Kulawise Privacy Policy

Your health is personal and so is your data.

At Kulawise, we build tools that help people eat better, optimize food spending, and stay consistent with their wellness goals. To make this possible, we collect and use certain personal information. This Privacy Policy explains what we collect, why we collect it, how we process it, and the rights you have under the Nigeria Data Protection Regulation (NDPR) and the Nigeria Data Protection Act (NDPA).

This policy applies to anyone who uses the Kulawise mobile app, website, or interacts with us through channels such as email, Telegram, or customer support.

For a plain-language summary of how we structure data internally, see our Data Handling page.

1. Why We Collect Data

We collect and process your data to:

  • Create and personalize your meal and wellness plans
  • Recommend meals based on your pantry, budget, preferences, and goals
  • Track activities such as steps, gym check-ins, challenges, and progress
  • Power AI features (meal generation, grocery suggestions, insights)
  • Improve app performance, fix bugs, and develop new features
  • Maintain security, prevent fraud, and comply with regulations
  • Communicate with you (notifications, reminders, service updates)
  • Process payments if you use subscription features

We only process your data when we have a legal basis, such as:

  • Your consent
  • Performance of a contract (delivering the Kulawise service)
  • Legitimate interest (analytics, feature improvement)
  • Legal obligation

2. How We Capture Your Consent

We capture consent for different data categories separately rather than bundling everything into one acceptance.

  • Account creation: You consent to processing of basic account information needed to deliver the Service.
  • Health and wellness data: A separate consent prompt appears the first time you enable health tracking. You can withdraw this consent at any time in Settings without losing access to the rest of the app.
  • Wallet and payment features: A separate consent step is required before you can fund a wallet or subscribe to a paid Circle.
  • Notifications and marketing: Captured at first launch with separate toggles for transactional and promotional messages.
  • AI personalization: Enabled by default, with opt-out available in Settings.

You can review and update your consent choices at any time in Settings > Privacy.

3. What We Collect

Depending on how you use Kulawise, we may collect the following:

Account Information

  • Name
  • Email address
  • Password (encrypted)

Health & Wellness Information (sensitive data collected only with explicit consent)

  • Allergies
  • Dietary restrictions
  • Health conditions (if you choose to share)
  • Weight, height, wellness preferences
  • Fasting activity
  • Sleep duration
  • Steps and exercise entries

Food & Meal Data

  • Pantry items
  • Grocery lists
  • Meal plans
  • Photos uploaded for meal scans

Community & Social Data

When you participate in Circles, we collect your membership status, challenge participation, leaderboard rankings, and messages sent within Circle chats. Leaderboard rankings and challenge completions are visible to other members of your Circle by design.

Wallet Data

Your wallet balance is processed and held by our licensed payment partners under their applicable regulatory authorizations. Kulawise maintains a closed-loop ledger that records your balance based on confirmed transactions. We collect:

  • Top-up and withdrawal records
  • Circle subscriptions & rewards history
  • Transaction timestamps and amounts

We do not store payment card details. These are processed and held by our licensed payment partners under PCI-DSS security standards. Transaction records are retained as required by Nigerian tax and business record-keeping laws.

Location Information

  • City, state, or region to provide localized grocery suggestions and pricing
  • We do not collect precise GPS location without explicit permission, and it's only ever used when you want to checkin to a gym and we never store it.

Activity & Usage Data

  • Challenges joined
  • Points earned
  • Device information
  • App usage statistics
  • Crash logs and technical diagnostics

Feedback & Communication

  • Support conversations
  • Survey responses
  • Reports or suggestions

We do not collect information that is not needed for your experience.

4. Cookies & Analytics

We use cookies and analytics tools to:

  • Understand how users interact with the app and website
  • Save your preferences
  • Improve performance and user experience

You can disable cookies in your browser at any time.

5. How We Use Your Data

We use your data to:

  • Generate personalized meal plans and insights with AI
  • Suggest affordable meals using pantry items and local prices
  • Track your progress and daily activities
  • Manage points, rewards, and challenges
  • Improve the quality of recommendations
  • Monitor system performance and security
  • Provide customer support
  • Enable payments for subscriptions or wallet features
  • Enforce our terms and legal obligations

We do not sell your data under any circumstances.

