Privacy Policy

Last Updated: 26 September 2026

Welcome to Seroto. We are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, share, and protect your information when you use our mobile application and services.

This policy complies with the Protection of Personal Information Act, 2013 (POPIA) of South Africa and the data-protection expectations applicable in Lesotho, where Pen Tech Center (Pty) Ltd operates Seroto.

Important: By using Seroto, you agree to the collection and use of information in accordance with this policy. If you do not agree with our policies and practices, please do not use our services.

Who may use Seroto

Seroto is a general-audience app published by Pen Tech Center (Pty) Ltd (Lesotho), Android package com.seroto.app.seroto. It is not a child-directed app. A date of birth is required on every account so these rules can be applied.

Information Officer (POPIA)

In compliance with POPIA, we have designated an Information Officer responsible for overseeing data protection compliance:

Information Officer
Email: info@seroto.org
For data subject requests, complaints, or enquiries regarding your personal information, please contact the Information Officer.

1. Information We Collect

1.1 Personal Information

When you register and use Seroto, we may collect the following personal information:

1.2 Usage Information

We automatically collect information about how you use our services:

1.3 Content You Create

If you are a content creator on Seroto:

2. How We Use Your Information

We use the collected information for the following purposes:

2.1 Service Delivery

2.2 Personalization

2.3 Communication

2.4 Analytics and Improvement

2.5 Security and Legal Compliance

3. Information Sharing and Disclosure

We do not sell your personal information. We may share your information in the following circumstances:

3.1 Service Providers

We work with third-party service providers who assist us in operating our platform:

These service providers have access to your information only to perform tasks on our behalf and are obligated to protect your information.

3.2 Content Creators and Rights Holders

We share aggregated, anonymized data with content creators about how their content is consumed, including:

3.3 Advertisers

We may share aggregated, non-personally identifiable information with advertisers to help them understand their audience. We do not share personal information that directly identifies you with advertisers.

3.4 Legal Requirements

We may disclose your information if required by law or if we believe such action is necessary to:

3.5 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity. We will notify you of any such change in ownership.

4. Data Storage and Security

We implement appropriate technical and organizational measures to protect your personal information:

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

5. Your Rights and Choices (Including POPIA Rights)

Under POPIA and this policy, you have the right to:

5.1 Access and Update

You can access and update your personal information through your account settings in the app at any time. You may also request a copy of your data via the "Export Data" feature or by contacting the Information Officer.

5.2 Data Deletion

You can request deletion of your account and associated data by contacting us at support@seroto.org or using the app's "Delete Account" feature. Please note that:

5.3 Marketing Communications

You can opt-out of promotional emails by clicking the "unsubscribe" link in any marketing email or adjusting your notification preferences in the app.

5.4 Location Services

You can control location permissions through your device settings. Disabling location services may limit certain features of the app.

5.5 Cookies and Tracking

You can control cookie settings through your browser settings. Note that disabling cookies may affect your ability to use certain features.

5.6 Complaints to the Information Regulator

If you are not satisfied with our response, you may lodge a complaint with the South African Information Regulator: https://www.justice.gov.za/inforeg/

6. Children's Privacy

Seroto is a general-audience service, not a service directed at children. Anyone may create an account. We use the date of birth on the account as follows:

Parents or guardians with questions about a student's account can contact the Information Officer at info@seroto.org.

7. Third-Party Services and Links

Our app may contain links to third-party websites or services that are not operated by us. We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party services you access through our app.

Third-Party Services We Use:

8. International Data Transfers

Your information may be transferred to and maintained on servers located outside of your country of residence, where data protection laws may differ. By using Seroto, you consent to the transfer of your information to other countries.

9. Lawful Processing (POPIA Conditions)

We process your personal information in accordance with POPIA's eight conditions for lawful processing:

9.1 Accountability

We take responsibility for ensuring compliance with POPIA and this policy.

9.2 Processing Limitation

We process personal information lawfully and in a reasonable manner that does not infringe your privacy. We collect only what is necessary for the purposes stated.

9.3 Purpose Specification

We collect personal information for specific, explicitly defined, and legitimate purposes (service delivery, transactions, support, compliance). We do not use it for incompatible purposes.

9.4 Further Processing Limitation

Further processing (e.g. analytics, improvements) is compatible with the original purpose or permitted by law.

9.5 Information Quality

We take reasonable steps to ensure personal information is complete, accurate, not misleading, and updated where necessary.

9.6 Openness

We maintain documentation of our processing activities and make this policy and related information available to you.

9.7 Security Safeguards

We implement appropriate technical and organisational measures to protect personal information against unauthorised access, loss, or damage (see Section 4).

9.8 Data Subject Participation

You have the right to know whether we hold your personal information, to access it, and to request correction or deletion (see Section 5).

10. Data Retention Schedule

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected and to comply with legal obligations. Our retention schedule includes:

Data Type Retention Period Purpose
Account informationUntil account deletion + 5 yearsLegal, tax, dispute resolution
Transaction history7 yearsTax, audit, compliance
Competition records5 yearsPlatform compliance
Ticket purchase records3 years after eventConsumer protection, refunds
Usage/analytics data2 years (aggregated)Service improvement
Support communications3 yearsCustomer service
Backup data90 daysDisaster recovery

After the retention period, we securely delete or anonymise personal information unless we are required by law to retain it longer.

11. Competition, Daily Guess, and Raffles

These features use real money (Seroto Wallet, in Rand) and are restricted:

12. Creator and Enterprise Users

If you are a content creator or enterprise user:

13. Advertising

Seroto displays advertisements from third-party advertisers. We may use your information to:

Advertisers may use their own tracking technologies. We do not control these technologies or the resulting information.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any significant changes by:

Your continued use of Seroto after any changes indicates your acceptance of the updated Privacy Policy.

15. Your California Privacy Rights

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

To exercise these rights, contact us at support@seroto.org.

16. European Users (GDPR)

If you are in the European Economic Area (EEA), you have rights under the General Data Protection Regulation (GDPR):

To exercise these rights or if you have questions about data processing, contact us at support@seroto.org.

17. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Pen Tech Center (Pty) Ltd trading as Seroto
Lesotho
Email: info@seroto.org
Support: support@seroto.org
Website: https://seroto.org
Account deletion: seroto.org/account-deletion

We will respond to your inquiry within 30 days.