Privacy Policy
Last Updated: January 13, 2026
1. Introduction
Welcome to hlomo ("we," "our," or "us"). We are committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our community management platform and services.
hlomo is registered in South Africa (Registration: 2022/858088/07) and complies with the Protection of Personal Information Act (POPIA) and applicable international data protection regulations including GDPR where applicable.
2. Information We Collect
2.1 Information You Provide
- Account Information: Name, email address, phone number, organization details
- Community Information: Community names, descriptions, member lists (phone numbers/emails)
- Profile Information: Profile photos, bio, interests, preferences
- Communication Data: Messages you send through our platform, support inquiries
2.2 Information We Collect Automatically
- Engagement Metadata: Message timestamps, participant counts, response rates, activity patterns
- Usage Data: Features used, pages visited, time spent, click patterns
- Device Information: IP address, browser type, device type, operating system
- Cookies: Session cookies, preference cookies, analytics cookies
2.3 Information from Third Parties
- WhatsApp Integration: Message metadata (sender, timestamp, participant info) - NOT message content
- Authentication Providers: Google, Microsoft, or other OAuth providers (name, email, profile photo)
🔒 What We DO NOT Collect
- Message Content: We do NOT read, store, or analyze the content of your WhatsApp messages or private communications
- Personal Conversations: We analyze engagement patterns and metadata only, never the substance of your conversations
- Sensitive Personal Data: We do not intentionally collect health data, financial information, or other special category data unless you explicitly provide it
3. How We Use Your Information
- Service Delivery: To provide, maintain, and improve our community management platform
- Community Analytics: To generate engagement reports, health scores, and participation insights
- AI Features: To power our AI co-pilots (Bro, Harmony, Buddy) with contextual community understanding
- Communication: To send service updates, notifications, and respond to your inquiries
- Safety & Security: To detect fraud, abuse, and maintain platform security
- Legal Compliance: To comply with applicable laws and legal obligations
- Research & Development: To improve our algorithms and develop new features (using anonymized/aggregated data)
4. How We Share Your Information
We share your information only in these limited circumstances:
- With Your Consent: When you explicitly authorize us to share information
- Within Your Community: Community leaders can see aggregated analytics about their communities
- Service Providers: Cloud hosting (Firebase/Google Cloud), analytics providers, email services - all under strict data processing agreements
- Legal Requirements: When required by law, court order, or to protect rights and safety
- Business Transfers: In the event of a merger, acquisition, or sale (with notice to you)
We do NOT sell your personal information to third parties. Ever.
5. Data Retention
We retain your information for as long as necessary to provide services and fulfill the purposes outlined in this policy:
- Account Data: Retained while your account is active, plus 90 days after deletion
- Community Analytics: Retained for up to 2 years for historical insights
- Aggregated/Anonymized Data: May be retained indefinitely for research and product improvement
- Legal/Security Records: Retained as required by law or for fraud prevention
6. Your Privacy Rights
You have the following rights regarding your personal information:
- Access: Request a copy of your personal information
- Correction: Update or correct inaccurate information
- Deletion: Request deletion of your personal information ("right to be forgotten")
- Data Portability: Receive your data in a machine-readable format
- Objection: Object to processing of your information for certain purposes
- Restriction: Request limitation on how we use your data
- Withdraw Consent: Withdraw consent for data processing at any time
To exercise these rights, contact us at:
- 📧 Email: privacy@hlomo.com
- 🗑️ Data Deletion Form: Submit Request
- 📱 Phone: +27 82 414 8292
We will respond to requests within 30 days (or as required by applicable law).
7. Security Measures
We implement industry-standard security measures to protect your information:
- Encryption in transit (TLS/SSL) and at rest
- Secure authentication (Firebase Auth, OAuth 2.0)
- Regular security audits and penetration testing
- Access controls and principle of least privilege
- Incident response and breach notification procedures
While we strive to protect your information, no method of transmission over the internet is 100% secure. Please use strong passwords and enable two-factor authentication.
8. Children's Privacy
Our services are not intended for children under 13 years of age. We do not knowingly collect personal information from children. If you believe we have inadvertently collected information from a child, please contact us immediately at privacy@hlomo.com.
9. International Data Transfers
Your information may be transferred to and processed in countries other than South Africa, including countries that may not have the same data protection laws. We ensure appropriate safeguards are in place:
- Standard Contractual Clauses (SCCs) for EU data transfers
- Adequacy decisions where applicable
- Compliance with POPIA cross-border transfer requirements
10. Cookies and Tracking
We use cookies and similar technologies to:
- Keep you signed in
- Remember your preferences
- Understand how you use our platform
- Improve our services
You can control cookies through your browser settings. Note that disabling cookies may affect functionality.
11. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of significant changes via email or prominent notice on our platform. Your continued use of hlomo after changes constitutes acceptance of the updated policy.
12. Contact Us
If you have questions or concerns about this Privacy Policy or our data practices:
hlomo (Pty) Ltd
Registration: 2022/858088/07
Email: privacy@hlomo.com
Phone: +27 82 414 8292
Website: hlomo.com
For POPIA-related complaints, you may also contact the South African Information Regulator at justice.gov.za/inforeg