Privacy Policy

Effective Date: 19 March 2026

This Privacy Policy applies to Funmerce, a short-form shoppable video platform owned, operated, and maintained by Gasobu Technologies Uganda Limited.

1. Introduction

This Privacy Policy explains how Funmerce collects, receives, records, organizes, stores, uses, analyzes, shares, transfers, discloses, secures, retains, and otherwise processes personal data and related information in connection with the Funmerce platform, including its websites, mobile experiences, applications, video feeds, product pages, seller storefronts, deep links, communication features, commerce tools, recommendation systems, trust and safety workflows, and any related services, features, releases, beta functions, or integrations made available now or in the future. Funmerce combines social content functionality, digital discovery, and commerce enablement. As a result, the categories of data processed and the reasons for processing are broader than those of a standard content platform or a conventional marketplace operating alone.

By accessing or using Funmerce, creating an account, uploading content, opening or sharing a deep link, viewing videos, following a creator, browsing products, opening a store, communicating with another user, or completing a transaction through the platform, you acknowledge that your information may be processed in accordance with this Privacy Policy and applicable law. If you do not agree with this Privacy Policy, you must refrain from using Funmerce.

2. Company Identity and Legal Ownership

Funmerce is owned, operated, and maintained by Gasobu Technologies Uganda Limited, a company organized and existing under the laws of Uganda. Gasobu Technologies Uganda Limited is responsible for the administration, governance, ongoing development, security oversight, and operational maintenance of the Funmerce platform. References in this Privacy Policy to "Funmerce," "we," "us," or "our" mean Funmerce and, where the context requires, Gasobu Technologies Uganda Limited and its affiliates, successors, assigns, contractors, service providers, and authorized operators acting in connection with the provision of the platform.

Where required by applicable law, Gasobu Technologies Uganda Limited acts as a controller, business, or equivalent primary decision-maker in relation to personal data processed for platform administration, trust and safety, analytics, personalization, legal compliance, commerce operations, fraud prevention, and service improvement. In some circumstances, independent sellers, payment partners, logistics partners, analytics vendors, or authentication providers may separately determine the purposes and means of processing certain data under their own legal obligations.

3. Definitions

For purposes of this Privacy Policy:

1. "Account" means a registered user profile used to access one or more features of Funmerce.
2. "Applicable Law" means any law, regulation, regulatory guidance, code, directive, judicial order, or legally binding rule applicable to the processing of data, online services, commerce activity, consumer protection, intellectual property, advertising, electronic communications, or platform governance.
3. "Content" means any video, image, audio, text, livestream, comment, review, product description, store profile material, username, listing, thumbnail, message, or other material submitted, uploaded, transmitted, displayed, or made available through Funmerce.
4. "Deep Link" means a direct route or URL pointing to specific platform content or destinations, including without limitation /watch/<video_id>, /product/<product_id>, /store/<store_id>, and /<username>.
5. "Personal Data" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an identified or identifiable natural person, household, device, or account, as recognized under Applicable Law.
6. "Seller" means any user, merchant, business, brand, creator, reseller, distributor, or other person or entity that lists, offers, promotes, advertises, sells, or intends to sell products or related services through Funmerce.
7. "Services" means the Funmerce platform and all related features, systems, interfaces, tools, content surfaces, recommendation functions, communication layers, transaction workflows, and future releases.
8. "User" means any individual or entity that accesses or uses Funmerce, whether registered or unregistered.

4. Scope of Policy

This Privacy Policy applies to personal data collected from or about users, sellers, creators, visitors, purchasers, support contacts, marketing recipients, applicants to seller programs, trusted reporters, rights holders, and other persons whose data is processed through the operation of Funmerce. It applies whether data is collected directly from you, automatically through your device or use of the platform, from other users, from merchants, from payment or logistics providers, from identity or authentication providers, from advertising and analytics technologies, from publicly available sources, or from trusted compliance, fraud, and security partners.

This Privacy Policy covers data processing connected to account creation, authentication, browsing behavior, watch activity, store management, product listing, ordering, payment facilitation, fraud review, content moderation, appeals, marketing, communications, referrals, deep link engagement, and future platform functions including livestream commerce, wallet systems, creator monetization, advertising systems, sponsored content tools, and cross-border commerce features. It does not override the independent privacy notices of third-party services, payment institutions, app stores, social login providers, logistics carriers, or sellers acting as separate data controllers where their own legal notices apply.

