Last updated: May 22nd, 2024
1. Introduction
Welcome to the pawaPay’s privacy policy.
pawaPay respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
2. Important information and who we are
2.1. Purpose of this privacy policy
2.1.1. This privacy policy aims to give you information on how pawaPay collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up for our services.
2.1.2. This website is not intended for children and we do not knowingly collect data relating to children.
2.1.3. It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
2.2. Controller
2.2.1. Payments Techco OU is the controller and responsible for your personal data (collectively referred to as “pawaPay”, "we", "us" or "our" in this privacy policy).
2.2.2. pawaPay is made up of different legal entities, details of which can be found here. This privacy policy is issued on behalf of the pawaPay Group so when we mention "pawaPay", "we", "us" or "our" in this privacy policy, we are referring to the relevant company in the pawaPay Group responsible for processing your data. The pawaPay entity you contract with will be the controller for your data when you sign up for our services. Payments TechCo OU is the controller and responsible for this website.
2.2.3. Our legal team is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact our legal team using the details set out below.
2.3. Contact details
If you have any questions about this privacy policy or our privacy practices, please contact our legal team here DPO@pawapay.io. You have the right to make a complaint at any time to the applicable data privacy regulator in your country. We would, however, appreciate the chance to deal with your concerns before you approach the regulator so please contact us in the first instance.
2.4. Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2.5. Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
3. The data we collect about you
3.1. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
3.2. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
(a) Identity Data includes [first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender].
(b) Contact Data includes billing address, email address and telephone numbers.
(c) Financial Data includes your payment information..
(d) Transaction Data includes details about payments to and from you, and on your behalf and other details of our services you have signed up for.
(e) Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
(f) Profile Data includes your username and password, purchases, orders made by you, your interests, preferences, feedback.
(g) Usage Data includes information about how you use our website, products and services.
(h) Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
3.3. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
3.4. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
3.5. If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
4. How is your personal data collected?
4.1. We use different methods to collect data from and about you including through:
4.1.1. Direct interactions. You may give us your Identity, Contact and Financial Data by corresponding with us by phone, email or otherwise. This includes personal data you provide when you:
(a) create an account on our pawaPay dashboard;
(b) subscribe to our services;
(c) request marketing to be sent to you; or
(d) give us feedback or contact us.
4.1.2. Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookie and other similar technologies. Please see our cookie policy for further details.
4.1.3. Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below :
(a) Technical Data from analytics providers and search information providers.
(b) Contact, Financial and Transaction Data from providers of technical and payment services.
4.1.4. Identity and Contact Data from publicly available sources such as companies registries.
5. How we use your personal data
5.1. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
5.1.1. Where we need to perform the contract we are about to enter into or have entered into with you.
5.1.2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
5.1.3. Where we need to comply with a legal obligation.
5.2. Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
5.3. Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
6. Purposes for which we will use your personal data
6.1. We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
6.2. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
7. Marketing and Promotional offers from us
7.1. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
7.2. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
7.3. You may receive marketing communications from us if you have requested information from us or signed up for our services and you have not opted out of receiving that marketing.
7.4. Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
7.5. Opting out
You can ask us or third parties to stop sending you marketing messages at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of previous transactions with us.
8. Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see here.
9. Change of purpose
9.1. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
9.2. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
9.3. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
10. Disclosures of your personal data
10.1. We may share your personal data with the parties set out below for the purposes set out in the table above.
10.1.1. Internal Third Parties as set out in the Glossary.
10.1.2. External Third Parties as set out in the Glossary.
10.1.3. Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
10.2. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
11. International transfers
11.1. We share your personal data within the pawaPay Group. This will involve transferring your data outside the UK and EU.
11.2. Many of our external third parties are based outside the UK and EU so their processing of your personal data will involve a transfer of data outside the UK and EU.
11.3. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
11.3.1. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data;
11.3.2. You have consented to the transfer; or
11.3.3. The transfer is necessary for the performance of a contract you have with us or another party.
11.4. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK and EU.
