Privacy Policy

POP Technologies Ltd. Kampala, Uganda | support@getpopafrica.com\nEffective Date: March 30, 2026

1. INTRODUCTION

POP Technologies Ltd. (“POP,” “we,” “us,” or “our”) is committed to protecting the privacy of every person who interacts with our platform. This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you use the POP platform, including the POP buyer application, POP Vendor application, POP Courier application, and the website located at getpopafrica.com (collectively, the “Platform”). By downloading, accessing, or using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal information as described herein. If you do not agree with this Privacy Policy, you must not use the Platform. This Privacy Policy applies to all users of the Platform, including Buyers, Vendors, and Couriers. It should be read together with our Terms of Service.

2. DEFINITIONS

For the purposes of this Privacy Policy: “Personal Data” means any information that identifies or could reasonably be used to identify you as an individual, directly or indirectly. “Processing” means any operation performed on Personal Data, including collection, storage, use, sharing, transfer, or deletion. “Third Party” means any individual, company, or entity other than you and POP. “User,” “you,” or “your” means any individual who accesses or uses the Platform in any capacity. All other capitalised terms not defined here carry the meanings given to them in POP’s Terms of Service.

3. INFORMATION WE COLLECT

We collect information in three ways: information you provide directly, information collected automatically, and information received from third parties.

3.1 Information You Provide Directly

Account Registration When you create an Account, we collect your full name, phone number, email address, password (stored in encrypted form), and, where applicable, business name and business registration details. Profile Information You may choose to provide additional profile information such as a profile photo, location, and bio. Vendor Information Vendors are required to provide business details, product listings, pricing, images, bank account or mobile money details for payouts, and identity verification documents where required. Courier Information Couriers are required to provide identity documents, vehicle information, and bank account or mobile money details for earnings disbursement. Transaction Information When you place or fulfill an Order, we collect delivery addresses, order details, payment information, and transaction history. Communications When you contact us via email, in-app support, or any other channel, we collect the content of your communications and any information you choose to provide. Live Sales When a Vendor hosts a Live Sale, we collect the video stream and any comments, reactions, or purchases made during the session. Reviews and Ratings Any reviews or ratings you submit on the Platform are collected and associated with your Account.

3.2 Information Collected Automatically

When you use the Platform, we automatically collect: Device Information Device type, operating system and version, unique device identifiers, mobile network information, and hardware model. Usage Data Features you access, pages or screens you view, search queries, time spent on the Platform, tap and scroll interactions, and crash reports. Location Data With your permission, we collect precise GPS location data to enable delivery services, show nearby vendors, and improve location-based features. You may disable location access through your device settings, though this may limit Platform functionality. Network and Log Data IP address, browser type, referring URLs, access times, and diagnostic data. Cookies and Similar Technologies We use cookies and similar tracking technologies on our website to recognise returning users, maintain session state, and analyse usage patterns. You may manage cookie preferences through your browser settings.

3.3 Information from Third Parties

We may receive information about you from third-party sources, including: Mapping and Location Services We integrate with third-party mapping services for location and delivery routing. These services may provide us with information in accordance with their own privacy policies. Payment Processors Our payment partners may share transaction confirmation data with us to facilitate Order processing and reconciliation. Verification Services Where we conduct identity or business verification, we may receive confirmation data from third-party verification providers. AI Service Providers Our AI features, including POP AI and POP Vendor AI, are powered by third-party AI infrastructure. Queries submitted to these features may be processed by third-party AI providers in accordance with their privacy policies.

4. HOW WE USE YOUR INFORMATION

We use the information we collect for the following purposes:

4.1 To Provide and Operate the Platform

Processing Orders, facilitating Transactions between Buyers and Vendors, enabling delivery services, processing payments, managing Accounts, and providing customer support.

4.2 To Personalise Your Experience

Showing relevant product recommendations, tailoring search results, and enabling features of POP AI to assist you in finding products that match your preferences.

4.3 To Enable AI Features

Processing your queries through POP AI and POP Vendor AI to generate relevant responses and improve the accuracy and quality of these features over time.

