Kulawise Privacy Policy

Your health is personal and so is your data.

At Kulawise, we build tools that help people eat better, optimize food spending, and stay consistent with their wellness goals. To make this possible, we collect and use certain personal information. This Privacy Policy explains what we collect, why we collect it, how we process it, and the rights you have under the Nigeria Data Protection Regulation (NDPR) and the Nigeria Data Protection Act (NDPA).

This policy applies to anyone who uses the Kulawise mobile app, website, or interacts with us through channels such as email, Telegram, or customer support.

Our goal is to be clear, honest, and respectful about how we handle your information.

1. Why We Collect Data

We collect and process your data to:

  • Create and personalize your meal and wellness plans
  • Recommend meals based on your pantry, budget, preferences, and goals
  • Track activities such as steps, gym check-ins, challenges, and progress
  • Power AI features (meal generation, grocery suggestions, insights)
  • Improve app performance, fix bugs, and develop new features
  • Maintain security, prevent fraud, and comply with regulations
  • Communicate with you (notifications, reminders, service updates)
  • Process payments if you use subscription features

We only process your data when we have a legal basis, such as:

  • Your consent
  • Performance of a contract (delivering the Kulawise service)
  • Legitimate interest (analytics, feature improvement)
  • Legal obligation

2. What We Collect

Depending on how you use Kulawise, we may collect the following:

Account Information

  • Name
  • Email address
  • Phone number
  • Password (encrypted)

Health & Wellness Information (special/sensitive data collected only with explicit consent)

  • Allergies
  • Dietary restrictions
  • Health conditions (if you choose to share)
  • Weight, height, wellness preferences
  • Fasting activity
  • Sleep duration
  • Steps and exercise entries

Food & Meal Data

  • Pantry items
  • Grocery lists
  • Meal plans
  • Photos uploaded for meal scans

Location Information

  • City, state, or region to provide localized grocery suggestions & pricing
  • We do not collect precise GPS location without explicit permission

Activity & Usage Data

  • Challenges joined
  • Points earned
  • Device information
  • App usage statistics
  • Crash logs and technical diagnostics

Feedback & Communication

  • Support conversations
  • Survey responses
  • Reports or suggestions

We do not collect information that is not needed for your experience.

3. Cookies & Analytics

We use cookies and analytics tools to:

  • Understand how users interact with the app and website
  • Save your preferences
  • Improve performance and user experience

You can disable cookies in your browser at any time.

4. How We Use Your Data

We use your data to:

  • Generate personalized meal plans and insights with AI
  • Suggest affordable meals using pantry items and local prices
  • Track your progress and daily activities
  • Manage points, rewards, and challenges
  • Improve the quality of recommendations
  • Monitor system performance and security
  • Provide customer support
  • Enable payments for subscriptions or credits
  • Enforce our terms and legal obligations

We do not sell your data under any circumstances.

5. Who We Share Data With

We only share your data with vetted and trusted service partners that help us provide the Kulawise service to you uniquely:

Examples include:

  • Cloud hosting providers
  • Payment processors (for premium features)
  • Customer support tools
  • Analytics tools
  • AI model providers (for meal generation and insights)

All partners operate under legally binding Data Processing Agreements (DPAs) and follow strict confidentiality and security standards.

International Transfers

Some partners may process data outside Nigeria (e.g., EU or US cloud providers).

We ensure that such transfers follow NDPR/NDPA requirements, using:

  • Contractual safeguards
  • GDPR-equivalent controls
  • Adequacy decisions where applicable

6. Your Rights & Controls

You have full rights under the NDPR/NDPA, including the right to:

  • View the data we hold about you
  • Update or correct your information
  • Download or request a copy of your data
  • Delete your account and data
  • Withdraw consent at any time (for health data, analytics, AI personalization)
  • Opt out of promotional messages
  • Object to certain types of processing
  • Restrict data processing in certain scenarios

To exercise any of your rights, email us at [email protected].

We will respond within the legally required timeline.

7. Security & Storage

We protect your data using:

  • Encryption (in transit and at rest)
  • Secure cloud hosting
  • Access controls and authentication rules
  • Regular security audits
  • Industry best practices for sensitive data handling
  • No direct storage of payment card details

Data Separation & Architecture

To enhance your privacy and security, we implement a data separation architecture where your health and wellness data is stored separately from your identity information in different database tables. This design ensures that:

  • Your identity (name, email, phone) and health data are isolated in separate, secure database structures
  • Access to health data requires additional authentication and authorization layers
  • Even in the event of a security incident, your identity and health information cannot be easily correlated without proper access credentials
  • Data is linked only through secure, encrypted identifiers that require proper authentication to access

This separation is a fundamental part of our security architecture and helps protect your sensitive health information.

You are also encouraged to use a strong password and keep your login credentials private.

8. Data Retention

We retain your data only for as long as:

  • Your account is active, or
  • We need it to deliver our services, or
  • It is required by law (e.g., fraud prevention, compliance)

Once you delete your account:

  • Most data will be deleted immediately
  • Some data may be retained temporarily if legally required
  • Backups will automatically purge data after their secure retention cycle

9. AI Processing & Automated Decisions

Kulawise uses AI models to:

  • Generate meals
  • Analyze food photos
  • Summarize health patterns
  • Provide grocery suggestions

AI outputs are based on the data you provide.

We do not use AI to make harmful or high-stakes automated decisions.

You may opt out of AI personalization at any time.

10. Updates to This Policy

We may update this Privacy Policy from time to time to reflect:

  • New features
  • Regulatory requirements
  • Security improvements
  • Product changes

If we make significant changes, we will notify you through email or an in-app message.

11. Governing Law

This Privacy Policy is governed by:

  • The Nigeria Data Protection Regulation (NDPR)
  • The Nigeria Data Protection Act (NDPA)
  • Any other applicable Nigerian laws and regulations

Any disputes will be handled under the laws of the Federal Republic of Nigeria.

Last updated: November 2025

If you have questions, contact: [email protected]