Privacy Policy

Last updated April 20, 2025

Casa Management Solutions ("Casa," "we," "us," or "our") is committed to protecting your privacy and building AI tools that enhance LPG cylinder management while respecting your data.

This Privacy Policy explains how we collect, use, disclose, and process your personal data when you use our Tekeraheza mobile application and related services where Casa acts as a data controller ("Services").

This Privacy Policy does not apply where Casa acts as a data processor and processes personal data on behalf of commercial customers using our business services – for example, if your LPG supplier has provisioned Tekeraheza Enterprise for your organization, or you're using an application that is powered on the back-end with Tekeraheza. In those cases, the commercial customer is the controller, and you can review their policies for more information about how they handle your personal data.

This Privacy Policy also describes your privacy rights. More information about your rights, and how to exercise them, is set out in Section 4 ("Rights and Choices").

Collection of Personal Data
Uses of Personal Data
How We Disclose Personal Data
Rights and Choices
Data Transfers
Data Retention and Security Controls
Children
Changes to Our Privacy Policy
Contact Information
Legal Bases for Processing

1. Collection of Personal Data

We collect the following categories of personal data:

Personal data you provide to us directly

Identity and Contact Data: Casa collects identifiers, including your name, email address, phone number, and account information when you sign up for a Tekeraheza account, or to receive information on our Services. We may also collect or generate indirect identifiers (e.g., "USER12345").
Payment Information: We shall collect your payment information if you choose to purchase access to Tekeraheza's premium features and services.
Cylinder Information and Usage Queries: Our AI-powered cylinder management system allows you to interact with the Services by scanning cylinder QR codes, submitting usage information, and natural language queries ("Inputs"), which generate usage predictions, refill reminders, and other cylinder management assistance ("Outputs") based on your Inputs. If you include personal data or reference external content in your Inputs, we will collect that information and this information may be reproduced in your Outputs.
Location Data: With your permission, Tekeraheza may access your location to provide services such as finding nearby LPG suppliers, delivery tracking, and location-based usage analytics.
Cylinder Scan Data: Information collected when you scan LPG cylinders, including cylinder serial numbers, QR codes, brand information, size specifications, and scan timestamps.
Usage Patterns: Data about your LPG consumption habits, refill frequency, usage predictions, and cylinder management preferences.
Feedback on your use of our Services: We appreciate feedback, including ideas and suggestions for improvement or rating our predictions and recommendations ("Feedback"). If you rate an Output in response to an Input, we will store the entire related interaction as part of your Feedback.
Communication Information: If you communicate with us, including via our support channels, we collect your name, contact information, and the contents of any messages you send.

Personal data we receive automatically from your use of the Services

When you use the Services, we also receive certain technical data automatically (described below, collectively "Technical Information"). This includes:

Device and Environment Information: Your mobile device automatically sends us information about when and how you install, access, or use our Services. This includes information such as your operating system, device model, app version, installed apps (with permission), and other device configurations.
Usage Information: We collect information about your use of the Services, such as the dates and times of access, features used, scan frequency, prediction accuracy metrics, and other information about how you use the Services.
Log and Troubleshooting Information: We collect information about how our Services are performing when you use them. This information includes log files. If you or your app experiences an error, we may collect information about the error, the time the error occurred, the feature being used, the state of the application when the error occurred, and any communications or content provided at the time the error occurred.
Telemetry Data: With your permission, we collect telemetry data about your usage patterns to improve the performance and functionality of the application. You can opt out of telemetry collection in the app settings.

