KONVOS PRIVACY POLICY Effective Date: 1st May 2026 FYNZIN TECH respects your privacy and is committed to protecting your personal data in compliance with the Kenya Data Protection Act, 2019 and the Data Protection (General) Regulations, 2021. 1. WHO WE ARE Konvos is operated by FYNZIN TECH, a data controller responsible for the personal data you provide when using this platform. Contact: feedkeical@gmail.com 2. DATA WE COLLECT When you use Konvos, we may collect: Account data: - Name, username, email address, year of birth, gender - Profile picture you upload Content data: - Messages and media you post in public Konvos - Private messages sent through your Inbox - Reactions and interactions with other users' content Usage data: - Konvos you join, create, or interact with - Notification preferences and mute settings - Trending topics you engage with Technical data: - Device model and operating system - Firebase Cloud Messaging (FCM) token for push notifications - IP address and log data for security purposes 3. HOW WE USE YOUR DATA We use your data to: - Create and manage your account - Enable participation in public Konvos and private messaging - Deliver push notifications including trending Konvo alerts - Calculate trending scores to surface popular conversations - Enforce our Community Guidelines and Terms of Use - Investigate reports of abuse or policy violations - Improve platform features and user experience - Comply with legal obligations under Kenyan law 4. LEGAL BASIS FOR PROCESSING Under the Kenya Data Protection Act, 2019, we process your data on the following bases: - Performance of a contract — to provide the services you signed up for - Legitimate interests — to maintain platform safety, prevent abuse, and improve features - Legal obligation — to comply with applicable Kenyan laws - Consent — for optional features such as push notifications (you may withdraw consent at any time) 5. PUBLIC KONVOS AND VISIBILITY When you post in a public Konvo, your message, username, and profile picture are visible to all members of that Konvo. Trending Konvos may be seen by a wider audience as the platform surfaces them to more users. Do not share sensitive personal information in public conversations. 6. PUSH NOTIFICATIONS We use Firebase Cloud Messaging (FCM), operated by Google, to deliver push notifications. Your FCM token is stored securely and used only to deliver notifications relevant to your activity, such as replies to your comments, reactions, and trending Konvo alerts. You can disable notifications at any time in your device or app settings. 7. DATA SHARING We do NOT sell your personal data. We may share data with: - Service providers — Our hosting Cloud, Firebase (Google) for push notifications, and analytics tools that help us run the platform. These providers are bound by data processing agreements. - Legal authorities — where required by Kenyan law, court order, or to protect the safety of our users - Third parties — only with your explicit consent 8. DATA STORAGE AND SECURITY Your data is stored on secure servers. We implement reasonable technical and organisational measures to protect it against unauthorised access, loss, or disclosure. However, no system is completely secure and we cannot guarantee absolute security. 9. YOUR RIGHTS UNDER KENYAN LAW Under the Kenya Data Protection Act, 2019, you have the right to: - Access — request a copy of the personal data we hold about you - Correction — request that inaccurate data be corrected - Deletion — request that your data be deleted (subject to legal retention requirements) - Restriction — request that we limit how we use your data - Objection — object to processing based on legitimate interests - Data portability — receive your data in a structured, commonly used format - Withdraw consent — for any processing based on consent, at any time To exercise any of these rights, contact us at feedkeical@gmail.com. We will respond within 21 days. 10. DATA RETENTION We retain your data for as long as your account is active. If you delete your account, we remove your personal data within 14 days, except where retention is required by law (e.g. for fraud prevention or legal compliance). Public Konvo content may be retained in anonymised form for platform integrity purposes. 11. CHILDREN Konvos is not intended for users under the age of 13. We do not knowingly collect data from children under 13. If you believe a child under 13 has created an account, contact us at feedkeical@gmail.com and we will delete the account promptly. 12. CHANGES TO THIS POLICY We may update this Privacy Policy to reflect changes in our practices or legal requirements. We will notify you of significant changes via the app. Continued use of Konvos after updates means you accept the revised policy. 13. CONTACT AND COMPLAINTS FYNZIN TECH Email: feedkeical@gmail.com If you are unsatisfied with how we handle your data, you have the right to lodge a complaint with the Office of the Data Protection Commissioner (ODPC) of Kenya at www.odpc.go.ke.