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.
- Anyone may create an account, including students and other people under 18.
- Under 18, Competition is closed. That includes Daily Guess and weekly competition. Those screens are hidden, and the server refuses the actions.
- Under 18, Apply is closed. A person under 18 cannot open role applications or submit one (artist, advertiser, enterprise, funder, farmer, farm store, marketer, competitor, or witness). The server refuses the application.
- Raffles have no age limit and are not limited to Lesotho. Students may join raffles. Competitions and Daily Guess remain limited to licensed markets (currently Lesotho).
- Music and other features that are not listed above stay available after signup. Some features still need email verification, identity checks, or a paid registration fee, as shown in the app.
- We do not sell personal information.
- You can delete the account in the app (Profile) or at seroto.org/account-deletion.
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:
- Account Information: Name, email address, phone number, username, password, and date of birth (required at any age). Competitions, Daily Guess, and role applications are available only from age 18. Raffles have no age limit.
- Profile Information: Profile picture, bio, artist information, and preferences
- Wallet and payments: Seroto Wallet (Rand) balance, deposits, transfers, cash-back requests, and transaction history. Card data is not stored by Seroto. Cash-in is processed by PayLesotho (M-Pesa / EcoCash) and Lenaka
- Identity Verification: Government ID images, a live face photo, and Didit KYC session results for creators, competitors, and other verified roles
- Device camera: Used only when you start KYC, scan an event ticket, or capture an optional farmer photo. Camera is not required to install or use music listening
- Location Data: Country and region you select on your profile (not continuous GPS tracking) for content delivery, licensed-contest geo-fencing, and local regulations
1.2 Usage Information
We automatically collect information about how you use our services:
- Listening History: Songs played, playlists created, favorites, and download history
- Competition Activity: competition history, preferences, and results (if you participate in our competition features)
- App Usage: Features used, time spent, navigation patterns, and interaction with content
- Device Information: Device type, operating system, unique device identifiers, mobile network information
- Log Data: IP address, browser type, access times, and pages viewed
1.3 Content You Create
If you are a content creator on Seroto:
- Music files, cover art, and metadata you upload
- Enterprise content (documents, media files)
- Comments, reviews, and chat messages
- Role applications and supporting documents
2. How We Use Your Information
We use the collected information for the following purposes:
2.1 Service Delivery
- Provide, maintain, and improve our music streaming services
- Process your transactions and manage your account
- Deliver content recommendations based on your preferences
- Enable competition features and process competition-related activities
- Facilitate communication between users and support staff
2.2 Personalization
- Customize your experience with personalized playlists and recommendations
- Show relevant advertisements based on your interests
- Provide location-specific content and features
2.3 Communication
- Send you notifications about your account, transactions, and app updates
- Respond to your inquiries and provide customer support
- Send promotional materials and special offers (you can opt-out anytime)
- Notify you about competition results and rewards
2.4 Analytics and Improvement
- Analyze usage patterns to improve our services
- Monitor and analyze trends and user preferences
- Calculate creator earnings and royalties
- Generate reports and statistics
2.5 Security and Legal Compliance
- Detect, prevent, and address fraud, security issues, and technical problems
- Verify user identity and prevent unauthorized access
- Comply with legal obligations and enforce our terms of service
- Protect the rights, property, and safety of Seroto, our users, and the public
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:
- Payment processors (mobile money and other payment gateways)
- Cloud storage and hosting providers
- Analytics services
- Customer support tools
- Email and notification services
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:
- Play counts and download statistics
- Revenue and earnings information
- Geographic distribution of listeners
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:
- Comply with legal processes, regulations, or government requests
- Enforce our Terms of Service and other agreements
- Protect the rights, property, or safety of Seroto, our users, or others
- Investigate and prevent fraud or security issues
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:
- Encryption: We use SSL/TLS encryption for data transmission
- Secure Storage: Your data is stored on secure servers with restricted access
- Access Controls: We limit access to personal information to authorized personnel only
- Regular Updates: We regularly update our security measures and conduct security audits
- Password Protection: User passwords are hashed and encrypted
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:
- Know whether we hold your personal information
- Access your personal information (via the app or by request)
- Correct inaccurate or incomplete information
- Object to the processing of your personal information in certain circumstances
- Lodge a complaint with the Information Regulator (South Africa)
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:
- Some information may be retained for legal or legitimate business purposes (see retention schedule)
- Deletion is permanent and cannot be undone
- Certain data may be retained in backup systems for a limited time
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:
- Users under 18 may use the account, including music, the wallet, and raffles. Raffles are not limited to Lesotho.
- Users under 18 cannot use Competition (including Daily Guess and weekly competition). The app hides those modules and the server refuses them.
- Users under 18 cannot apply for extra roles. The Apply module is hidden and the server refuses role applications.
- Raffles have no minimum age.
- Users under 18 on a free plan may still see Seroto advertisements (audio ads before songs, and image ads on home). Basic, Premium, and Farmer plans remove song audio ads. Premium and Farmer also remove home image ads. We do not sell personal information to advertisers.
- Family and homework features can be used from a parent or guardian account.
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:
- PayLesotho (M-Pesa / EcoCash): Wallet cash-in and cash-out in Lesotho
- Lenaka: Wallet cash-in and related partner payments
- Didit: Automated identity verification (ID and liveness)
- Cloud hosting: Application hosting and media storage
- Email and notification services: Transactional messages
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 information | Until account deletion + 5 years | Legal, tax, dispute resolution |
| Transaction history | 7 years | Tax, audit, compliance |
| Competition records | 5 years | Platform compliance |
| Ticket purchase records | 3 years after event | Consumer protection, refunds |
| Usage/analytics data | 2 years (aggregated) | Service improvement |
| Support communications | 3 years | Customer service |
| Backup data | 90 days | Disaster 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:
- A date of birth is required on the account. Competitions, Daily Guess, and role applications require age 18 or older. Raffles have no minimum age and are not limited to Lesotho
- Competitions and Daily Guess are limited to licensed markets (currently Lesotho) until further licences are obtained
- We collect competition history, stakes, results, and related wallet movements
- See Responsible play for harm-minimisation information
- Account deletion is available in the app and at seroto.org/account-deletion (Google Play Data safety)
12. Creator and Enterprise Users
If you are a content creator or enterprise user:
- We collect additional information for verification and payment purposes
- Your content and associated metadata are stored on our servers
- We track performance metrics to calculate earnings and royalties
- Your public profile information is visible to other users
- We may feature your content in promotional materials
13. Advertising
Seroto displays advertisements from third-party advertisers. We may use your information to:
- Show relevant ads based on your interests and usage patterns
- Measure ad performance and effectiveness
- Prevent fraudulent ad clicks
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:
- Posting the new Privacy Policy in the app
- Updating the "Last Updated" date at the top of this policy
- Sending you a notification through the app or email
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):
- Right to know what personal information is collected
- Right to know whether your personal information is sold or disclosed
- Right to say no to the sale of personal information
- Right to access your personal information
- Right to request deletion of your personal information
- Right to non-discrimination for exercising your privacy rights
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):
- Right of access to your personal data
- Right to rectification of inaccurate data
- Right to erasure ("right to be forgotten")
- Right to restrict processing
- Right to data portability
- Right to object to processing
- Right to withdraw consent
To exercise these rights or if you have questions about data processing, contact us at support@seroto.org.