6. Who We Share Data With

We share data only with vetted processors that help us deliver the Service:

  • Cloud hosting providers (encrypted application data)
  • Licensed payment partners (payment processing and wallet custody)
  • AI model providers (meal generation and wellness insights)
  • Customer support tools

All processors operate under legally binding Data Processing Agreements (DPAs) that bind them to our privacy and security standards. We do not track or use your data for targeted ads under any circumstance.

International Transfers

Some processors operate data centres outside Nigeria, including the EU and US. Where we transfer data internationally, we use:

  • Contractual safeguards under NDPR/NDPA
  • GDPR-equivalent controls where applicable
  • Adequacy decisions where they exist

7. Your Rights & Controls

You have full rights under the NDPR/NDPA, including the right to:

  • View the data we hold about you
  • Update or correct your information
  • Download or request a copy of your data
  • Delete your account and data
  • Withdraw consent at any time for health data, analytics, or AI personalization
  • Opt out of promotional messages
  • Object to certain types of processing
  • Restrict data processing in certain scenarios

To exercise any of your rights, email hello@kulawise.com. We respond within the legally required timeline.

8. Security & Storage

We protect your data using:

  • Encryption (in transit and at rest)
  • Secure cloud hosting
  • Access controls and authentication rules
  • Ongoing security reviews and monitoring
  • Industry best practices for sensitive data handling
  • No direct storage of payment card details

Data Separation Architecture

Your identity data (name, email) and health data are stored in separate database structures with isolated access controls. They are linked only through encrypted reference identifiers. A compromise of either store does not expose the other without access to both sets of credentials.

This separation is a core part of our security architecture. For more detail, see our Data Handling page.

You are also encouraged to use a strong password and keep your login credentials private.

9. Data Retention

We retain different categories of data for different periods based on legal requirements and operational needs.

  • Account information: Retained while your account is active. Deleted within 30 days of account closure, unless legally required to retain.
  • Health and wellness data: Retained while your account is active. Deleted within 30 days of account closure or withdrawal of consent.
  • Wallet and transaction records: Retained as required by Nigerian tax and business record-keeping laws, typically up to 6 years.
  • Communications and support records: Retained for two years after the last interaction.
  • Backups: Purged on a 90-day rolling cycle after primary deletion.

You can request earlier deletion of any data not subject to legal retention requirements by contacting our designated officer at hello@kulawise.com.

10. AI Processing

Kulawise uses AI models to:

  • Generate personalized meal plans
  • Analyze food photos
  • Summarize health patterns and provide wellness insights
  • Provide grocery suggestions
  • Recommend Circles, coaches, or content

AI outputs are based on the data you provide. Our AI providers operate under agreements that restrict retention and prohibit training on your data.

We do not use AI to make high-stakes automated decisions that affect your access to services, financial standing, or insurance eligibility.

To opt out of AI personalization, go to Settings > Privacy > AI Personalization in the app. Opting out disables personalized meal generation and AI wellness insights. Core app features remain available.

11. Breach Notification

If we experience a personal data breach that may pose a risk to your rights, we will:

  • Notify the Nigeria Data Protection Commission within 72 hours of becoming aware of the breach
  • Notify you directly via email and in-app message where the breach is likely to result in a high risk to you
  • Document the breach, its effects, and the remediation steps taken

12. Updates to This Policy

We may update this Privacy Policy to reflect:

  • New features
  • Regulatory requirements
  • Security improvements
  • Product changes

If we make significant changes, we will notify you through email or an in-app message at least 30 days before the changes take effect.

13. Governing Law

This Privacy Policy is governed by:

  • The Nigeria Data Protection Regulation (NDPR)
  • The Nigeria Data Protection Act (NDPA)
  • Any other applicable Nigerian laws and regulations

Any disputes will be handled under the laws of the Federal Republic of Nigeria.

14. Data Protection Contact

Our Data Protection responsibilities are overseen by a designated officer reachable at hello@kulawise.com. For any questions about how we handle your personal data, please use this address.

Last updated: June 2026

General questions: hello@kulawise.com