5. Eligibility and Age Restrictions

Funmerce is not directed to children who are below the age at which they may lawfully consent to data processing or enter binding digital service arrangements under Applicable Law. Users must meet the minimum age required in their jurisdiction to create an account and use the relevant services. In jurisdictions where parental or guardian authorization is required, use is permitted only with valid supervision or consent. Certain commerce, seller, payout, wallet, or monetization features may be subject to higher age thresholds, documentary verification, or enhanced compliance checks.

Where we become aware, or are reasonably put on notice, that personal data has been collected from a child in violation of Applicable Law or our platform rules, we may suspend the relevant account, limit visibility, remove associated content, and take steps to delete, de-identify, or otherwise appropriately handle the information, subject to legal retention duties.

6. Categories of Personal Data Collected

Funmerce may collect and process the following categories of personal data, depending on how you use the platform:

1. Identity data: name, legal name, display name, username, date of birth, gender where provided, national identification details where legally required, tax identifiers where required, and other identifiers used for account administration or verification.
2. Profile data: biography, profile photo, preferences, interests, social graph signals, followed accounts, saved items, wishlists, seller profile information, and account settings.
3. Device data: device identifiers, browser type, operating system, hardware model, app version, language settings, IP address, network details, crash data, session diagnostics, and security signals associated with a device or browser.
4. Location data: coarse geolocation inferred from IP address, device-based location where permission is granted, delivery address location, country selection, region of activity, and signals used to localize content or meet legal restrictions.
5. Transactional data: items viewed, items added to cart, orders placed, checkout activity, transaction value, shipping selections, refunds, returns, cancellations, dispute records, and associated timestamps.
6. Payment-related data: payment method type, masked payment instrument details, payment authorization tokens, payer billing metadata, transaction references, risk signals, and settlement or payout status. Funmerce may not store full card numbers or sensitive payment credentials except as permitted by law and through compliant payment infrastructure.
7. Seller business data: business name, registration data, tax details, incorporation records, beneficial ownership information where required, licensing data, compliance certificates, return addresses, warehouse details, customer support contacts, and bank or payout account metadata.
8. Uploaded media: videos, images, product media, store banners, audio tracks, thumbnails, captions, metadata embedded in files, livestream assets, and related moderation or machine analysis outputs.
9. Communications data: comments, reviews, messages, customer inquiries, seller responses, support submissions, appeals, trust and safety reports, and communications preference settings.
10. Support interactions: tickets, complaint details, verification correspondence, dispute narratives, screenshots, attachments, call or chat records where lawfully collected, and internal support handling notes.
11. Behavioral analytics: viewed videos, clicked products, product interests, search history, watch duration, pause or replay activity, follows, unfollows, saved items, seller interactions, shares, shared links, referrals, session paths, dwell time, feed engagement patterns, report submissions, moderation actions, and similar interaction signals used for recommendations, fraud detection, seller trust evaluation, feed optimization, product relevance, and service improvement.

7. Account Registration Data

When you create an account, we may collect your phone number, email address, username, password or password-derived credentials, date of birth, location information, country selection, referral information, profile image, and any other registration details required for security, fraud prevention, age screening, localization, or compliance. We may also generate internal account identifiers, registration timestamps, security event logs, device association records, and onboarding metadata to administer access and detect unauthorized or abusive account creation.

Where an account is created through a referral, invite flow, or deep-link-driven onboarding sequence, we may associate the registration with the referral source, campaign identifier, originating page, or link metadata to measure conversion, abuse patterns, or incentive program compliance.

8. Authentication Systems

Funmerce may support direct authentication and third-party authentication or identity services, including services such as Firebase Authentication or functionally similar providers. When you authenticate using such systems, we may receive and process identity tokens, hashed identifiers, session state, sign-in timestamps, authentication provider metadata, phone verification status, email verification status, device trust signals, multi-factor authentication status, recovery actions, and account linkage data.