Personal data we collect or receive to train our models

Casa obtains personal data from various sources in order to train our usage prediction and cylinder management models. Specifically, we train our models using data from the following sources:

Publicly available LPG usage patterns and industry data
Datasets that we obtain through commercial agreements with third party businesses
Data that our users or research participants provide with explicit consent
Data that we generate internally

2. Uses of Personal Data

We use your personal data for the following purposes:

To provide, maintain and facilitate the Tekeraheza mobile application and related services offered to you with respect to your Tekeraheza account, which are governed by our Terms of Service;
To provide, maintain and facilitate optional services and features that enhance cylinder management functionality and user experience;
To generate AI-powered predictions about cylinder usage and refill timing;
To send refill reminders and usage notifications;
To provide location-based services such as supplier recommendations and delivery tracking;
To communicate with you, including to send you information about our Services and events;
To create and administer your Tekeraheza account;
To facilitate payments for premium features and services provided by Casa;
To prevent and investigate fraud, abuse, and violations of our Usage Policy, unlawful or criminal activity, unauthorized access to or use of personal data or Casa systems and networks, to protect our rights and the rights of others, and to meet legal, governmental and institutional policy obligations;
To investigate and resolve disputes;
To investigate and resolve security issues;
To debug and to identify and repair errors that impair existing functionality;
To improve the Services and conduct research; and
To enforce our Terms of Service and similar terms and agreements, including our Usage Policy.

We will not use your cylinder scan data, usage patterns, or location information to train our models, unless: (1) your interactions are flagged for Trust & Safety review (in which case we may use or analyze them to improve our ability to detect and enforce our Usage Policy), or (2) you've explicitly reported the materials to us (for example via our feedback mechanisms), or (3) you've otherwise explicitly opted in to the use of your Inputs and Outputs for training purposes. We understand the sensitivity of your usage data and personal information and prioritize your privacy in this regard.

3. How We Disclose Personal Data

Casa will disclose personal data to the following categories of third parties for the purposes explained in this Policy:

Affiliates & corporate partners: Casa discloses the categories of personal data described above between and among its affiliates and related entities.
Service providers & business partners: Casa may disclose the categories of personal data described above with service providers and business partners for a variety of business purposes, including hosting, ensuring compliance with industry standards, research, auditing, data processing, and providing you with the services.
LPG Suppliers and Delivery Partners: With your consent, we may share relevant information with authorized LPG suppliers and delivery partners to facilitate cylinder refills, deliveries, and customer service.

Casa may also disclose personal data in the following circumstances:

As part of a significant corporate event: If Casa is involved in a merger, corporate transaction, bankruptcy, or other situation involving the transfer of business assets, Casa will disclose your personal data as part of these corporate transactions.
Third-Party Services and Integrations: Our Services may involve integrations with, or may direct you to, other services such as payment processors, mapping services, or other utility applications. By interacting with these third parties, you are providing information directly to the third party and not Casa and subject to the third party's privacy policy. Our linking to another service doesn't mean we endorse it or speak for that third party.
Pursuant to regulatory or legal requirements, safety, rights of others, and to enforce our rights: We may disclose personal data to governmental regulatory authorities as required by law, including for legal, tax or accounting purposes, in response to their requests for such information or to assist in investigations. We may also disclose personal data to third parties in connection with claims, disputes or litigation, when otherwise permitted or required by law, or if we determine its disclosure is necessary to protect the health and safety of you or any other person, to protect against fraud or credit risk, to enforce our legal rights or the legal rights of others, to enforce contractual commitments that you have made, or as otherwise permitted or required by applicable law.
With an individual's consent: Casa will otherwise disclose personal data when an individual gives us permission or directs us to disclose this information, including as a part of our Services.

4. Rights and Choices

Depending on where you live and the laws that apply in your country of residence, you may enjoy certain rights regarding your personal data, as described further below. However, please be aware that these rights are limited, and that the process by which we may need to action your requests regarding our training dataset are complex. We may also decline a request if we have a lawful reason for doing so.

To exercise your rights, you or an authorized agent may submit a request by emailing us at privacy@casamanagementsolutions.com. After we receive your request, we may verify it by requesting information sufficient to confirm your identity. Casa will not discriminate based on the exercising of privacy rights you may have. Set out below is a summary of the rights which you may enjoy, depending on the laws that apply in your country of residence.

