# Zambia Legal Review Checklist

This document is not legal advice. It defines questions for qualified Zambian counsel before pilot and production.

## Product classification

- How is DIREKT classified as a marketplace/directory/intermediary?
- What duties arise from provider verification claims?
- Which disclaimers are enforceable and which duties cannot be excluded?
- Does field verification create additional liability or agency?

## Data protection

- Controller/processor roles;
- registration/notification obligations;
- lawful bases/consent;
- sensitive identity and location;
- cross-border hosting/vendors;
- data subject rights;
- retention and breach notification;
- employee/agent access monitoring;
- age restrictions.

## Consumer protection

- transparent pricing and promotions;
- subscription renewal/cancellation;
- complaints/refunds;
- misleading “verified/trusted” claims;
- sponsored placement;
- provider independence;
- electronic terms and records.

## Business/professional verification

For each launch category:

- legally required qualification/licence;
- issuing authority;
- lawful method to verify/display;
- expiry/revocation;
- use of PACRA or sector information;
- limits on reproducing certificates/logos.

## Payments/tax

- approved payment providers;
- whether DIREKT receives/holds funds;
- receipts/VAT/tax treatment;
- refunds/chargebacks;
- mobile-money terms;
- reconciliation/records.

## Contracts

Customer terms, provider agreement, field-agent/reviewer contracts, privacy notice, cookie/portal notice, vendor DPAs, acceptable use and complaints/appeals.

## Sign-off record

Counsel, date, documents reviewed, jurisdictional assumptions, required changes, unresolved risks and re-review triggers.