4.4 To Enable Live Sales

Facilitating real-time video streaming for Live Sale events, enabling viewer interactions, and processing in-stream purchases.

4.5 To Facilitate Delivery

Sharing your delivery address and contact information with the assigned Courier to enable order fulfillment, and using location data to optimise routing and estimated delivery times.

4.6 To Process Payments and Payouts

Verifying payment details, processing charges to Buyers, disbursing earnings to Vendors and Couriers, and maintaining financial records as required by law.

4.7 To Serve Advertising

Displaying personalised and non-personalised advertisements through Google AdMob. Advertising personalisation is based on your usage data and preferences in accordance with Google’s advertising policies and this Privacy Policy.

4.8 To Communicate with You

Sending Order confirmations, delivery updates, account notifications, security alerts, promotional communications (where you have opted in), and responses to your support requests.

4.9 To Ensure Safety and Security

Detecting and preventing fraud, abuse, and unauthorised access; monitoring for violations of our Terms of Service; and protecting the safety of our users and the integrity of the Platform.

4.10 To Comply with Legal Obligations

Retaining and disclosing information as required by applicable law, regulatory authority, or lawful process.

4.11 To Improve the Platform

Analysing usage patterns, conducting research, diagnosing technical problems, and improving the features and performance of the Platform.

5. LEGAL BASIS FOR PROCESSING

Where applicable under data protection law, we rely on the following legal bases for processing your Personal Data: Contractual Necessity: Processing required to provide you with the services you have requested, including facilitating Transactions, processing payments, and enabling delivery. Legitimate Interests: Processing that serves our legitimate business interests, including fraud prevention, security monitoring, product improvement, and marketing to existing users, where these interests are not overridden by your rights. Consent: Processing based on your explicit consent, including location access, personalised advertising, and promotional communications. You may withdraw consent at any time without affecting the lawfulness of processing based on consent before withdrawal. Legal Obligation: Processing required to comply with applicable laws and regulations.

6. HOW WE SHARE YOUR INFORMATION

We do not sell your Personal Data. We share your information only as described below.

6.1 With Other Users

To facilitate Transactions, we share limited information between Buyers, Vendors, and Couriers. For example, a Vendor receives an order with the Buyer’s delivery address and contact information, and a Courier receives delivery details including pickup and drop-off locations.

6.2 With Service Providers

We share information with trusted third-party service providers who assist us in operating the Platform, including providers of cloud infrastructure, mapping and location services, payment processing, live streaming, content delivery, advertising, AI services, and identity verification. All service providers are contractually required to process your information only as instructed by POP and in accordance with applicable privacy laws.

6.3 With Legal and Regulatory Authorities

We may disclose your information to law enforcement agencies, regulatory bodies, or courts where required by applicable law, legal process, or to protect the rights, property, or safety of POP, our users, or the public.

6.4 In Connection with a Business Transfer

In the event of a merger, acquisition, restructuring, or sale of all or substantially all of POP’s assets, your information may be transferred to the acquiring entity. We will notify affected users prior to any such transfer taking effect.

6.5 With Your Consent

We may share your information with third parties in any other circumstances where you have given explicit consent for us to do so.

7. INTERNATIONAL DATA TRANSFERS

POP is headquartered in Kampala, Uganda. Your information may be processed and stored on servers located outside Uganda, operated by POP and its third-party service providers globally. Where your information is transferred outside your country of residence, we take steps to ensure that adequate protections are in place in accordance with applicable law, including relying on standard contractual clauses or equivalent safeguards where required.

8. DATA RETENTION

We retain your Personal Data for as long as your Account is active or as necessary to provide you with the Platform’s services. We also retain data as required to comply with our legal obligations, resolve disputes, enforce agreements, and maintain business records. Upon deletion of your Account, we will delete or anonymise your Personal Data within a reasonable period, subject to the following exceptions: (a) Transaction records and financial data may be retained for up to seven (7) years as required by applicable tax and financial regulations; (b) Data relevant to pending legal claims or investigations will be retained until such matters are resolved; (c) Anonymised or aggregated data from which you cannot be identified may be retained indefinitely for analytical purposes.