Right to know: the right to know what personal data Casa processes about you, including the categories of personal data, the categories of sources from which it is collected, the business or commercial purposes for collection, and the categories of third parties to whom we disclose it.
Access & data portability: the right to request a copy of the personal data Casa processes about you, subject to certain exceptions and conditions. In certain cases and subject to applicable law, you have the right to port your information.
Deletion: the right to request that we delete personal data collected from you when you use our Services, subject to certain exceptions. You also are able to clear your usage history through the app settings, which will be removed from your history and automatically deleted from our back-end within 30 days.
Correction: the right to request that we correct inaccurate personal data Casa retains about you, subject to certain exceptions. Please note that we cannot guarantee the accuracy of usage predictions. If Outputs contain inaccurate information relating to you, you can submit a correction request and we will make a reasonable effort to correct this information.
Objection: the right to object to processing of your personal data, including profiling conducted on grounds of public or legitimate interest. In places where such a right applies, we will no longer process the personal data in case of such objection unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or for the establishment, exercise or defense of legal claims. If we use your information for direct marketing, you can object and opt out of future direct marketing messages using the unsubscribe link in such communications.
Restriction: the right to restrict our processing of your personal data in certain circumstances.
Withdrawal of consent: Where Casa's processing of your personal data is based on consent, you have the right to withdraw your consent. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.
Automated decision-making: Casa does not engage in decision making based solely on automated processing or profiling in a manner which produces a legal effect (i.e., impacts your legal rights) or significantly affects you in a similar way.

5. Data Transfers

When you access our Services, your personal data may be transferred to our servers, or to other countries outside your home country. This may be a direct provision of your personal data to us, or a transfer that we or a third party make.

Where required by applicable law, we ensure sufficient data protection safeguards for international transfers of data through appropriate legal frameworks, such as standard contractual clauses or adequacy decisions where available.

6. Data Retention and Security Controls

Casa retains your personal data for as long as reasonably necessary for the purposes outlined in this Privacy Policy.

When the personal data collected is no longer required by us, we and our service providers will perform the necessary procedures for destroying, deleting, erasing, or converting it into an anonymous form as permitted or required under applicable laws.

User-Generated Data Ownership

All data, including usage patterns, cylinder information, and other content created through the Tekeraheza application:

Belongs to the users who have full rights to control, modify, and use such data as they see fit.
Is also licensed to Casa Management Solutions, granting us the right to use, reproduce, modify, and distribute such content for purposes related to improving our services, with the following limitations: a. We will never claim ownership of your personal usage data or cylinder information. b. We will respect the privacy of your consumption patterns and usage habits. c. We will anonymize any data used for service improvement.
When using user-generated data, Casa Management Solutions will respect users' privacy and will not unnecessarily disclose personally identifiable information or proprietary usage patterns.
Casa Management Solutions reserves the right to showcase anonymized examples of usage predictions and cylinder management features as examples of the platform's capabilities, unless a user has explicitly opted out of such usage.

Aggregated or De-Identified Information

We may process personal data in an aggregated or de-identified form to analyze the effectiveness of our Services, conduct research, study user behavior, and train our AI models as permitted under applicable laws. For instance:

When you submit Feedback, we disassociate Inputs and Outputs from your user ID to use them for training and improving our models.
If our systems flag Inputs or Outputs for potentially violating our Usage Policy, we disassociate the content from your user ID to train our trust and safety internal classification and generative models. However, we may re-identify the Inputs or Outputs to enforce our Usage Policy with the responsible user if necessary.
To improve user experience, we may analyze and aggregate general user behavior and usage data. This information does not identify individual users.

Security Controls

We implement appropriate technical and organizational security measures designed to protect personal data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. These measures include:

Encryption of sensitive data in transit and at rest
Regular security assessments of our systems
Access controls and authentication requirements for our systems
Secure development practices for our application and services

7. Children

Our Services are not directed towards, and we do not knowingly collect, use, disclose, sell, or share any information about, children under the age of 18. If you become aware that a child under the age of 18 has provided any personal data to us while using our Services, please email us at privacy@casamanagementsolutions.com and we will investigate the matter and, if appropriate, delete the personal data.