Authentication data is used to establish and secure your account, support login recovery, prevent account takeover, enforce session integrity, identify suspicious sign-in attempts, maintain audit trails, and satisfy legal or contractual security obligations. Third-party authentication providers may independently process certain information under their own privacy notices. Funmerce does not control third-party provider practices except to the extent of our contractual or technical configuration rights.

9. Seller Verification Data

Where a user applies to sell through Funmerce or to access enhanced commerce, payout, wallet, advertising, or monetization features, we may collect verification materials including government-issued identification, business registration records, tax or trading documentation, proof of address, beneficial ownership details, corporate authorization letters, bank account evidence, product authorization evidence, compliance certificates, and related declarations. We may also collect facial comparison or liveness verification outputs where permitted by law and necessary for fraud prevention or platform integrity.

Seller verification data is used to confirm legitimacy, reduce counterfeit and fraud risk, comply with anti-money laundering, sanctions, tax, consumer protection, know-your-business, or marketplace integrity obligations, and determine seller eligibility, trust scoring, or access to certain commerce features.

10. Store Information Collected

When a seller creates or manages a store, Funmerce may collect store name, store handle, branding materials, business category, support contact details, return address, shipping settings, operating hours, warehouse or fulfillment information, payout profile references, public store description, linked social or business references, and customer service policies published by the seller. We may also collect performance signals associated with the store, including complaint rates, fulfillment rates, product report rates, moderation history, cancellation trends, response times, and conversion statistics.

11. Video and Media Content Processing

Funmerce processes uploaded and viewed media to host content, display it in feeds, generate thumbnails, enable playback, optimize quality, detect abuse, and improve discovery. Processing may include transcoding, compression, resizing, format conversion, metadata extraction, audio analysis, speech-to-text generation, caption processing, frame analysis, object or product detection, duplicate detection, content classification, safety review, rights enforcement, and internal ranking or recommendation scoring.

Where permitted by law, automated systems may infer attributes from media such as probable language, topical category, product category, likely audience interest, or integrity risk indicators. Such outputs may be used to personalize feeds, detect misleading product videos, identify counterfeit risk, enforce community rules, and support search or recommendation relevance.

12. Product Listing Information

Funmerce collects product listing data submitted by sellers or generated through listing workflows, including product titles, descriptions, categories, tags, variations, SKU references, dimensions, stock information, pricing, promotional terms, images, videos, brand claims, product specifications, warranty statements, compliance labels, shipping attributes, and inventory status. We may also create internal moderation, quality, ranking, and trust records relating to each listing.

Product listing information may be analyzed for completeness, policy compliance, prohibited or restricted goods risk, authenticity indicators, pricing anomalies, misleading claims, duplicate catalog entries, and search relevance.

13. Order and Commerce Transaction Data

When a purchase or attempted purchase occurs, we may collect order data including buyer and seller identifiers, order contents, quantities, price components, discounts, taxes, shipping fees, fulfillment selections, recipient details, invoice details, transaction status, risk review outcomes, support records, refund and dispute events, and proof of delivery or non-delivery data where available. We may also record order communication events, cancellation reasons, payment authorization results, and transaction reconciliation data.

Order and commerce data are used to process and administer transactions, communicate order status, manage disputes, detect fraud, provide customer support, satisfy accounting requirements, evaluate seller performance, improve recommendations and commerce UX, and enforce marketplace rules.

14. Payment Data Handling

Payment processing may be conducted by Funmerce, by regulated payment partners, or through third-party processors. Funmerce may collect or receive payment method type, masked card details, mobile money references, transaction tokens, payer name, billing metadata, risk indicators, authorization responses, and settlement records. Sensitive payment credentials are ordinarily processed by specialized providers using industry-standard security controls and are not stored in raw form by Funmerce except where lawfully permitted and technically necessary under compliant standards.

Payment-related data may be used to complete transactions, support refunds or chargeback responses, prevent fraudulent payments, comply with financial recordkeeping requirements, reconcile seller payouts, administer wallets or stored-value features if launched in the future, and monitor systemic abuse.

15. Fraud Prevention Systems

Funmerce maintains risk and fraud prevention systems designed to detect suspicious registration behavior, account takeover attempts, fake stores, seller fraud, payment abuse, counterfeit product activity, fake engagement, referral abuse, policy evasion, coordinated inauthentic behavior, misleading product demonstrations, chargeback patterns, and other harmful conduct. To support these systems, we may analyze identity signals, device associations, network information, transaction history, watch and click behavior, content patterns, complaint histories, moderation records, shipment anomalies, and signals from third-party fraud intelligence tools.

