Privacy Policy

Introduction

This Privacy Policy explains how Mbuya Gallery LLC, d/b/a FAMBUL GLOBAL ("FAMBUL GLOBAL," "we," "our," or "us") collects, uses, shares, and protects personal information when you use the FAMBUL GLOBAL website, mobile applications, and related services (collectively, the "Platform"). This Policy applies to Guests, Suppliers (also displayed on the Platform as "Experience Providers"), and other visitors to the Platform, and forms part of our Terms of Service.

For purposes of the EU and UK General Data Protection Regulation (GDPR), Mbuya Gallery LLC, d/b/a FAMBUL GLOBAL, acts as the data controller for personal information processed through the Platform. We comply with applicable U.S. federal and state privacy laws, including the New York SHIELD Act, and with the GDPR and UK GDPR where they apply to a Guest or Supplier located in the European Union or United Kingdom.

Capitalized terms not defined here have the meanings given in the Terms of Service or the Supplier & Experience Provider Agreement, as applicable.

Information We Collect

We collect the following categories of information:

  1. Account information — name, email address, phone number, password, and profile details you provide when creating an account.
  2. Booking information — the Experiences you book or list, booking dates, group size, and related messages between Guests and Suppliers sent through the Platform.
  3. Payment information — billing details necessary to process a booking. Full payment card details are collected and processed by our payment processor, not stored directly by FAMBUL GLOBAL.
  4. Communications — messages you send to FAMBUL GLOBAL, reviews, and support requests.
  5. Media data — photos, videos, or audio recordings taken during an Experience, as described in our Terms of Service.
  6. Device and usage information — IP address, browser type, device identifiers, and how you interact with the Platform, collected automatically.
  7. Location information — where you choose to provide it, such as to find Experiences near you.

How We Use Information

We use personal information to: operate and improve the Platform; process bookings and payments; facilitate communication between Guests and Suppliers; provide customer support; send booking-related and, where permitted, marketing communications; detect and prevent fraud; comply with legal obligations; and enforce our terms and policies.

Lawful Bases for Processing

Where the GDPR or UK GDPR applies, we process personal information under the following lawful bases:

  1. Contract — to process and manage a booking, payment, or your participation as a Supplier.
  2. Consent — for marketing communications, promotional use of media data where separate consent is required, and non-essential cookies.
  3. Legitimate Interests — to keep the Platform secure, prevent fraud, and operate it efficiently.
  4. Legal Obligation — to comply with tax, accounting, and other applicable legal requirements.

How We Share Information

We share personal information in the following circumstances:

  1. With a Supplier, when a Guest books that Supplier's Experience — limited to what the Supplier reasonably needs to fulfill the booking.
  2. With service providers who help us operate the Platform — for example, payment processing, authentication, email delivery, analytics, cloud storage and hosting, fraud prevention, and customer support — under confidentiality and data protection obligations.
  3. Where required by law, regulation, legal process, or governmental request.
  4. In connection with a merger, acquisition, financing, or sale of assets.
  5. With a Guest's or Supplier's consent, or at their direction.

We do not sell personal information to third parties.

Guest Information Shared with Suppliers

When a Guest books an Experience, FAMBUL GLOBAL shares the information reasonably necessary for the Supplier to fulfill that booking. Under the Supplier & Experience Provider Agreement, Suppliers are prohibited from using Guest Information to build a marketing database, selling or transferring it to third parties, or retaining it beyond what is necessary to fulfill the booking. If a Supplier misuses Guest Information, please report it to us using the contact details in the Contact Us section.

Cookies and Tracking Technologies

We use cookies and similar technologies to operate the Platform, remember preferences, and understand how the Platform is used, including:

  1. Essential cookies — required for the Platform to function, such as keeping you logged in or completing a booking.
  2. Analytics cookies — help us understand how the Platform is used so we can improve it.
  3. Marketing and advertising cookies — used, if and when we adopt them (for example, tools such as Google Analytics, Meta Pixel, or similar services), to measure and improve our marketing.

You can control cookies through your browser settings; disabling certain cookies may affect Platform functionality. Where required by law, we will request your consent before setting non-essential cookies.

Data Retention

We retain personal information for as long as necessary to provide the Platform, comply with legal obligations, resolve disputes, and enforce our agreements. Retention periods vary depending on the type of information and the purpose for which it was collected.

Data Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials.

Security Incidents and Breach Notification

If a data breach affecting your personal information occurs, we will notify you and any relevant regulator as required by applicable law, including the New York General Business Law and, where applicable, the GDPR and UK GDPR.

International Data Transfers

FAMBUL GLOBAL is headquartered in the United States, and personal information may be transferred to, stored, and processed in the United States or another country other than the one in which it was collected.

Where we transfer personal information out of the European Union or United Kingdom, we rely on Standard Contractual Clauses or other legally recognized transfer mechanisms, where applicable. By using the Platform, you acknowledge that your personal information may be transferred to and stored in the United States.

Automated Decision-Making

FAMBUL GLOBAL does not make decisions that produce legal or similarly significant effects about you based solely on automated processing.

Your Rights and Choices

Depending on where you live, you may have the right to access, correct, delete, or receive a portable copy of your personal information, and to object to or restrict certain processing. You may update most account information directly through the Platform, or contact us using the details in the Contact Us section to exercise these rights. We will respond to verifiable requests consistent with applicable law.

We may retain certain information notwithstanding a deletion request where required by law, or for tax or accounting purposes, fraud prevention, dispute resolution, or enforcement of our agreements. Residents of California and certain other U.S. states may have additional privacy rights under applicable state law.

You may opt out of marketing communications at any time using the unsubscribe link in those communications or through your account settings. You will still receive booking-related communications necessary to the Platform's operation.

Children's Privacy

The Platform is not directed to children, and we do not knowingly collect personal information from anyone under the age of 18. If you believe a child has provided us with personal information, please contact us so we can take appropriate action.

Changes to this Policy

We may update this Policy from time to time. If we make material changes, we will provide notice through the Platform or by email before the changes take effect. Continued use of the Platform after changes take effect constitutes acceptance of the updated Policy.

Contact Us

If you have questions about this Privacy Policy or wish to exercise your rights, contact us at admin@fambulglobal.com.