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Kwata TV

Privacy notice

Draft: this text contains highlighted items that the service owner or their counsel must complete. It has not been validated and must not be published as it stands.

Effective date: [TO COMPLETE: date]

This text explains, in plain language, which personal data Kwata TV records, why, for how long, who receives it and how to exercise your rights. It describes what the service does today.

Who is responsible for your data

The service is published by: [TO COMPLETE: name or company name, legal form, registration number and address of the publisher]. Its full details are in the legal notice.

For any question about your data: Write to support on WhatsApp. [TO COMPLETE: dedicated contact address for personal data, if there is one]

The data we record

This is everything the service records about you.

  • Your email address. It is your login. It is not verified and the service never writes to you.
  • Your password, only as a fingerprint (a one-way transformation). We cannot read it back.
  • Your recovery code, only as an irreversible fingerprint. Each code is shown to you only once: when you sign up, then each time there is a new code (one you ask for in "My account", or one created when you recover your account).
  • The country you choose, the Mobile Money number that pays and the operator you chose. The number is written in international format (your country's code, for example +237 or +254, then the number). They are asked for when you pay; the country and the last number used are kept with your account to pre-fill your next payment (the country is saved only when you start a payment). As soon as you have entered the number in full, it is also sent to our payment provider (see "Who receives your data") to suggest the likely operator and to check that it belongs to the country you chose, before any payment; the service does not keep that request. Payment tracking and the team's lists show the number masked, for example "+237 6•• •• 34 56".
  • Your payment history: amount, date, status and the payment reference (the operator's transaction identifier, or the payment's identifier at our payment provider; this reference helps us help you when something goes wrong). There is no payment code to enter on the site: you approve the PIN request on your phone, and the service never sees that PIN.
  • Your access periods: the start and end of each period granted.
  • Your device: a technical identifier of your browser (kept as a fingerprint), the dates it was first and last used, and a very general label made of the browser family and the system family (nothing more). Your full browser identifier is not kept.
  • Your sign-in session: the fingerprint of the session token, the start and last-activity dates, and the device concerned.
  • Your language (French or English).
  • The channel being played: for each account the service remembers the last playback started, so that only one viewer at a time is allowed. This is replaced at each new playback. There is no history of what you watch.
  • Security records: a log of important actions (sign-up, sign-in and failed sign-ins, password or email changes, account recovery, payment, access granted) with the date, the internal identifier of your account and a request identifier. Your IP address is not written to the database; at most, some security records keep an irreversible fingerprint of it.
  • Your exchanges with support: if you write to support on WhatsApp, we receive your WhatsApp number and your message; WhatsApp processes them under its own terms. [TO COMPLETE: how long support conversations are kept]
  • Temporary counters against abuse: to limit mass sign-ups and sign-in attempts, the service briefly counts requests per IP address, in a temporary memory, for the length of the limit (a day at most).
  • Your IP address, to guess your country. When you open the home page or the payment screen, the service looks up which country your IP address is in, using a database installed on its own servers, to suggest that country to you and to show the price for that country. Nothing is sent to a third party for this, the guessed country is not stored, the address is not kept for this (the technical logs described below follow their own rules) and no cookie is set for it. You can always change the country.
  • Your device, during a free-access period. A random identifier is created for your device when you watch without an account. The service counts how many devices watched during the period, without keeping which device watched which channel; the identifier is deleted at the end of the period. Your IP address is not kept for this (the technical logs described below have their own rules).
  • Technical server logs, which may contain your IP address (see "How long we keep your data").

The service does not ask for your name, date of birth, an identity document, your location or your contacts. To protect itself from robots it uses a computing challenge hosted by the service itself: it runs on your device, with no third-party service and no tracking.

What this data is used for

  • Creating and protecting your account, and recognising you when you come back.
  • Applying the rule of one active device and one viewer per account.
  • Collecting your Mobile Money payments, checking that they are really confirmed, and giving you your access period.
  • Helping you when something goes wrong: account recovery, a payment charged without access.
  • Protecting the service against abuse (robots, mass-created accounts, hacking attempts) and keeping a record of important actions.
  • Running and improving the service: the capacity it needs, and the order of the channels by the number of minutes watched, an overall figure that holds no information about any person.

[TO COMPLETE: legal basis for each purpose, under the law applicable in each country where payment is open]

Cookies and local storage

The service only uses cookies that are needed for it to work or for a choice you make. It shows no third-party advertising (the publisher may only broadcast its own videos on the channels), uses no audience-measurement tool and no third-party tracker, so the site does not show a cookie-choice banner. [TO COMPLETE: review of this sentence by the publisher's counsel (third-party advertising, the publisher's own videos)] If you browse the catalogue without an account, the site sets no cookie (except the language one, if you change language, and the device one described below if you ask to watch for free during a free-access period).

