Legal document

Privacy Policy

Version: 1.0 · Effective date: 23 September 2026 · Last updated: 23 September 2026

Atuule Marketing Agency Limited is a Zambia-based provider of multi-tenant business software and digital workspace infrastructure. Depending on the plan, Atuule may provide private workspaces, business websites and online stores, customer and member records, correspondence, billing and invoices, AI-assisted tools including Njavwa, integrations, generated sites or mini-apps, and optional implementation or managed services.

1. SaaS relationship and privacy roles

A tenant normally operates its own business through an isolated workspace and controls its customers, members, staff, contacts, products, prices, brand, records, policies, transactions, and fulfilment arrangements. Tenants retain ownership or lawful control of submitted data and content and give Atuule only the limited rights needed to host, process, secure, display, back up, and transmit it to provide the services, follow authorised instructions, and meet legal obligations. Atuule may act as an independent controller for account authentication, subscriptions, support, platform security, fraud prevention, service analytics, legal compliance, account communications, and lawful marketing. For tenant-controlled data, Atuule may act as a service provider or processor under the tenant’s instructions. The role depends on the activity, agreement, instructions, and applicable law.

Tenants remain responsible for suitable notices, consent where required, authority to process data, customer privacy requests, workspace permissions, data accuracy, and sector-specific requirements.

2. Information collected

Data may include account and identity details; workspace invitations and roles; tenant branding, domains, catalogues, contacts, records, messages, documents, forms, approvals, audit records, and generated content; subscription plans, invoices, payment status, usage, AI-credit consumption, transaction references, and reconciliation data; AI prompts, files, conversations, outputs, model, cost, and approval metadata; provider identifiers, secure connection metadata, webhooks, and message delivery data; and IP, browser, device, operating system, approximate location, logs, security events, usage, performance, and error information.

Payment providers may process payment credentials. Atuule may receive transaction references, status, and billing information; this policy does not claim Atuule stores raw card details. Credentials and tokens use approved secure server-side flows and are not unnecessarily exposed to generated apps or unauthorised users.

3. Purposes and tenant-data boundaries

Atuule uses information to administer accounts and workspaces; authenticate users and enforce roles and tenant isolation; provide enabled sites, stores, records, correspondence, billing, and modules; store tenant content; process Atuule subscription and add-on payments; enforce usage or AI-credit limits; support users; operate approved AI and integrations; send transactional notices; prevent fraud, abuse, malicious code, and unauthorised access; improve reliability; meet legal duties; and send marketing only where lawfully permitted.

Atuule does not use one tenant’s private customer lists, records, conversations, payment data, or business data to build another tenant’s customer audience or expose cross-tenant insights.

4. Workspace Separation and Security

Each tenant operates in a logically separated workspace. Authentication, roles, permissions, server-side authorisation, database controls, and application controls protect tenant-scoped records. Changing a URL, identifier, or request does not authorise access to another tenant’s private records. Public storefronts expose only deliberately published information; private owner, staff, supplier, customer, payment, and internal records are not public. Generated apps, AI agents, integrations, and connectors receive approved scoped capabilities and must not receive unrestricted database credentials or privileged service access. Atuule personnel do not have unrestricted permission to use tenant data; access is limited to authorised service delivery, tenant-requested support, security and incident response, compliance, or legal purposes and is subject to access controls and auditability. No internet service can guarantee absolute security.

5. Correspondence, WhatsApp, and Telegram

Atuule Correspondence may store messages, participants, timestamps, read state, attachments, delivery information, and audit metadata for the relevant workspace according to tenant roles. Through Atuule’s official WhatsApp Cloud API channel, Meta may process content, identifiers, phone numbers, media references, and delivery metadata; Atuule may use them for support, notifications, or an approved tenant workflow. Availability does not mean every outbound or autonomous capability is enabled.

Telegram may process bot or mini-app interactions, chat identifiers, usernames, and related metadata. Atuule may use them for the specific assistant, onboarding, learning, sourcing, or workspace workflow initiated by the user.

6. Njavwa and AI providers

Njavwa is assistive and AI output may be inaccurate or incomplete. AI proposes, people approve, deterministic code executes. Consequential actions require human approval. Prompts, files, and context may be sent to configured providers to generate responses. Applicable providers vary by active configuration; this policy does not claim every provider or plan excludes training use. Do not submit highly sensitive data without authority and suitable safeguards. Usage may consume credits or allowances and is subject to safety, retention, rate, and cost controls.

7. Integrations and processors

Authorised features may use hosting and database, authentication, payment, email, SMS, WhatsApp, Telegram, AI, analytics, error-monitoring, cloud and deployment, domain and certificate, logistics, or other providers. A tenant may authorise a connection for its workspace and remains responsible for data it directs through the provider. Provider terms also apply. Data is shared only as needed for the authorised feature or action. Integrations may be live, pilot, gated, manual, planned, or unavailable; a visible name does not prove data is being sent.

8. Cookies, consent, analytics, and advertising

Necessary cookies support authentication, security, preferences, and core functionality. Preference cookies remember choices. Optional analytics cookies measure usage and reliability. Optional marketing or advertising technologies operate only when active and permitted by consent and configuration rules. Users can withdraw consent through Cookie Settings or browser controls, although disabling necessary cookies may prevent core functions. Private tenant lists are not pooled for cross-tenant advertising, and tenant advertising assets and audiences remain separated.

9. Retention and deletion

Account and workspace data is kept while active and for a reasonable period afterward; tenant content follows tenant instructions, deletion settings, and plan terms; billing and tax records follow applicable law; security and audit logs support security, fraud, disputes, and legal duties; AI data follows feature and provider settings; backups remain until secure rotation; and legal records remain for required periods. Deletion may be delayed for law, fraud prevention, disputes, backups, security, audit, or others’ rights. Where supported, an authorised tenant administrator may request or complete an export before closure, subject to plan terms, technical limits, identity and authority checks, security requirements, and legal holds. See Terms of Service, Privacy Policy, Data Deletion, Cookie Settings, and Acceptable Use.

10. Rights, children, and sensitive data

Applicable rights may include access, correction, deletion, objection, restriction, portability, withdrawal of consent, information about processing, and complaint or regulatory escalation. Identity verification may be required. A tenant may need to handle requests for data it controls, with Atuule assisting where appropriate. Legal retention, security, contracts, or others’ rights may limit a request.

The public SaaS service is intended for businesses and organisations, not children. Do not upload financial information, identity documents, health or biometric data, children’s data, passwords, authentication secrets, or private customer communications without legal authority, a suitable feature, and required safeguards.

11. Changes, law, and contact

After legal approval, the actual date and version will be recorded. Material changes may be notified through the website, account, or email, with consent obtained where required and prior versions preserved where appropriate. This policy is governed by the laws of the Republic of Zambia, subject to mandatory privacy rights and regulatory requirements, and does not replace a tenant’s own privacy notice or sector obligations.

Privacy requests: privacy@atuule.com. Atuule Marketing Agency Limited, Chitongo Market, Choma–Namwala Road, Namwala, Zambia; P.O. Box 004, Namwala, Zambia; +260 968 373 423.