Fraud review may include automated scoring, manual investigation, enhanced verification requests, account limitation, listing suspension, delayed payouts, transaction holds, or disclosure to payment institutions, law enforcement, or affected parties where legally justified.

16. Device Fingerprinting and Abuse Prevention

To protect the platform, Funmerce may use device fingerprinting and related abuse prevention techniques that analyze non-precise device and browser characteristics, network patterns, login history, session consistency, emulator detection, bot indicators, abnormal interaction sequences, account clustering signals, and other technical indicators that help distinguish genuine use from scripted, fraudulent, or malicious activity. These techniques are used for trust and safety, authentication hardening, rate limiting, fraud prevention, spam control, and policy enforcement.

17. Cookies and Tracking Technologies

Funmerce and its service providers may use cookies, SDKs, pixels, tags, local storage, server logs, and similar technologies to authenticate users, remember preferences, preserve session continuity, measure content performance, understand product interaction, assess campaign effectiveness, attribute referrals, personalize experiences, prevent abuse, and support analytics or advertising functions. Some technologies are essential for the operation and security of the platform, while others support measurement, personalization, or marketing.

Depending on your jurisdiction, you may have the ability to manage certain cookie or tracking settings, subject to the technical requirements of the service and the lawful bases available to us.

18. Recommendation Engine Data Usage

Funmerce uses behavioral, contextual, and transactional signals to determine what videos, products, stores, creators, and offers may be most relevant to a user. Signals may include viewed videos, watch duration, replays, product clicks, search history, product interests, follows, saved items, cart activity, seller interactions, purchases, shares, shared links, referrals, device language, approximate location, store performance, and content category. Recommendation systems may also take into account product availability, policy risk, freshness, quality indicators, complaint rates, and user feedback signals.

These systems are designed to improve discovery, feed relevance, product relevance, seller trust, user experience, and platform efficiency. Recommendation outputs may affect the visibility of content, listings, or stores, but do not guarantee any level of distribution, impressions, or sales.

19. Search Analytics

Funmerce may record search queries, autocomplete interactions, search result clicks, dwell time following search, search filters used, failed searches, repeated searches, query reformulations, and search-to-purchase conversion events. Search analytics help us improve retrieval quality, understand product demand, surface relevant products and creators, identify prohibited or risky queries, and refine search ranking and taxonomy systems.

20. Feed Personalization

The Funmerce feed may be personalized based on behavioral and contextual signals, including viewed videos, skipped videos, watch duration, pause events, audio engagement, product clicks, follows, saved items, profile visits, recent purchases, seller interactions, share behavior, location region, device language, and prior moderation or trust outcomes where relevant to safety. Feed personalization may also incorporate aggregate or cohort-level trends, seasonal demand, commerce events, and limited experimentation to improve quality and safety.

21. AI-Assisted Ranking Systems

Funmerce may use AI-assisted, machine-assisted, or algorithmic systems to rank, recommend, classify, label, prioritize, suppress, review, or otherwise process content, products, stores, and accounts. These systems may evaluate engagement signals, content similarity, trust metrics, product metadata, quality indicators, user preference patterns, and safety factors. Automated systems may be complemented by human review, especially where trust and safety, seller integrity, fraud, or legal risk are implicated.

AI-assisted ranking is used to improve relevance, reduce spam and harmful content, identify misleading demonstrations, detect suspicious seller behavior, and manage content distribution quality at scale. Automated outputs may be imperfect and may be reviewed, corrected, or overridden.

22. Deep Link Activity Tracking

Funmerce may collect data about the creation, opening, forwarding, sharing, and performance of Deep Links, including the referring source, destination page, timestamp, campaign or creator attribution, device or browser context, general location, and resulting actions such as account creation, video views, product clicks, follows, purchases, or abuse patterns. Deep link tracking supports attribution, user experience continuity, referral systems, fraud detection, content distribution analysis, and product analytics.