  • __Host-session: keeps you signed in. It holds only a random token, unreadable by the page's code. Set when you sign up or sign in; it lasts 30 days at most (7 days without activity) and is removed when you sign out.
  • __Host-csrf_token: protects your actions against booby-trapped forms. The page reads it to sign your requests, and it lasts as long as the session.
  • __Host-device_id: recognises your browser as your active device (one active device per account). Set when you sign up or sign in; it lasts 400 days and stays after you sign out.
  • NEXT_LOCALE: remembers the language you chose (French or English). Set only when you change language; it lasts one year.
  • __Host-guest_id: set only if you ask to watch without an account during a free-access period. It recognises your device so as to give you one stream at a time, and it is also used to count how many different devices watched during the period (an overall figure, without keeping which device watched which channel); it disappears at the end of the period (at most 2 days). [TO COMPLETE: decision by the publisher's counsel: are both uses strictly necessary for the service asked for, or does counting devices require consent?]

The attack-protection provider through which the site's traffic passes (see "Who receives your data") may set its own cookies on your browser: they are not in this list. [TO COMPLETE: check with the provider which cookies it sets, how long they last and what they are for, then list them here; if it sets one that measures audience or tracks visitors, also correct the start of this section (no tracker, no choice banner)]

The service also keeps one setting in your browser's local storage: the player's "data saver" mode (key kwata.player.dataSaver). It stays on your device, is never sent to the service, and you can erase it at any time from your browser settings.

How long we keep your data

  • Account with no payment and no access: an account that never started a payment, never received access and is not blocked is deleted automatically after 90 days with no activity at all (sign-in, password change…). No message is sent beforehand, since the service sends no email or SMS; you can simply sign up again. [TO COMPLETE: confirm, before publishing this sentence, that automatic deletion is enabled in production]
  • Account with a payment (even a failed or expired one), with access, or blocked: it is never deleted automatically. [TO COMPLETE: retention period and conditions for deletion at the user's request]
  • Payments, access granted and the log of important actions: kept; the service does not delete them automatically. [TO COMPLETE: retention period required by law for payment records and logs]
  • Sessions and device: a session stays valid 30 days at most; the device cookie, 400 days. Records of expired sessions and of devices stay linked to the account as long as it exists.
  • Technical server logs (which may contain your IP address): 14 days. Our providers' logs follow their own rules. [TO COMPLETE: log retention at the host and at the protection provider]
  • Audience figures per channel (minutes watched, with no personal information): 35 days.
  • Saved country: kept with your account, it goes away with it.
  • Device identifier of a visitor without an account: deleted at the end of the free-access period.

Who receives your data

  • The service team: authorised people, for support and security; depending on their role, they see your email address and your payment number in full or only masked, and lists show the number masked. Every sensitive action is recorded.
  • Our Mobile Money payment provider. To suggest the likely operator for your number and to check its country (as soon as you have entered it in full, before any payment), then to collect the payment, it receives your payment number, your operator, the amount (in your country's currency) and an internal payment reference. It does not receive your email address. It sends us back the status of the payment. [TO COMPLETE: identity, country and privacy policy of the payment provider]
  • Your Mobile Money operator, which sends the PIN request to your phone and carries out the payment through our payment provider.
  • WhatsApp, if you write to support through that channel: your message and your WhatsApp number go through that service. [TO COMPLETE: operator and terms that apply to the support's WhatsApp Business number]
  • The server host: [TO COMPLETE: host name and country of the servers, to confirm when the servers are ordered; planned: Netherlands].
  • The attack-protection provider: the traffic of the site and of the API goes through this provider, which relays it to our servers and therefore sees requests and IP addresses. [TO COMPLETE: company, country and retention at this provider, to confirm with the provider]
  • Authorities, if the law requires us to give them data. [TO COMPLETE: legal framework and procedure]

The supplier of the television signals receives no data about you: it only sees the service's connections. The service contains no advertising, statistics or error-tracking tool supplied by a third party: no data is sent to advertisers or to analytics services.

Transfers outside your country

The servers, the protection provider and the payment provider may be outside your country. [TO COMPLETE: countries concerned and safeguards that apply to data transfers]

Security

  • Exchanges with the site and the API are encrypted (HTTPS).
  • Your password, your recovery code and your session tokens are only kept as irreversible fingerprints.
  • Access to data is limited to the people who need it; your data can only be read by your own account on the user side, and the team's sensitive actions are recorded.
  • Abuse attempts are limited automatically.

No system is infallible. [TO COMPLETE: procedure for informing users and the authorities after an incident, under the applicable law]

Your rights and how to exercise them

You can manage some things yourself from "My account": change your email address and your password, get a new recovery code, choose your language and sign out.

For the rest (getting a copy of your data, having it corrected, asking for your account to be deleted, asking a question), write to support: Write to support on WhatsApp. Deleting your account yourself does not exist yet: it goes through support.

[TO COMPLETE: list of the rights recognised by the applicable law, identity-verification procedure and reply time]

Complaints

If you think your data is not handled properly, you can write to us first. You can also contact the competent authority: [TO COMPLETE: data protection authority of each country where payment is open, or the publisher's].

Minimum age

[TO COMPLETE: minimum age to use the service and rules that apply to minors]

Changes to this text

We may change this text. The effective date is at the top of the page. [TO COMPLETE: how users are told about an important change]