12. Data security
12.1. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
12.2. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
13. Data retention
13.1. How long will you use my personal data for?
13.1.1. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
13.1.2. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
13.1.3. In some circumstances you can ask us to delete your data: see below for further information.
13.1.4. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
14. Your legal rights
14.1. Under certain circumstances, you have rights under data protection laws in relation to your personal data, such as to:
14.1.1. Request access to your personal data.
14.1.2. Request correction of your personal data.
14.1.3. Request erasure of your personal data.
14.1.4. Object to processing of your personal data,
14.1.5. Request restriction of processing your personal data.
14.1.6. Request transfer of your personal data.
14.1.7. Withdraw consent.
14.2. If you wish to exercise any of the rights set out above, please contact us at legal@pawapay.io.
14.3. No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
14.4. What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
14.5. Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
15. Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
THIRD PARTIES
Internal Third Parties
Other companies in the pawaPay Group acting as joint controllers or processors and who are based in Africa and provide payment processing services.
External Third Parties
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Welcome to the pawaPay’s privacy policy.pawaPay respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
2.1 Purpose of this privacy policy When you register for our services, we need to know your name and other personal details like postal address, email address, telephone number, bank account information and other relevant information.
2.2 In addition to the above, your personal data may also be collected when you voluntarily provide such information, such as when you contact us with inquiries, respond to one of our surveys or register for access to the services on the Site.
2.3 Other information: Some personally non-identifiable data may be collected when you interact with pawaPay through the Website. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. pawaPay may store such information itself or such information may be included in databases owned and maintained by pawaPay affiliates, agents or service providers. We may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, and the domain names of our visitors' Internet service providers.
3.1 To process registration you make on the Website.
3.2 To personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested.
3.3 To allow us to better serve you in responding to your customer service requests.
3.4 To quickly process your transactions.To follow up with you after correspondence (email or phone inquiries).
3.5 To help us develop the website and our services.
3.6 To provide your information to our customer service agencies for research and analysis purposes so that we can monitor and improve the services we provide.
3.7 We or our agents and subcontractors may contact you by post, e-mail or telephone to ask you for your feedback and comments on our services.
3.8 To provide you with information about special features of our Website or any other service or products we think may be of interest to you.
3.9 To provide you with related information from third parties we think may be of interest to you.
3.10 To provide your information to carefully selected third parties whose products or services we believe may be of interest to you. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. We seek to protect the integrity of our site and welcome any feedback about these sites.
pawaPay is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:
4.1 Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.
4.2 Related Companies: We may also share your Personal Data with our related Companies for purposes consistent with this Privacy Policy.
4.3 Agents, Consultants and Related Third Parties: pawaPay sometimes hires other companies to perform certain business-related functions. When we employ another entity to perform business functions, we only provide them with the information that they need to perform their specific function.
4.4 Legal Requirements: pawaPay may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of pawaPay, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.
In operating the Website, we may use a technology called "cookies". A cookie is a piece of information that the computer that hosts our Website gives to your browser when you access the Website. Our cookies help provide additional functionality to the Website and help us analyze Website usage more accurately. For instance, our Site may set a cookie on your browser that allows you to access the Services without needing to remember and then enter a password more than once during a visit to the Site. In all cases in which we use cookies, we will not collect Personal Data except with your permission or use information gathered for tracking purposes. For more information on our use of cookies, refer to our cookie statement.
We have put in place various security procedures as set out in this policy.
6.1 Our Website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site safe as possible.
6.2 We use regular malware scanning.
6.3 Your Personal Information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.
6.4 All data is encrypted both when transmitted and stored using industry best practice encryption.
From time to time and for security and other relevant reasons, pawaPay may contact you to update any of the information that you have provided and you may also do so on your own by updating your account on the website.
By submitting your information you consent to the use of that information as set out in this policy. The Website and our business may change from time to time. As a result, at times it may be necessary for pawaPay to make changes to this Privacy Policy. pawaPay reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. If we change our privacy policy, we will post the changes on this page and may place notice on other pages of the website, so that you may be aware of the information we collect and how we use it all times.
We will also e-mail you should we make any changes so that you may consent to our use of your information in that way. Continued use of service will signify that you agree to any such changes.
In the case of a breach of any of the obligations with respect to your personal data, a data breach procedure is established and maintained in order to deal with incidents concerning Personal Data or privacy practices leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data transmitted, stored or otherwise processed. On notification of such breach, pawaPay will investigate to determine if an actual breach has occurred, the actions required to manage such breach, communicate with the subject of the breach and take appropriate action as will be agreed between pawaPay and the subject of the breach to compensate the subject for such breach within one month of notification of breach.
This Privacy Statement does not address, and we are not responsible for, the privacy practices of any third parties, including those that operate websites to which this Site links. The inclusion of a link on this Site does not imply that we or our affiliates endorse the practices of the linked website.
