Applies across Zulra Markets (Nigeria, Australia, United Kingdom, United States, Canada, South Africa, Ghana, Germany, France, and the United Arab Emirates). Same substance as in-app Settings → Legal. This is a product policy for transparency — not a substitute for advice from qualified counsel in each jurisdiction. Contact: hello@getzulra.com
1. Who we are
Zulra is operated by Drewbie Ventures Ltd (RC 7411103, registered in Nigeria) (“we”, “us”) and provides an events, ticketing, messaging, and cash-gifting platform. This Privacy Policy explains how we collect, use, store, share, and protect personal data when you use the Service across: Nigeria, Australia, United Kingdom, United States, Canada, South Africa, Ghana, Germany, France, and the United Arab Emirates. It is designed to align with the Nigeria Data Protection Act 2023 (NDPA) and NDPR, GDPR / UK GDPR, Australia Privacy Act 1988 (APPs), Canada PIPEDA and applicable provincial laws, South Africa POPIA, Ghana Data Protection Act 2012, UAE Federal Decree-Law No. 45/2021 (PDPL), and US state privacy laws including California CCPA/CPRA where they apply. This in-app text is a product privacy disclosure for transparency—not a substitute for advice from qualified counsel in each jurisdiction.
2. Data we collect
Account data: account type (individual or organisation), display name, optional organisation category and legal name, contact person for organisation accounts, optional organisation registration / CAC number and scan (photo or PDF you upload for staff verification), phone number and dial code, email, Market/location choice, profile photo, and authentication artefacts (hashed PIN, device trust tokens, WebAuthn passkeys for getzulra.com when Face ID / Sign in with passkey is used, on native apps with Face ID / biometrics on—encrypted session refresh tokens in the OS Keychain / Keystore for Sign in with Face ID restore, and—on native apps after email/password auth—your email and password remembered in the OS Keychain / Keystore for Sign in with password prefill on that device after Face ID / biometrics; not raw Face ID templates, which remain on-device where the OS provides them). Event & social data: events you create or attend (including Going / Pending / Past), guest lists, follow graph (who you follow and who follows you), digital invites, messages to Zai, and support notes. Messaging data: 1:1 and group-chat content, event live-feed posts (text, photos, and short videos on Zulra host event pages), attachments you send, reply metadata, membership in rooms, invite tokens (e.g. getzulra.com/g/<token>), and read/receipt state when cloud messaging is enabled. Notification data: device push tokens when enabled; transactional notification rows (titles, bodies, read/dismiss state, deep-link targets) stored on our servers so your in-app activity feed can sync across signed-in devices. Payment data: ticket and gift amounts, currency, FX disclosure snapshots, optional gift message you attach at send, payout bank details (account name, number, bank), payment method type, and payment-provider references. We do not store full card PAN or CVV on Zulra servers. Card details you type or Autofill from your device are processed by payment partners (Flutterwave). When Apple Pay is offered — for diaspora Markets (e.g. Australia, United Kingdom, United States), including visits to Nigeria, or after a Nigeria resident leaves Nigeria — we receive tokenised payment references from Apple and our partners, not your full card number. Apple Pay is not offered to Nigeria locals while they stay in Nigeria. Location signals: Residence Market (settings); GPS hub (after permission); Discover explore city (browse-only, not written as GPS). Device & usage: device model, app version, approximate location if you enable it, push tokens when notifications are enabled, interaction analytics when separately enabled, and privacy-minimised crash diagnostics. Current first-party crash diagnostics include error type, app build, platform, route path without query values, and redacted stack/component stack; they exclude session replay, DOM/keystrokes/screenshots, auth tokens, payment references, NUBAN, email, phone, and private message content. We do not use cookies for advertising or tracking on any platform — preferences (theme, session continuity) and short-lived client caches are kept in on-device storage; see §17 for detail. When you are signed in, account, event, social, messaging, notification, and payment records described above are stored on our application servers (Supabase Postgres) and related processors listed in §7 — they are not localStorage-only. On-device storage holds preferences, session continuity helpers, and caches that sync from or mirror the cloud store; it is not a substitute for your server-side account.