9. YOUR RIGHTS AND CHOICES

Subject to applicable law, you have the following rights regarding your Personal Data:

9.1 Access

You have the right to request a copy of the Personal Data we hold about you.

9.2 Correction

You have the right to request correction of any inaccurate or incomplete Personal Data we hold about you. You may update most information directly through your Account settings.

9.3 Deletion

You have the right to request deletion of your Personal Data. You may delete your Account at any time through in-app settings. Note that certain data may be retained as described in Section 8.

9.4 Restriction of Processing

You have the right to request that we restrict processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to our use of it.

9.5 Data Portability

Where technically feasible and required by applicable law, you may request that we provide your Personal Data in a structured, commonly used, machine-readable format.

9.6 Objection

You have the right to object to processing of your Personal Data where we rely on legitimate interests as the legal basis. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.

9.7 Withdrawal of Consent

Where we rely on consent as the legal basis for processing, you may withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

9.8 How to Exercise Your Rights

To exercise any of the above rights, please contact us at support@getpopafrica.com with the subject line “Privacy Request.” We will respond within 30 days of receipt of your request. We may require you to verify your identity before processing your request. 10. CHILDREN’S PRIVACY The Platform is not directed at or intended for use by individuals under the age of 18. We do not knowingly collect Personal Data from minors. If we become aware that we have collected Personal Data from a person under 18 without verifiable parental consent, we will take steps to delete that information promptly. If you believe a minor has provided us with Personal Data, please contact us at support@getpopafrica.com.

11. ADVERTISING AND TRACKING

11.1 Personalised Advertising

The Platform displays advertisements through third-party advertising networks. These networks may use your device identifiers and usage data to serve personalised advertisements. You can opt out of personalised advertising by adjusting your device settings: On Android: Settings > Google > Ads > Opt out of Ads Personalisation On iOS: Settings > Privacy > Tracking, and by disabling “Allow Apps to Request to Track”

11.2 Analytics

We use analytics tools to understand how users interact with the Platform. Analytics data is aggregated and used solely to improve the Platform and does not identify you as an individual.

11.3 Do Not Track

Some browsers transmit “Do Not Track” signals. Our website does not currently alter its data collection practices in response to such signals, but we will review this as standards evolve.

12. SECURITY

We implement industry-standard technical and organisational security measures to protect your Personal Data against unauthorised access, disclosure, alteration, or destruction. These measures include encryption of data in transit and at rest, access controls, secure authentication protocols, and regular security reviews. However, no method of transmission over the internet or electronic storage is completely secure. While we take the protection of your data seriously, we cannot guarantee absolute security. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you in accordance with applicable law. 13. THIRD-PARTY LINKS AND SERVICES The Platform may contain links to third-party websites or integrate with third-party services. This Privacy Policy applies only to the POP Platform. We are not responsible for the privacy practices of any third-party websites or services. We encourage you to review the privacy policies of any third-party services you access through or in connection with the Platform.

14. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will notify you via in-app notification or email at least 14 days before the changes take effect, unless a shorter notice period is required by law. The “Last Updated” date at the top of this document indicates when the most recent revision was made. Your continued use of the Platform after the effective date of any update constitutes your acceptance of the revised Privacy Policy.

15. CONTACT AND COMPLAINTS

If you have any questions, concerns, or complaints about this Privacy Policy or our data practices, please contact us: POP Technologies Ltd. Kampala, Uganda Email: support@getpopafrica.com Website: getpopafrica.com For privacy-related legal matters, correspondence may be directed to the attention of the Chief Strategy Officer. We take all privacy concerns seriously and will respond to your enquiry within 30 days. If you are not satisfied with our response, you may have the right to lodge a complaint with the relevant data protection authority in your jurisdiction. This Privacy Policy was prepared by POP Technologies Ltd. legal personnel and is effective as of the date set forth above.