23. Marketing Communications

Where permitted by law, Funmerce may use your contact details, preferences, engagement history, transaction data, and inferred interests to send or tailor marketing communications relating to new products, platform features, seller promotions, platform campaigns, creator content, marketplace events, wallet or monetization features, advertising products, or other updates that may be relevant to you. Marketing communications may be sent by email, SMS, push notification, in-app messaging, on-site banners, or other lawful channels.

You may have the ability to opt out of non-essential marketing communications, but operational, legal, security, and transactional communications may still be sent where necessary.

24. Push Notifications

If you enable push notifications, Funmerce may send alerts relating to follows, comments, likes, saves, shares, product price changes, seller responses, order status, shipping updates, refund updates, promotions, recommendations, security events, trust and safety notices, and future livestream or monetization events. Device tokens and notification preference data may be stored and processed to deliver and manage such communications.

25. Email Communications

Funmerce may send emails for account verification, login security, password reset, order confirmation, payment updates, shipping notices, support responses, policy notices, moderation decisions, legal notices, and marketing where lawful. We may track delivery, bounce, open, unsubscribe, and engagement events to maintain deliverability, improve message quality, prevent abuse, and document compliance.

26. In-App Messaging Data

Where in-app messaging or user-to-user communication features are made available, Funmerce may process message content, metadata, attachments, timestamps, sender and recipient identifiers, delivery records, abuse reports, moderation flags, and automated safety indicators. Messaging data may be used to provide the feature, investigate harassment, scams, seller fraud, counterfeit sales, prohibited transactions, or other violations, and comply with lawful requests.

27. Log Retention

Funmerce maintains technical, security, and operational logs, including server logs, authentication logs, API logs, moderation logs, transaction logs, and abuse prevention records. Log retention periods vary based on the purpose of the log, the nature of the event, the need to investigate security or fraud issues, legal retention requirements, and operational necessity. Certain logs may be retained for longer periods where required for dispute handling, incident response, or evidence preservation.

28. Security Monitoring

We monitor platform activity to protect users, sellers, content integrity, transaction reliability, and system security. Monitoring may include automated alerts, anomaly detection, malware scanning, access control review, credential misuse detection, transaction risk review, suspicious seller pattern analysis, and investigation of reports submitted by users, sellers, payment partners, logistics partners, or rights holders. Security monitoring may involve both automated and human review.

29. Data Storage Locations

Personal data may be stored or processed in Uganda and in other jurisdictions where Funmerce, its affiliates, or its service providers maintain facilities, infrastructure, support teams, security operations, analytics environments, or backup systems. Storage architecture may be distributed for redundancy, performance, resilience, analytics, content delivery, or compliance reasons. The precise storage location of a given data element may vary over time based on service providers, regional deployment, disaster recovery design, and business needs.

30. Third-Party Service Providers

Funmerce may engage third-party service providers to support hosting, infrastructure, authentication, payments, analytics, content delivery, moderation tooling, customer support, logistics coordination, fraud detection, communications delivery, KYC or KYB verification, marketing measurement, and legal compliance. Such providers may process personal data on our behalf or, in some cases, under their own legal responsibilities. We take commercially reasonable steps to evaluate providers, apply contractual controls where appropriate, and require security and confidentiality obligations consistent with the nature of the services.

31. Cloud Hosting

Cloud infrastructure providers may host application servers, databases, media storage, backups, log pipelines, monitoring systems, AI workloads, and disaster recovery environments. These providers may process system content and operational data as necessary to maintain infrastructure, security, scaling, and resilience, subject to contractual controls and applicable law.

32. CDN and Media Delivery Providers

Funmerce may use content delivery networks, edge caching systems, media optimization providers, transcoding providers, and similar vendors to deliver videos, product images, thumbnails, and other media assets efficiently. These providers may necessarily process IP addresses, device and browser headers, request metadata, playback statistics, regional routing information, and content access logs in order to perform delivery, optimization, and security functions.

33. Analytics Providers

Funmerce may use internal analytics tools and external analytics providers to measure traffic, engagement, conversion, seller performance, search quality, recommendation effectiveness, and product interactions. Analytics data may include viewed videos, watch duration, clicked products, search history, product interests, saved items, seller interactions, shared links, referrals, and commerce conversion signals. We use such analytics for recommendations, fraud detection, seller trust, feed optimization, product relevance, and service improvement.

