Privacy Policy

Last updated: March 6, 2026

Effective Date: March 6, 2026

1. Introduction

SparkSync Investments Pty Ltd (“SparkSync”, “we”, “us”, or “our”), a private company duly registered with the Ministry of Commerce, Industry and Trade of the Kingdom of Eswatini, operates the LusitoHub platform, including the website located at lusitohub.com, mobile applications, APIs, and related services (collectively, the “Platform” or “Services”).

This Privacy Policy explains how we collect, use, disclose, store, protect, and otherwise process personal information when you access or use the Platform, interact with our services, communicate with us, or when we obtain information about you from third parties.

We are committed to protecting your privacy and handling your personal information responsibly in accordance with applicable laws of the Kingdom of Eswatini, including the Data Protection Act (if enacted) and relevant international standards where applicable.

2. Information We Collect

2.1 Information You Provide Directly

When you register, create a profile, post a job, submit a bid, enter into a contract, make or receive a payment, contact support, or otherwise interact with the Platform, we may collect:

• Full name, email address, phone number, physical address
• Profile information (photo, bio, skills, vehicle details, certifications)
• Identification documents (ID/passport, driver’s license, vehicle registration – for verification)
• Payment information (mobile money number, transaction references – processed via third-party gateways)
• Job details (pickup/drop-off locations, description, photos, budget, dates/times)
• Communications between you and other users or support (messages, reviews, disputes)
• Any other information you voluntarily provide

2.2 Information Collected Automatically

When you use the Platform, we automatically collect certain technical and usage information, including:

• Device information (IP address, device type/model, operating system, browser type/version)
• Log data (access times, pages viewed, features used, errors/crashes)
• Location data (approximate location derived from IP, precise location if you enable GPS and consent)
• Cookies and similar technologies (see our separate Cookie Policy)
• Usage patterns (time spent, clicks, scrolls, searches performed)

2.3 Information from Third Parties

We may receive information about you from:

• Third-party verification services (for identity, driver’s license, vehicle checks)
• Payment processors (MTN MoMo transaction confirmations)
• Social media or Google login (if you choose to sign in via these services)
• Referrers (if someone refers you to the Platform)
• Publicly available sources or partners (for fraud prevention)

3. How We Use Your Information

We use the collected information for the following purposes:

• To provide, maintain, and improve the Platform and Services
• To verify your identity and eligibility to use certain features
• To facilitate connections between Clients and Providers
• To process payments, hold funds in escrow, and release payments
• To send transactional communications (booking confirmations, job updates, payment receipts)
• To send service-related notifications and marketing messages (with consent where required)
• To detect, prevent, and respond to fraud, abuse, security incidents, or illegal activity
• To comply with legal obligations, respond to lawful requests, and protect our rights
• To conduct research, analytics, and product development (using aggregated/anonymized data where possible)
• To enforce our Terms of Service, resolve disputes, and administer our policies

4. Sharing Your Information

We do not sell your personal information. We may share it only in these limited circumstances:

• With other users – only the information necessary to facilitate a job (name, phone, pickup/drop-off details, profile photo, ratings)
• With service providers – third parties who help us operate the Platform (hosting, analytics, payment processors, SMS providers, identity verification services) under strict confidentiality agreements
• For legal reasons – when required by law, court order, regulatory authority, or to protect our rights, safety, or property
• In business transfers – if we undergo merger, acquisition, or sale of assets, your information may be transferred (with notice where required)
• With your consent – for any other purpose you explicitly agree to

5. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this policy, or as required by law:

• Account data – retained while your account is active + 2 years after closure (for legal/tax purposes)
• Transaction/escrow data – retained for 7 years (financial record-keeping)
• Job-related data – retained for 5 years after completion (dispute resolution, ratings)
• Verification documents – deleted 90 days after verification or account closure (unless legally required longer)
• Analytics data – retained in aggregated form indefinitely

6. Your Privacy Rights

Depending on applicable law, you may have the following rights regarding your personal information:

• Access – request a copy of the data we hold about you
• Correction – request correction of inaccurate or incomplete data
• Deletion – request deletion of your data (subject to legal retention obligations)
• Restriction – request restriction of processing in certain circumstances
• Objection – object to processing based on legitimate interest or for direct marketing
• Portability – receive your data in a structured, machine-readable format
• Withdraw consent – where processing is based on consent

To exercise any of these rights, contact us at privacy@lusitohub.com. We will respond within 30 days (or longer if permitted by law). We may require identity verification before processing requests.

7. International Data Transfers

Your personal information may be transferred to, stored, or processed in countries outside Eswatini, including by our service providers (e.g., cloud hosting in South Africa, United States, or Europe). We ensure appropriate safeguards are in place (e.g., standard contractual clauses) to protect your data in accordance with this policy and applicable law.

8. Security of Your Information

We implement reasonable technical, administrative, and physical safeguards to protect your personal information from unauthorized access, loss, misuse, alteration, or destruction. However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

9. Children’s Privacy

Our Services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children under 18. If we become aware that we have collected such information, we will take steps to delete it.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The revised version will be posted here with an updated “Last updated” date. Material changes will be notified via in-app message, email, or prominent notice on the Platform.

Your continued use of LusitoHub after any changes constitutes acceptance of the revised policy.