PRIVACY POLICY

Effective Date: 22 February 2026

Trulib Ltd ("we," "us," or "our") operates the Kwanya mobile application ("App"). This Privacy Policy explains how we collect, use, store, and protect your personal data when you use our App.

By using Kwanya, you agree to the practices described in this Privacy Policy.

1. INFORMATION WE COLLECT

a) Information You Provide:
• Phone number or email address (for account registration)
• One-Time Passwords (OTPs) for verification
• Text messages and voice recordings submitted during conversations
• Payment information processed through Monnify

b) Information Collected Automatically:
• Device type and operating system
• App usage data (e.g., session frequency, features used)
• Unique device identifiers
• Conversation metadata (timestamps, message counts)

c) Information from Third Parties:
• Payment confirmation data from Monnify
• Verification status from Termii (SMS/Email OTP provider)

2. HOW WE USE YOUR INFORMATION

We use your data to:
• Provide and improve AI-powered conversational services
• Verify your identity during registration and login
• Process credit purchases and manage your account balance
• Monitor usage for billing (credit deductions per message/voice input)
• Improve the quality and accuracy of our AI responses
• Ensure security and prevent fraud or abuse
• Comply with legal obligations

3. AI DATA PROCESSING

• Your text and voice inputs are sent to third-party AI models (e.g., Google Gemini) for generating responses.
• Voice inputs are processed using automatic speech recognition (ASR) to convert speech to text before being sent to the AI model.
• We may retain conversation history to maintain context within a session. Context is limited to the most recent messages per conversation.
• We do not use your personal conversations to train AI models.

4. DATA SHARING

We do not sell your personal data. We may share your data with:
• AI Service Providers (e.g., Google) — to process your queries
• Payment Processors (e.g., Monnify) — to handle transactions
• Communication Providers (e.g., Termii) — to send OTPs
• Law Enforcement — if required by law or to protect rights and safety

All third-party providers are bound by their own privacy policies and data protection obligations.

5. DATA RETENTION

• Account data: Retained as long as your account is active
• Conversation history: Stored to maintain context; may be deleted upon account deletion
• Payment records: Retained as required by financial regulations
• OTP data: Deleted immediately after verification

You may request deletion of your data by contacting us (see Section 11).

6. DATA SECURITY

We implement reasonable technical and organizational measures to protect your data, including:
• Encrypted data transmission (HTTPS/TLS)
• Secure storage of credentials and tokens
• Access controls on backend systems
• Regular security reviews

However, no system is completely secure, and we cannot guarantee absolute protection.

7. CHILDREN'S PRIVACY

Kwanya is not intended for children under the age of 13. We do not knowingly collect personal data from children under 13. If we discover such data has been collected, we will delete it promptly. Users between 13 and 18 must have parental or guardian consent.

8. YOUR RIGHTS

Depending on your jurisdiction, you may have the right to:
• Access the personal data we hold about you
• Request correction of inaccurate data
• Request deletion of your data
• Withdraw consent for data processing
• Object to certain types of data processing
• Request data portability

To exercise any of these rights, contact us at the details in Section 11.

9. COOKIES AND TRACKING

The Kwanya App does not use browser cookies. We may use local storage (e.g., AsyncStorage) on your device to maintain session data and preferences. This data remains on your device and is not transmitted to external tracking services.

10. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. Any changes will be posted within the App, and your continued use constitutes acceptance of the updated policy. We encourage you to review this policy periodically.

11. CONTACT US

If you have questions, concerns, or requests regarding your privacy, please contact:

Trulib Ltd
Email: privacy@trulib.com

12. GOVERNING LAW

This Privacy Policy is governed by the laws of the Federal Republic of Nigeria, including the Nigeria Data Protection Regulation (NDPR) and any successor legislation.