34. Legal Basis for Processing Data

Where Applicable Law requires a legal basis, Funmerce processes personal data on one or more of the following grounds:

1. performance of a contract or steps taken at your request before entering into a contract, including account provision, transaction administration, seller onboarding, and support;
2. legitimate interests pursued by Funmerce or a third party, including security, fraud prevention, analytics, product improvement, feed personalization, recommendation systems, moderation, seller trust, business continuity, and platform integrity, where such interests are not overridden by your rights;
3. compliance with legal obligations, including tax, accounting, consumer protection, law enforcement response, sanctions screening, and recordkeeping;
4. consent, where consent is required or chosen as the legal basis, including for certain marketing, tracking, or location functions; and
5. protection of vital interests, public interest, or establishment, exercise, or defense of legal claims where recognized under Applicable Law.

35. Data Retention Periods

Funmerce retains personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the services, maintain security, investigate fraud or abuse, comply with legal obligations, resolve disputes, enforce agreements, protect rights, and preserve evidence. Retention periods depend on the category of data, sensitivity, risk, legal requirements, and operational need.

Account data may generally be retained for the life of the account and a reasonable period thereafter. Transaction and financial records may be retained for longer periods to satisfy accounting, tax, audit, chargeback, fraud, consumer protection, and dispute obligations. Moderation records, reports submitted, and enforcement actions may be retained for platform integrity and repeat-abuse prevention. Backup copies may persist for limited periods beyond primary deletion due to system rotation schedules.

36. User Rights

Subject to Applicable Law, you may have the right to:

1. access personal data we hold about you;
2. request correction of inaccurate or incomplete data;
3. request deletion of certain data;
4. request restriction of certain processing;
5. object to certain processing, particularly where based on legitimate interests or direct marketing;
6. request portability of certain data in a structured, commonly used, and machine-readable format; and
7. withdraw consent where processing is based on consent, without affecting prior lawful processing.

These rights are not absolute. We may decline, limit, or condition requests where permitted by law, including where data is required for legal compliance, fraud prevention, security, dispute resolution, public interest, freedom of expression, or protection of other users or sellers. We may request verification before acting on a rights request.

37. Seller Obligations Regarding Customer Data

Sellers that receive or access customer data through Funmerce must process such data only for legitimate transaction-related purposes, including order fulfillment, customer support, lawful returns handling, tax documentation, and other permitted commerce functions. Sellers must not misuse customer data for unauthorized marketing, off-platform solicitation, identity misuse, profiling unrelated to the transaction, unlawful disclosure, resale of personal data, or any activity inconsistent with Applicable Law or platform policy.

Sellers are independently responsible for complying with applicable data protection, consumer protection, tax, product safety, and electronic commerce laws in the jurisdictions where they operate or sell.

38. Cross-Border Data Transfers

Because Funmerce may operate with international infrastructure, service providers, sellers, buyers, and support operations, personal data may be transferred across borders. Where cross-border transfers occur, Funmerce will take commercially reasonable steps to implement safeguards appropriate under Applicable Law, which may include contractual protections, transfer assessments, security measures, localization where required, and other recognized mechanisms.

39. Law Enforcement Disclosures

Funmerce may preserve, use, and disclose personal data to law enforcement, regulatory authorities, courts, rights holders, payment institutions, anti-fraud organizations, or other authorized third parties where we determine in good faith that disclosure is required or appropriate to comply with law, respond to a lawful request, protect life or safety, investigate fraud or illegal conduct, enforce our agreements, or defend legal claims. We may also disclose information where necessary to prevent imminent harm, financial loss, platform abuse, or systemic security threats.

40. Business Transfers / Acquisitions

In the event of a merger, acquisition, financing, corporate restructuring, insolvency proceeding, asset sale, business transfer, or similar transaction involving all or part of Funmerce or Gasobu Technologies Uganda Limited, personal data may be disclosed to advisers, counterparties, investors, lenders, and successor entities as part of due diligence, negotiation, and completion of the transaction, subject to confidentiality obligations and applicable legal requirements.

