Privacy
Policy

Welcome to Fefefe, Africa's AI Creative Suite ("Platform", "we", "us", or "our"), operated by CrownCity Technologies Ltd, a company incorporated in the Republic of Ghana. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you access or use fefefe.app and our related applications.

This Policy applies to all users of the Platform including individuals, small and medium enterprises (SMEs), brands, creators, filmmakers, designers, educational institutions, and freelancers across our operating markets of Ghana, Nigeria, Kenya, South Africa, and any other territories we expand into.

By registering an account, subscribing to a plan, or otherwise using the Platform, you acknowledge that you have read, understood, and consent to the practices described in this Privacy Policy. If you do not agree, please discontinue use of the Platform immediately.

The following terms carry specific meanings throughout this Policy:

3.1 Information You Provide Directly

• —Account registration details: full name, email address, phone number, country of residence, and business name (if applicable).
• —Payment information: mobile money account number, bank card details (processed via Paystack or other licensed payment service providers— we do not store full card numbers), billing address, and currency preference.
• —Profile information: profile photo, occupation, creative niche, and social media handles (optional).
• —Content inputs: prompts, form selections, uploaded images or videos submitted for AI processing.
• —Communications: messages you send to our support team, feedback submitted through the Platform, and survey responses.
• —Referral information: your referral code usage and accounts you referred.

3.2 Information Collected Automatically

• —Device information: IP address, browser type and version, operating system, device model, and screen resolution.
• —Usage data: pages visited, features used, templates accessed, generation history, time spent, and click behavior.
• —Location data: approximate geographic location derived from your IP address for currency detection and regional content customization.
• —Cookies and tracking technologies: session cookies, persistent cookies, and similar technologies (see Section 9).
• —API logs: request timestamps, model endpoints called, generation success/failure rates, and token usage.

3.3 Information from Third Parties

• —Payment processors: transaction status and fraud signals from Paystack.
• —AI model providers: generation metadata from API partners.
• —Analytics providers: aggregated behavior patterns from analytics integrations.
• —Social platforms: basic profile data if you choose to sign in via a social media account (e.g., Google).

We process your Personal Data under the following legal grounds:

4.1 Performance of Contract

• —To create and manage your account and authenticate your identity.
• —To process payments and manage subscription billing in your local currency.
• —To deliver AI-generated content based on your template selections and inputs.
• —To deliver AI-generated content based on your template selections and inputs.
• —To send transactional communications such as payment receipts, generation confirmations, and account notifications.

4.2 Legitimate Interests

• —To improve the quality, cultural accuracy, and performance of our AI models and prompt systems.
• —To detect, prevent, and investigate fraud, abuse, and violations of our Terms of Service.
• —To analyze platform usage patterns and optimize the user experience.
• —To train and fine-tune our proprietary AI models using anonymized or aggregated data derived from platform usage (see Section 4.5 for your choices).
• —To operate our referral tracking system and attribute rewards correctly.

4.3 Consent

• —To send you marketing communications about new features, promotions, and content tips (you may withdraw consent at any time).
• —To use your testimonials or case studies in our marketing materials (only with your explicit written consent).
• —To send you WhatsApp-based updates and community announcements through our official channels.

4.4 Legal Compliance

• —To comply with applicable laws in Ghana, Nigeria, Kenya, South Africa, and other jurisdictions where we operate.
• —To respond to lawful requests from regulatory authorities or law enforcement.
• —To maintain records required by tax and financial regulations.

4.5 Your Choices Regarding AI Training

We value your creative output. By default, content you generate on the Platform may be used in an anonymized and aggregated manner to improve our AI models. You may opt out of this use at any time through your Account Settings > Privacy > AI Training Preference. Opting out does not affect your ability to use the Platform.

We do not sell your Personal Data. We share it only in these limited circumstances:

5.1 Service Providers

We engage trusted third-party service providers who process data on our behalf under contractual obligations of confidentiality and data protection:

5.2 Business Transfers

If CrownCity Technologies Ltd undergoes a merger, acquisition, restructuring, or sale of assets, your Personal Data may be transferred to the successor entity. We will notify you of any such transfer and applicable privacy choices.

5.3 Legal Requirements

We may disclose your Personal Data if required to do so by law, court order, or governmental authority, or if we believe in good faith that such disclosure is necessary to protect the rights, property, or safety of CrownCity Technologies, our users, or the public.

5.4 With Your Consent

We will share your information with any other third party where you have given us your prior consent to do so.

We retain Personal Data only as long as necessary to fulfill the purpose it was collected for.

You may request deletion of your account and data at any time (see Section 8).

As a pan-African platform with globally distributed AI infrastructure, your data may be transferred to and processed in countries outside your residence, including the United States and EU.

We safeguard all cross-border transfers through:

• —Contractual clauses binding our service providers to equivalent data protection standards.
• —Processing agreements that comply with applicable African data protection laws including Ghana's Data Protection Act (Act 843), Nigeria's Nigeria Data Protection Act 2023 (NDPA), Kenya's Data Protection Act 2019, and South Africa's Protection of Personal Information Act (POPIA).

By using the Platform, you consent to your information being transferred to and processed in these countries in accordance with the safeguards described above.

Depending on your country of residence, you hold the following rights:

To exercise any of these rights, please contact us at privacy privacy@fefefe.app or through your Account Settings > Privacy. We will respond to your request within 30 days. We may ask you to verify your identity before processing your request. Some requests may be subject to exceptions under applicable law.

We use the following types of cookies on the Platform:

You may manage your cookie preferences through your browser settings or our Cookie Preference Center. Disabling certain cookies may affect Platform functionality.

We implement industry-standard technical and organizational measures to protect your Personal Data against unauthorized access, disclosure, alteration, or destruction. These include:

• —Encryption of data in transit using TLS/SSL protocols.
• —Encryption of sensitive data at rest, including payment-related information.
• —Access controls limiting data access to authorized personnel only.
• —Regular security audits and vulnerability assessments.
• —Secure API authentication for all third-party integrations.

The Platform is not directed to individuals under the age of 16. We do not knowingly collect Personal Data from children under 16 without verifiable parental consent. If we become aware that we have collected data from a child under 16 without appropriate consent, we will delete that information promptly.

Users between 16 and 18 years of age may use the Platform through educational institutions or with parental consent as described in our educational partnership program.

We may update this Privacy Policy from time to time. When we make material changes, we will notify you by:

• —Sending an email to the address associated with your account.
• —Displaying a prominent notice on the Platform for at least 30 days before changes take effect.
• —Updating the "Effective Date" at the top of this Policy.

Your continued use of the Platform after the effective date constitutes acceptance of the revised Policy.

For any privacy-related questions, requests, or complaints, please reach our Data Protection Officer:

If you are not satisfied with our response to a privacy complaint, you have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction, including the Data Protection Commission (Ghana), the Nigeria Data Protection Commission, the Office of the Data Protection Commissioner (Kenya), or the Information Regulator (South Africa).