1. About this policy

1.1 This policy explains how [BELENGA] ("Belenga", "we", "us"), collects and uses personal data when you use the Belenga platform at [www.belenga.com].

1.2 We are the data controller for that personal data.

1.3 We process personal data in accordance with the Data Protection Act No. 3 of 2021.

2. What we collect

2.1 Information you give us

(a) All users: your name, email address, mobile number and password (which we store only in encrypted form).

(b) Authors additionally: your mobile money number and network, your Taxpayer Identification Number (TPIN), your National Registration Card or passport number, your biography and photograph and the details of the works you submit.

(c) Anything you send us in support messages, and any reviews you write.

2.2 Information created when you use the Platform

(a) Your purchase history and order references.

(b) Your reading activity — which Titles and Samples you open, your reading position within them, when you read, for how long, and on which device. We collect this so that we can provide Reading Access, sync your progress across your devices, and report aggregate figures to Authors.

(c) Your withdrawal requests and payout history, if you are an Author.

2.3 Technical information

(a) Your IP address, device type, operating system, browser and the approximate location derived from your IP address.

2.4 Payment information

(a) WE DO NOT COLLECT OR STORE YOUR CARD DETAILS. Payments are processed by payment gateways. We receive only a confirmation of payment and a transaction reference.

3. Why we use personal data, and our lawful basis

We use personal data for the purposes set out below. The lawful basis for each is stated.

(a) To create and manage your account — your identity and contact details. Basis: performance of our contract with you.

(b) To process purchases and provide Reading Access — your purchase and reading data. Basis: performance of our contract with you.

(c) To sync your reading progress across devices — your reading activity. Basis: performance of our contract with you.

(d) To pay Authors — mobile money details, TPIN. Basis: performance of our contract with the Author, and legal obligation for tax records.

(e) To report aggregate sales and reading figures to Authors — reading activity, aggregated and stripped of identity. Basis: our legitimate interests in operating a marketplace, and the Author's legitimate interest in understanding their sales.

(f) To prevent fraud, unauthorised copying and abuse — technical and activity data. Basis: our legitimate interests.

(g) To send you marketing about Belenga — your contact details. Basis: your consent, which you may withdraw at any time.

(h) To comply with tax and other legal obligations — transaction records. Basis: legal obligation.

4. Who we share personal data with

4.1 We share personal data with the following categories of recipient:

(a) Payment Gateway — to process payments from Readers and payouts to Authors.

(b) Bulk Marketing Platforms — to send transactional and marketing email.

(c) HOSTING PROVIDER — to host the Platform.

(d) STORAGE / CDN PROVIDER — to store and deliver Title files.

(e) Authors — aggregate sales and reading figures only. WE DO NOT DISCLOSE THE IDENTITY OF INDIVIDUAL READERS TO AUTHORS. Authors see numbers, not names.

(f) Our professional advisers, including accountants and lawyers, where necessary.

(g) Law enforcement, regulators or courts where we are required by law to do so.

(h) A buyer, if the business is sold or transferred.

4.2 WE DO NOT SELL PERSONAL DATA.

5. How long we keep personal data

5.1 Account data: for as long as your account is open.

5.2 Purchase records: for as long as you retain reading access to the Title for tax and accounting purposes.

5.3 Reading activity: for as long as your account is open.

5.4 Where an Author withdraws a Title, we delist it but retain the file, because readers who bought it before withdrawal keep their reading access and we must be able to continue serving it to them.

5.6 Tax and accounting records: as required by the Zambia Revenue Authority.

6. Your rights

6.1 Under the Data Protection Act 2021 you have the right to ask us to:

(a) give you a copy of the personal data we hold about you;

(b) correct personal data that is inaccurate or incomplete;

(c) delete your personal data;

(d) restrict or object to how we use it;

(e) transfer it to another provider;

(f) withdraw consent, where we rely on consent.

6.2 Some limits apply. In particular:

(a) If you ask us to delete your account, you will lose reading access to every Title you have bought, and we will not refund you.

(b) We may need to keep some records after deletion to comply with tax law or to defend a legal claim.

6.3 To exercise any right, contact support@belenga.com. We will respond within 7 days.

7. How we protect personal data

7.1 We use encryption in transit, store passwords only in hashed form, restrict staff access to what is necessary, hold Title files in private storage that is not publicly accessible, and do not store card details.

7.2 No system is completely secure. We cannot guarantee absolute security, but we take the measures we consider appropriate to the risk.

7.3 If a data breach occurs that is likely to affect you, we will notify you and the Data Protection Commissioner as required by the Act.

8. Children

8.1 The Platform is intended for people aged 18 and over. A person under 18 may use it only with the consent and supervision of a parent or guardian.

8.2 We do not knowingly collect personal data from children without that consent.

9. Cookies

9.1 We use cookies that are strictly necessary to operate the Platform and keep you signed in.

10. Changes to this policy

10.1 We may update this policy. We will post the updated version at www.belenga.com and, where the change is significant, tell you by email.