Privacy Policy

1.0 Introduction

2.0 Definitions

i) Customer- the person who subscribes to, uses or purchases any of our products and services or accesses our websites and includes any person who accesses any of the products and services you have subscribed to.

ii) Any agent, dealer and/or merchants who has signed an agreement with us and is recognized as a merchant or agent in accordance with any applicable laws or regulations.

iii) Any visitor that is a person (including contractors/subcontractors or any third parties) who gains access to any Tupay premises.

iv) Any partner who has been contracted by Tupay and executed a partner contract.

3.0 Statement Details

3.1 Collection of Information

a) register for a specific product or service, including but not limited to Tupay and Tupay-powered services;

b) buy, subscribe to or use a Tupay product or service online, on the cloud, on a mobile or other device

c) subscribe to Tupay or third-party premium rates services, Short Message Service (SMS), email or social media platforms;

d) ask Tupay for more information about a product or service or contact Tupay with a query or complaint;

e) respond to or participate in a survey, marketing promotion, prize competition or special offer;

f) visit, access or use Tupay or third-party websites;

g) We may also collect your information from other organizations including credit-reference bureaus, fraud prevention agencies and business directories;

h) We may collect your information when you interact with us as a supplier, agent, merchant or dealer as prescribed in this statement;

i) We also collect information when you visit any of our premises.

3.2 What Information is collected?

3.2.1 Your identity, phone number, location and device Id. You can optionally provide your name, photograph, address, identity document type and number, date of birth, email address, age and gender.

3.2.2 Your can optionally provide credit or debit-card information, information about your bank account numbers and SWIFT codes or other banking information.

3.2.3 Your transaction information when you use our Tupay service.

3.2.4 Your preferences for particular products and services, based on information provided by you or from your use of Tupay’s (or third party) network, products and services.

3.2.5 You can optionally provide your name and profiling information such as level of education, income brackets, etc. collected as part of surveys conducted by Tupay and their agents on behalf of Tupay.

3.2.6 Your contact with us, such as when you: call us or interact with us through social media, email, register your biometric information such as your voice, finger prints etc.

3.2.7 Your contact list can be accessed upon your permission and the contacts you select will be collected.

3.2.i8 Your mobile money payment confirmation sms can be accessed upon your permission to process payments.

3.3 Use of Information

3.3.1 Processing products and services that you have bought from Tupay or from third parties;

3.3.2 Billing you for products or services or taking the appropriate amount of credit from you;

3.3.3 Responding to any of your queries or concerns;

3.3.4 Verifying your identity information through publicly available and/or restricted government databases in order to comply with applicable regulatory requirements;

3.3.5 Carrying out credit checks and credit scoring;

3.3.6 Keeping you informed generally about new products and services and contacting you with offers or promotions based on how you use our or third-party products and services unless you opt out of receiving such marketing messages (you may contact Tupay at any time to opt out of receiving marketing messages);

3.3.7 to comply with any legal, governmental or regulatory requirement or for use by our lawyers in connection with any legal proceedings;

3.3.8 In business practices including to quality control, training and ensuring effective systems operations;

3.3.9 To protect our network including to manage the volume of use of our service;

3.3.10 To understand how you use our products and services for purposes of developing or improving products and services;

3.3.11 Preventing and detecting fraud or other crimes;

3.3.12 For research, statistical, survey and other scientific or business purposes;

3.3.13 Provide aggregated data (which do not contain any information which may identify you as an individual) to third parties for research and scientific purpose;

3.3.14 Administer any of our online platforms/websites.

3.3.15 Contact lists are saved for ease of access of preferred contacts.

3.3.16 SMS confirmation from mobile money payments.

3.4. Categories of Data

3.5. Lawful Basis for processing your information

3.5.1 The performance of a Product/Service Agreement with you;

3.5.2 Tupay’s legitimate business interests;

3.5.3 Compliance with a mandatory legal obligation;

3.5.4 Consent you provide;

3.5.5 Public interest;

3.5.6 Your vital interest.

3.6. Retention of Information

4.0 Disclosure of Information

a) law-enforcement agencies, regulatory authorities, courts or other statutory authorities in response to a demand issued with the appropriate lawful mandate and where the form and scope of the demand is compliant with the law.

b) our subsidiaries, associates, partners, software developers or agents who are involved in delivering Tupay products and services you order or use;

c) Fraud prevention and Anti money laundering agencies, credit-reference agencies;

d) publicly available and/or restricted government databases to verify your identity information in order to comply with regulatory requirements;

e) debt-collection agencies or other debt-recovery organizations;

f) Survey agencies that conduct surveys on behalf of Tupay;

g) Emergency service providers when you make an emergency call (or where such disclosure to emergency service providers is necessary for your rescue, health and safety) including your approximate location;

h) Any other person that we deem legitimately necessary to share the data with.