Privacy Policy

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Effective Date: 12/02/2026

1. Introduction

Ubaba ("we," "our," "or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our websites www.ubaba.net or www.ubaba.pro, or use our marketplace services.

By using our platform, you consent to the data practices described in this policy.

2. Information We Collect

To provide our services, including Talent Vetting and AI-powered matching, we collect the following types of information:

A. Personal Identification Information

• Registration Data: Name, email address, phone number, and physical address when you sign up as a Client or Freelancer.

• Profile Data: For Freelancers, we collect professional portfolios, skills, work history, and photos.

B. Sensitive Personal Data (Verification)

To maintain our Trust & Verification standards and assign Pro/Standard tiers, we collect sensitive personal data from Freelancers, including:

• National Registration Cards (NRC) or Passports.

• Trade certificates, licenses, and educational qualifications.

• Background check information.

C. Payment and Transaction Data

• To facilitate Escrow protection and subscription fees, we collect transaction details.

• Note: We do not store sensitive credit card information on our servers. All financial transactions are processed through secure third-party payment gateways.

D. Usage and AI Data

• We collect data on how you interact with the platform (e.g., search history, project clicks) to power our AI recommendations and instant talent matching algorithms.

3. How We Use Your Information

We use the collected data for the following purposes:

1. Service Delivery: To connect Clients with Tradespeople and facilitate projects.

2. Verification: To vet tradespeople (Know Your Customer/KYC) and ensure a safe environment.

3. Payment Processing: To hold funds in Escrow and release them upon milestone completion.

4. Platform Improvement: Using data to train our AI for better matching and to improve our Collaboration Tools.

5. Legal Compliance: To comply with financial regulations and the Data Protection Act.

4. Sharing Your Information

We value Transparency and only share information in the following situations:

• Between Users: When a Client hires a Freelancer, necessary contact and project details are shared.

• Third-Party Service Providers: We may share data with payment processors, ID verification services, or hosting partners.

• Legal Requirements: We may disclose information if required to do so by Zambian law.

5. Data Security

We implement security measures designed to protect your information, including:

• Encryption of data in transit and at rest.

• Strict access controls for our internal team regarding vetting documents (NRCs/Certificates).

• Secure servers for hosting our AI and database infrastructure.

6. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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7. Compliance with the Data Protection Act No. 3 of 2021

Ubaba is a Data Controller as defined under the Data Protection Act No. 3 of 2021 of the Laws of Zambia. We are committed to processing your data lawfully, fairly, and transparently.

7.1 Lawful Basis for Processing

We process your personal data based on:

• Contractual Necessity: Processing is necessary to fulfill the service agreement (connecting Clients and Freelancers).

• Legal Obligation: Processing is necessary for compliance with Zambian financial and tax laws.

• Consent: We obtain your explicit consent before collecting sensitive data (such as NRCs) for vetting purposes.

7.2 Your Rights Under the Act

Under the Data Protection Act No. 3 of 2021, you have the following rights:

• Right of Access: You have the right to request a copy of the personal data we hold about you.

• Right to Rectification: You may request that we correct any inaccurate or incomplete data.

• Right to Erasure (Right to be Forgotten): You may ask us to delete your personal data where there is no good reason for us to continue processing it.

• Right to Object: You may object to the processing of your data for direct marketing purposes.

• Right to Data Portability: You have the right to request the transfer of your personal data to another party.

7.3 Automated Decision Making

Our platform uses AI algorithms to match Freelancers with Clients. While this involves automated processing, significant decisions (such as banning a user or resolving an Escrow dispute) always involve human intervention.

7.4 Complaints

If you believe that Ubaba has not handled your personal data in accordance with the Act, you have the right to lodge a complaint with the Office of the Data Protection Commissioner (ODPC) in Zambia.

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8. Contact Us

If you have questions about this Privacy Policy or wish to exercise your rights under the Data Protection Act, please contact our Data Protection Officer at:

• Ubaba

• Email: admin@ubaba.net

• Address: Plot 11293 Nchoncho Road, Light Industrial Area, Lusaka, Zambia

• Phone: +260 969731477

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