8. Changes to Our Privacy Policy

Casa may update this Privacy Policy from time to time. We will notify you of any material changes to this Privacy Policy, as appropriate, and update the Effective Date at the top. You can view a summary of privacy policy changes and previous versions by contacting us.

9. Contact Information

If you have any questions about this Privacy Policy, or have any questions, complaints or requests regarding your personal data, you can contact us as described below:

Casa Management Solutions
Kampala
Kampala, Sir Apollo Kaggwa Road, 256
Uganda
Email: privacy@casamanagementsolutions.com
Website: www.casamanagementsolutions.com
Hours: Mon. - Fri. 8AM - 6PM

Please note that under many countries' laws, you have the right to lodge a complaint with the supervisory authority in the place in which you live or work.

10. Legal Bases for Processing

Purpose	Type of Data	Legal Basis
To provide, maintain and facilitate the Tekeraheza mobile application and related services	Identity and Contact Data, Payment Information, Feedback, Cylinder Information and Usage Queries, Location Data	Contract
To provide, maintain and facilitate optional services and features that enhance cylinder management functionality	Identity and Contact Data, Feedback, Cylinder Information and Usage Queries, Location Data	Legitimate interests: It is in our and our users' legitimate interests to expand our product features and deliver additional services that enhance cylinder management functionality and user experience.
To communicate with you, including to send you information about our Services and events	Identity and Contact Data, Communication Information, Technical Information	Where necessary to perform a contract with you. Your consent when we ask for it to process your personal data for a specific purpose that we communicate to you.
To create and administer your Tekeraheza account	Identity and Contact Data, Payment Information, Feedback	Contract
To facilitate payments for premium features and services provided by Casa	Identity and Contact Data, Payment Information	Contract
To prevent and investigate fraud, abuse, and violations of our Usage Policy	Identity and Contact Data, Payment Information, Cylinder Information and Usage Queries, Technical Information	Legitimate interests, Legal obligation: It is our legitimate interest to protect our business, employees and users from illegal activities, inappropriate behavior or violations of terms that would be detrimental. We also have a duty to cooperate with authorities.
To investigate and resolve disputes	Identity and Contact Data, Cylinder Information and Usage Queries, Feedback	Legitimate interests, Legal obligation: It is our legitimate interest to fully understand and make reasonable efforts to resolve customer complaints in order to improve user satisfaction. We also have a legal obligation in some cases.
To investigate and resolve security issues	Identity and Contact Data, Feedback, Technical Information, Cylinder Information and Usage Queries	Legal obligation, Legitimate interests: It is our legitimate interest to protect user data and our systems from intrusion or compromise through monitoring and swift response. We also have a legal obligation to provide adequate security safeguards.
To debug and to identify and repair errors that impair existing functionality	Identity and Contact Data, Feedback, Technical Information	Legitimate interests: It is our legitimate interest to maintain continuous functioning of our services and rapid correction of problems to ensure a positive user experience that encourages engagement.
To improve the Services and conduct research	Identity and Contact Data, Feedback, Technical Information, Cylinder Information and Usage Queries	Legitimate interests: It is our legitimate interest and in the interest of Casa users to evaluate the use of the Services and adoption of new features to inform the development of future features and improve direction and development of the Services.
To improve the Services and conduct research (including model training)	Feedback (which may include Cylinder Information and Usage Queries), Inputs and Outputs flagged for Trust & Safety review	Consent (when users submit Feedback), Legitimate interests (for trust and safety purposes): It is our legitimate interest and in the interest of Casa users to evaluate the use of the Services and adoption of new features to inform the development of future features and improve direction and development of the Services.
To enforce our Terms of Service and similar terms and agreements, including our Usage Policy	Identity and Contact Data, Cylinder Information and Usage Queries, Technical Information	Contract, Legitimate interests: In certain circumstances outside of the performance of our contract with you, we may rely on legitimate interests. It is our legitimate interest to enforce the rules and policies governing use of our services, to maintain intended functionality and value for users. We aim to provide a safe, useful platform.