Privacy Policy – Afrosmeet Zambia

Last updated: 3 October 2026

1. Data Controller

Afrosmeet is operated by LBT Synergy, located at 34 avenue des Champs-Élysées, 75008 Paris, France.
LBT Synergy acts as the Data Controller under Zambia's Data Protection Act, 2021 (Act No. 3 of 2021) and under the GDPR.
Contact: contact@afrosmeet.com

2. Applicable Law & Scope

This Privacy Policy applies to all users in Zambia and to members of the Zambian and wider African diaspora who use Afrosmeet. We comply with:

• Zambia's Data Protection Act, 2021 (Act No. 3 of 2021) and its regulations, including the Data Protection (Registration and Licensing) Regulations, 2021.
• GDPR — General Data Protection Regulation (EU) 2016/679, applicable to our EU operations and data transfers.

Where both laws apply, we apply the stricter standard to ensure full protection of your personal data.

3. Personal Data Collected

• Identity and contact details provided during registration (name, email address, age).
• Profile information, photos, bio and dating preferences you choose to share.
• Identity verification photo (mandatory, deleted immediately after validation).
• Geolocation data, only with your explicit consent, to suggest nearby profiles.
• Messages exchanged between matched members.
• Usage data, device information, IP address and technical logs for security and stability.
• Payment data — processed exclusively by Apple App Store or Google Play. Afrosmeet does not store any banking or mobile money (Airtel Money, MTN MoMo) information.

4. Purpose of Processing

• Creating and managing your account, and enabling matching and messaging features.
• Verifying profiles and moderating the platform against fake accounts, scammers and prohibited content.
• Improving app performance, usability and functionality.
• Sending activity-related notifications (with your consent).
• Complying with legal obligations.

5. Legal Basis for Processing

• Consent — for geolocation, push notifications and non-essential cookies. You may withdraw consent at any time.
• Contractual necessity — to provide the core Afrosmeet service (account creation, matching, messaging).
• Legitimate interest — for moderation, fraud prevention, platform safety and service improvement.
• Legal obligation — where processing is required by Zambian or French law.

6. Sensitive Personal Data

Some information you may choose to share on your profile (for example about your religious beliefs) can be considered sensitive personal data under the Data Protection Act, 2021 (Act No. 3 of 2021). Such data is processed only with your explicit consent, protected with enhanced security measures, and used solely to improve matching relevance. You can remove it from your profile at any time.

7. Data Sharing & International Transfers

We do not sell your personal data. It may be shared only with:

• Technical service providers — cloud hosting (AWS, EU servers), push notifications (Firebase/Google), payments (Apple/Google).
• Competent authorities — only where required by law.

Afrosmeet's servers are located outside Zambia, in the European Union, which is subject to the GDPR. Transfers of personal data outside Zambia are carried out in accordance with Part VIII of the Data Protection Act, 2021 (Act No. 3 of 2021): with your consent, under safeguards approved by or with the authorisation of the Data Protection Commissioner where required, and with appropriate technical and organisational safeguards. Sensitive personal data is only transferred where the Act permits it.

8. Data Security, Breaches & Retention

We implement appropriate technical and organisational measures (HTTPS/TLS encryption, restricted access, secure AWS hosting) to protect your personal data. In the event of a personal data breach, we will notify the Data Protection Commissioner and, where required, affected users, within the time limits set by the Act.

• Active account: data retained for the duration of your account activity.
• Inactive account: data deleted or anonymised after 12 months of inactivity.
• After deletion: data erased within 30 days, except where legal retention is required (max. 5 years).
• Verification photo: deleted immediately after profile validation.

9. Your Rights

Under the Data Protection Act, 2021 (Act No. 3 of 2021) and the GDPR, you have the right to:

• Be informed about how your personal data is used, and obtain confirmation of whether it has been processed.
• Access the personal data we hold about you.
• Correct inaccurate or incomplete data.
• Delete your account and personal data.
• Object to processing, including processing based on legitimate interest.
• Not be subject to decisions based solely on automated processing that significantly affect you.
• Data portability — receive your data in a structured, machine-readable format.
• Withdraw consent for geolocation, cookies or notifications at any time.
• Complain to the relevant supervisory authority (see Section 10).

To exercise your rights, contact us at contact@afrosmeet.com. We respond without undue delay and within the time limits required by applicable law.

10. Supervisory Authorities

• Office of the Data Protection Commissioner (ODPC)
  Established under the Data Protection Act, 2021 (Act No. 3 of 2021), within the Ministry responsible for communications.
• CNIL (France / EU)
  3 place de Fontenoy, TSA 80715 — 75334 Paris Cedex 07, France
  Website: www.cnil.fr

11. Cookies

Afrosmeet uses essential cookies required for platform functionality. Analytics cookies (Google Analytics / GTM) and advertising pixels (Meta Pixel) are deposited only with your explicit consent.

12. Minors

Afrosmeet is exclusively for adults aged 18 and over. We do not knowingly collect personal data from children. Accounts found to belong to persons under 18 will be deleted immediately. To report a minor: contact@afrosmeet.com

13. Changes to This Policy

This Privacy Policy may be updated from time to time. Material changes will be communicated via the app or by email.

14. Contact

LBT Synergy — Data Controller
34 avenue des Champs-Élysées, 75008 Paris, France
contact@afrosmeet.com