, and events based on your interests
• Display localized content based on your location
• Customize your feed based on your interactions
• Provide relevant search results using machine learning

4.3 Transactions & Payments

• Process purchases and subscriptions
• Manage event credits and virtual currency
• Handle refunds and disputes
• Generate invoices and receipts

4.4 Communications

• Send transactional notifications (orders, bookings, messages)
• Deliver push notifications for interactions (likes, comments, follows)
• Send security alerts and account notifications
• Provide customer support
• Send marketing communications (with your consent)

4.5 Safety & Security

• Verify user identities
• Detect and prevent fraud
• Enforce our Terms of Service
• Protect against unauthorized access
• Monitor for abuse and policy violations

4.6 Analytics & Improvement

• Analyze app usage to improve features
• Conduct research and development
• Monitor app performance and stability
• Debug and fix issues

4.7 Advertising

• Display advertisements within the app
• Measure ad performance
• Provide personalized ads (with your consent)

4.8 Legal Compliance

• Comply with applicable laws and regulations
• Respond to legal requests and court orders
• Enforce our legal rights

5. Legal Basis for Processing (GDPR)

For users in the European Economic Area (EEA), United Kingdom, and Switzerland, we process personal data under the following legal bases:

You may withdraw consent at any time by adjusting your settings or contacting us.

6. Data Sharing and Third-Party Services

We do not sell your personal data. We share information only in the following circumstances:

6.1 Service Infrastructure Providers

6.2 Analytics Providers

6.3 Payment Processors

6.4 Authentication Providers

6.5 Advertising Partners

6.6 Location Services

6.7 Machine Learning Services

⚠️ Note: ML Kit image processing occurs on-device and images are not sent to Google servers.

6.8 Other Sharing Circumstances

• Legal Requirements: We may disclose data to comply with applicable laws, legal processes, or governmental requests.
• Safety & Security: To protect against fraud, security threats, or protect rights and safety.
• Business Transfers: In case of merger, acquisition, or sale of assets, user data may be transferred (you will be notified).
• With Your Consent: When you explicitly authorize sharing.

7. Advertising and Personalization

7.1 Google AdMob

Medueti displays advertisements through Google AdMob. AdMob may collect and use:

• Device advertising identifier (IDFA on iOS, GAID on Android)
• IP address (for approximate location)
• Ad interaction data (impressions, clicks)
• Device information (type, OS, language)

7.2 Ad Personalization

By default, you may see personalized ads based on your interests and activity. You can choose to receive non-personalized ads by:

1. Adjusting your device advertising settings
2. iOS: Settings → Privacy → Tracking → Disable "Allow Apps to Request to Track"
3. Android: Settings → Google → Ads → Opt out of Ads Personalization

7.3 iOS App Tracking Transparency (ATT)

On iOS 14.5+, we will request your permission before tracking your activity across other apps and websites for advertising purposes. You can change this setting at any time in your device settings.

7.4 SKAdNetwork (iOS)

For iOS, we work with the following SKAdNetwork partners for ad attribution:

These networks receive limited attribution data to measure ad campaign effectiveness.

7.5 Premium Users

Users with Premium, Pro, or Business subscriptions may enjoy an ad-free experience based on their subscription tier and our current policies.

8. Device Permissions

Medueti requests the following device permissions to enable specific features:

8.1 Android Permissions

8.2 iOS Permissions

📱 All optional permissions can be denied without blocking basic access to the app. You can modify permissions at any time in your device settings.

9. Cookies and Tracking Technologies

9.1 Mobile App

The Medueti mobile app uses:

• Firebase Analytics: Collects anonymized usage data using device identifiers
• Firebase Remote Config: Stores feature flags and A/B test assignments
• Local Storage: Stores user preferences, cached data, and authentication tokens

9.2 Web Platform

Our website may use:

• Essential cookies: Required for basic functionality
• Analytics cookies: Google Analytics for website traffic analysis
• Preference cookies: Remember your settings and preferences

9.3 Managing Cookies

• Mobile: Adjust tracking settings in your device privacy settings
• Web: Use your browser settings to manage or delete cookies
• Analytics Opt-Out: Disable Firebase Analytics in app settings (when available)

10. Data Security

We implement comprehensive security measures to protect your data:

10.1 Technical Measures

10.2 Access Controls

• Restricted access to personal data (need-to-know basis)
• Multi-factor authentication for administrative access
• Regular security audits and penetration testing
• Employee security training and confidentiality agreements

10.3 Biometric Authentication

Medueti supports biometric authentication (Face ID, Touch ID, fingerprint) as an optional security feature. Biometric data is:

• Processed and stored only on your device
• Never transmitted to Medueti servers
• Used solely for local authentication

10.4 Data Breach Response

In the event of a data breach affecting your personal data, we will:

• Notify affected users within 72 hours as required by GDPR
• Notify relevant supervisory authorities
• Take immediate steps to mitigate the breach
• Provide guidance on protective measures