41. Children's Privacy

Funmerce does not knowingly permit unlawful collection of personal data from children. Where children are permitted to use limited aspects of the service under Applicable Law, additional safeguards, age-gating, parental involvement measures, feature limitations, or restricted processing may apply. If a parent, guardian, or regulator believes a child has provided personal data unlawfully, they should contact us promptly so that appropriate review and remediation steps can be taken.

42. Content Moderation Implications

Information associated with videos, products, comments, messages, reports, appeals, reviews, seller conduct, and account activity may be processed for moderation, trust and safety, legal compliance, and enforcement. This may include automated classification, human review, reviewer annotations, policy labels, internal case files, risk scoring, and escalation logs. Reports submitted by users and moderation actions taken by Funmerce may be retained to investigate repeat abuse, maintain platform safety, and document enforcement consistency.

43. Public Content Visibility Rules

Certain information is inherently public or semi-public when you use Funmerce. Depending on your settings and the relevant feature, your username, profile image, public bio, uploaded videos, public comments, store name, product listings, reviews, and certain engagement signals may be visible to other users, search engines, referral recipients, or the public through shared Deep Links. Users should exercise care before uploading content or store information they do not wish to be publicly associated with them.

44. Deleted Content Handling

When you delete content or request deletion of account information, the content may no longer be visible through ordinary user interfaces, but copies may remain for a period in caches, backups, moderation systems, legal preservation holds, abuse prevention records, or logs. We may also retain deleted content or associated data where necessary to investigate violations, comply with law, enforce rights, process disputes, or prevent repeat abuse.

45. Backup Retention

Funmerce maintains backup and disaster recovery systems for resilience, continuity, and restoration. Personal data contained in backups may continue to exist until backup media or backup sets are rotated, overwritten, expired, or securely destroyed according to our retention practices. Backup data is typically subject to access restrictions and is not ordinarily restored except for legitimate recovery, continuity, testing, legal, or security purposes.

46. Security Safeguards

Funmerce applies technical, administrative, and organizational safeguards designed to protect personal data against unauthorized access, destruction, loss, alteration, disclosure, misuse, or other unlawful processing. Safeguards may include encryption in transit and at rest where appropriate, access controls, role-based permissions, logging, monitoring, secret management, secure development practices, authentication controls, vulnerability management, vendor review, incident handling procedures, and employee or contractor confidentiality obligations.

No system can be guaranteed absolutely secure. Users are responsible for maintaining account credential confidentiality, using strong passwords or secure sign-in methods, protecting devices, and notifying us of suspected compromise.

47. Incident Response

Funmerce maintains incident response processes intended to identify, assess, contain, investigate, remediate, and document security incidents and other data-related events. Where required by Applicable Law, we may notify affected individuals, regulators, law enforcement, payment partners, or other stakeholders within the timeframes and conditions prescribed by law. Incident handling may involve temporary access restrictions, session invalidation, transaction holds, forensic review, provider coordination, and preservation of evidence.

48. Changes to Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in law, regulation, platform features, business operations, security practices, data uses, international expansion, seller programs, payment models, wallet systems, creator monetization programs, livestream commerce features, ad systems, or other developments. The revised version will become effective when posted or as otherwise stated. Where required by law, we will provide additional notice or obtain consent. Continued use of Funmerce after the effective date of an updated Privacy Policy constitutes acknowledgment of the revised terms to the extent permitted by law.

49. Contact Information

Questions, requests, complaints, notices, and data rights submissions relating to this Privacy Policy or the processing of personal data through Funmerce should be directed to:

Gasobu Technologies Uganda Limited
Funmerce Privacy Office
Email: privacy@funmerce.com
Support: support@funmerce.com

If you are contacting us regarding a rights request, please provide sufficient detail for us to verify your identity, understand the request, and locate the relevant data.

50. Governing Jurisdiction

This Privacy Policy is governed principally by the laws of Uganda to the extent such laws apply to the operation of Funmerce by Gasobu Technologies Uganda Limited. However, where Funmerce expands into other jurisdictions or processes personal data of persons located outside Uganda, we may apply additional disclosures, rights frameworks, contractual protections, or local compliance measures required by Applicable Law. If any provision of this Privacy Policy is inconsistent with mandatory local law, the mandatory law shall prevail to the extent of the inconsistency, without invalidating the remaining provisions.