3. Why we process data (purposes & legal bases)
We process data to: create and secure accounts (including OTP on a new device, native-app Face ID / device credential / PIN unlock, Keychain-backed Face ID session restore after native sign-out at approximately 24 hours, Keychain-remembered email/password for Sign in with password prefill on native apps, and browser-session protection on ordinary web); set Market and gift currencies; personalise Home discovery (GPS hub content for On Zulra events, Around town, and Stay nearby hotels); sell tickets and process gifts; pay hosts; operate messaging and invite links; send transactional push/email/SMS; prevent fraud, abuse, and money laundering; provide customer support; improve the Service; and meet legal obligations. Legal bases include contract performance, legitimate interests (security, product improvement balanced against your rights), consent (where required for marketing or precise location or push), and legal obligation. Marketing messages require opt-in where mandated (e.g. certain EU/UK/AU rules); you can opt out in Settings → Preferences.
4. Market, GPS & Explore (location model)
Residence Market is determined at signup from phone dial code or an explicit country pick and may be updated in Settings → LOCATION → Home country. It drives your default send currencies (Nigeria: NGN only; other Markets: local send currency and/or NGN as configured) and default hub when GPS is off. After you grant / confirm location permission, the GPS hub appears in the Home location chip and Settings → Near you (GPS); it personalises On Zulra events, Around town, and Stay nearby for that locality and is not cycled by Explore city search. When GPS is confirmed in a catalogued country, Zifts may also offer that country’s local send currency as an extra option — this does not change your Home country or Residence Market. Explore search lets you browse other cities (Nigeria cities for diaspora residence) without changing your GPS hub, Market, or currencies. Hosts receive Naira. FX rates shown before gift confirm (and used for gift charge) come from Flutterwave’s live transfer-rates API; if Flutterwave rates are unavailable we keep retrying and diaspora gifts cannot be confirmed. The rate, spread, and fees disclosed at confirm are locked for that payment and logged with the transaction. Gift fee corridor is based on the currency you send, never GPS alone.
5. Messaging & cloud storage (Supabase)
Message bodies, attachment metadata, membership, read receipts, and invite tokens are stored in our application database (Supabase Postgres) with realtime delivery via Supabase Realtime when messaging is enabled for your account. Event live-feed photos and short videos on Zulra host events stay in that store for 7 days after the event is Past in the app, then we strip those media attachments (captions may remain). Without a Cloudinary destroy credential we cannot guarantee immediate deletion of the underlying CDN file. Display-name colours in group chat are derived client-side from a hash of user id for readability; they are not a separate sensitive data category. You should assume other members of an event live feed can see messages, photos, and videos you send there. Do not share secrets or payment card numbers in chat.
6. Push notifications (OneSignal)
When you enable notifications, we (or our push provider OneSignal) may process a device push token / player id, device type, and coarse app-state needed to deliver alerts. OneSignal delivers via APNs (iOS), FCM (Android), and web push where supported. Push is used for transactional alerts (e.g. new message, someone joined via your group invite, ticket/RSVP updates, live feed opening for Going guests, gift or payout status) and may deep-link into the relevant thread or event page. Settings → Preferences (Notification centre) stores your channel preferences on your account — including Push categories, email alerts, and SMS/WhatsApp preference flags (those SMS/WhatsApp channels are not delivered yet) — plus an optional timezone used to localise reminder copy. When chat push permanently fails and email alerts are on, we may send a short Resend email with a message preview. We also store transactional notification rows on our servers (activity inbox) so your in-app bell feed can sync across devices when signed in; that feed is separate from chat message content. OneSignal is not the system of record for message content — that remains in Supabase (see §5). You can revoke permission in OS settings and limit categories in Settings → Preferences.
7. Sharing & processors
We share data with: payment partners (Flutterwave and Nigerian banking rails for NIP host payouts, initiated via secured server egress where required; Apple or Google only when you choose Apple Pay / Google Pay where offered); cloud hosting and database providers (Supabase, Vercel); push providers (OneSignal); media hosts for event covers, profile photos, gift receipts, and organisation verification scans (Cloudinary); identity and authentication providers (including Supabase Auth and, when you choose them, Google Login and — on iOS and the web — Sign in with Apple; the Android app offers Google Login only); analytics when enabled (planned: PostHog — product analytics, not ads); and professional advisers. Google Login: if you tap Continue with Google, Google authenticates you and provides Zulra with the identifiers and profile fields you authorise (typically name, email, and profile photo). Sign in with Apple: if you tap Continue with Apple (iOS app or web), Apple authenticates you and provides Zulra with the identifiers and profile fields you authorise (typically a private relay email and, on first authorisation when available, a name). We use that data only to create or sign in to your Zulra account and to display your profile. You can revoke Zulra’s access in your Apple or Google account security settings; deleting your Zulra account (see §9) removes the linked Zulra profile independently. We may disclose data to regulators, courts, or law enforcement when legally required. We do not sell personal information for money. Under CCPA/CPRA, “sale”/“sharing” for cross-context behavioural advertising—if ever enabled—will be disclosed with opt-out controls.