11. Data Retention

We retain personal data only as long as necessary for the purposes described:

11.1 Automatic Data Cleanup

• Expired notifications: Deleted after 7 days
• Typing indicators: Cleaned via scheduled process
• Invalid FCM tokens: Automatically removed
• Deleted messages: Hard-deleted after 30-day retention period

12. Your Rights

12.1 Rights Under GDPR (EEA/UK/Switzerland)

12.2 How to Exercise Your Rights

In-App Options:

1. Data Export: Settings → Privacy → Export My Data
2. Account Deletion: Settings → Account → Delete Account
3. Notification Preferences: Settings → Notifications
4. Ad Personalization: Settings → Privacy → Ad Settings

Contact Us:

• Email: privacy@medueti.com
• Response time: Within 30 days

12.3 Account Deletion

When you delete your account:

1. Your data enters a 30-day grace period (account recovery possible)
2. After 30 days, all personal data is permanently deleted or anonymized
3. Certain data may be retained for legal compliance (e.g., transaction records)

13. International Data Transfers

Your data may be processed in countries outside your residence:

We ensure all international transfers comply with GDPR through:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Adequacy decisions where applicable
• Additional safeguards as required

14. Children's Privacy

Medueti is intended for users aged 18 and over.

• We do not knowingly collect data from children under 18
• If we discover a minor's account, it will be immediately deleted
• Parents/guardians who believe their child has provided data should contact us at privacy@medueti.com

15. User-Generated Content

15.1 Content Moderation

Users may publish text, photos, videos, comments, and listings. Medueti reserves the right to remove content that is:

• Contrary to applicable laws
• Hateful, discriminatory, violent, or pornographic
• Violating the privacy or intellectual property of others
• Spam, scams, or fraudulent
• Otherwise violating our Terms of Service

15.2 Reporting System

• In-app reporting for inappropriate content
• Human moderation review
• Appeals process available

15.3 Public vs. Private Content

• Public content (posts, listings, profiles) may be visible to other users
• Private messages are encrypted and only visible to participants
• Adjust your profile visibility in Settings → Privacy

16. Account Verification

16.1 Business Verification

Business accounts may submit verification documents:

16.2 Document Handling

• Documents reviewed by authorized personnel only
• Stored securely with encryption
• Deleted after verification (or retained if required by law)
• Not shared with third parties

17. Payment Processing

17.1 Stripe Payments

Credit/debit card payments are processed by Stripe:

• Card numbers are never stored on Medueti servers
• Stripe is PCI DSS Level 1 compliant
• We receive only transaction confirmation and last 4 digits of card

17.2 In-App Purchases

17.3 Subscription Types

• Business Subscription: Monthly/yearly
• Shop Feature: Monthly
• Services Feature: Monthly
• Event Credits: Consumable (virtual currency)

Manage subscriptions through your device's app store settings.

18. California Privacy Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

18.1 Your CCPA Rights

18.2 Categories of Personal Information Collected

(Under CCPA categories)

• Identifiers: Name, email, phone number, IP address, device ID
• Personal Information: Account information, payment history
• Commercial Information: Purchase history, transaction records
• Internet Activity: Browsing history, search history, interaction data
• Geolocation Data: Location information (with permission)
• Sensory Data: Photos, videos, audio uploaded by user
• Inferences: Preferences, characteristics, behavior patterns

18.3 "Sale" of Personal Information

We do not sell your personal information in the traditional sense. However, sharing data with advertising partners may constitute a "sale" under CCPA. You can opt out of this by:

• Disabling ad personalization in your device settings
• Contacting us at privacy@medueti.com

18.4 Exercising Your CCPA Rights

Contact us at privacy@medueti.com with subject line "CCPA Request"

We will verify your identity before processing requests.

19. Changes to This Policy

• Medueti may update this Privacy Policy to reflect changes in our practices, legal requirements, or features
• The "Last updated" date at the top indicates the most recent revision
• Material changes will be notified via:
  • In-app notification
  • Email to registered users
  • Prominent notice in the app
• Continued use after changes constitutes acceptance

We recommend reviewing this policy periodically.

20. Contact Us

For any questions, concerns, or requests regarding this Privacy Policy or your personal data:

Summary of Key Points

✅ We collect registration data, profile info, content you create, usage analytics, and technical data
✅ We use your data to provide services, personalize experience, process payments, and display ads
✅ We share data with service providers (Firebase, Stripe, AdMob) but never sell your data
✅ You control your data through privacy settings, data export, and account deletion
✅ We protect your data with encryption, secure infrastructure, and strict access controls
✅ Your rights include access, deletion, portability, and objection (GDPR/CCPA)
✅ Messages are encrypted end-to-end for your privacy
✅ Ads can be personalized or not — your choice

This Privacy Policy was last updated on November 25, 2025.

🌍 Medueti — Connecting the African Diaspora Worldwide