8. International transfers
Data may be processed in Nigeria and in other countries where our providers operate. Where we transfer personal data from the EEA/UK/Switzerland or other regions with transfer restrictions, we use appropriate safeguards (such as Standard Contractual Clauses, UK IDTA/Addendum, or adequacy decisions) and conduct transfer risk assessments as required.
9. Retention & how to delete your data
We keep account data while your account is active. To permanently erase your Zulra account and request deletion of your personal data: (1) Sign in at https://getzulra.com → Settings → ACCOUNT → Delete account, or open https://getzulra.com/delete-account and type DELETE; or (2) Email hello@getzulra.com with subject “Delete my Zulra account” and the email on the account. Step-by-step instructions (no sign-in required to read): https://getzulra.com/data-deletion. When erase succeeds, we permanently remove your login and anonymise profile faces; chat memberships and personal attendance linked to your identity are removed with the account. Transaction, payout, and AML-relevant records may be retained for periods required by financial and tax rules (often 5–7+ years depending on Market), with personal identifiers removed where practicable. Hosted event listings may remain with a “Deleted account” host name so guest tickets stay usable. Support chats and device logs are kept for shorter operational periods unless needed for disputes or security. Event live-feed photos are removed from the app 7 days after the event is Past (see §5). On-device data is cleared when erase succeeds. Deletion is subject to legal retention overrides.
10. Security
We apply administrative, technical, and organisational measures including encryption in transit, access controls, and device authentication (Face ID/PIN/OTP). No method of transmission or storage is fully secure. You must protect your devices and codes.
11. Your rights
Depending on your Market, you may have rights to access, correct, delete, restrict, or object to processing; data portability; withdraw consent; and lodge a complaint with a supervisory authority (e.g. Nigeria NDPC, ICO UK, EU DPAs, OAIC Australia, OPC Canada, Information Regulator SA, Ghana DPC, UAE Data Office, California Privacy Protection Agency). You may also have rights to appeal decisions and to non-discrimination for exercising privacy rights (US state laws). Use Settings → Privacy Policy / in-app support to exercise rights. We will verify requests as required by law.
12. Children
The Service is not directed to children under 18 (or higher age of majority). We do not knowingly collect children’s data. If you believe we have, email hello@getzulra.com and we will delete it where required.
13. Automated decisions
We may use automated rules for fraud scoring, sanctions screening, and rate limiting. Significant decisions with legal or similarly significant effects will include human review avenues where required by GDPR Art. 22 and similar laws.
14. Host plans & product analytics
Plan selection (Starter / Event Plus / Host Pro) and privilege unlocks may be stored with your account to enforce guest caps and features such as door scan. Operational metrics for authorised staff derive from live transaction ledgers (tickets, gifts, payouts). First-party sanitised crash diagnostics (error kind, message, route, build, and platform — not your account id, and not session replay) are written to our Vercel runtime logs and an aggregate staff reliability store for troubleshooting; Zulra does not use session replay. If we enable broader product analytics or third-party monitoring (e.g. PostHog or Sentry), we will update this Policy and store nutrition labels before relying on that data.
15. Changes
We may update this Privacy Policy. The effective date appears at the top of the in-app document (Settings → Privacy Policy). Material changes will be highlighted in-app.
16. Contact
Privacy requests: email hello@getzulra.com, or use in-app Zai and mark the message PRIVACY. Supervisory authorities in your Market remain available for complaints if we cannot resolve your concern.
17. No advertising cookies — on-device storage
Zulra does not use advertising, tracking, or cross-site cookies on any platform. Preferences (theme, a chat wallpaper you pick from Photos, session continuity) and short-lived client caches are kept in on-device storage: the mobile apps (iOS/Android, via Capacitor) store them in WebView / secure on-device storage, and ordinary web uses browser storage scoped to your device only — localStorage for small preferences and IndexedDB for a time-limited public Home event snapshot that can reopen while offline. A custom chat wallpaper stays on this device for that chat and is not uploaded to our servers or shown to the other person. We do not move payment details, NUBAN, private chat bodies, PINs, or authentication credentials into that public offline snapshot. Signed-in account, chat, event, and payment data live on our servers as described in §2 and §5; on-device copies are caches, not the sole copy. If we add product analytics (e.g. PostHog), it will be disclosed here first and will not use tracking cookies.