Personal data protection
Privacy Notice
This notice explains how Keshopay collects and uses personal data, when it acts as a controller or processor, the safeguards applied, and how people can exercise their rights under Tanzanian data-protection law.
Review draft: complete the BRELA registration number, TIN, business licence number, address, email, and toll-free contact fields before publishing this document as an approved customer notice.
Scope and our role
This notice applies to personal data processed through Keshopay websites, dashboards, APIs, hosted payment experiences, communications, support, onboarding, complaints, and operational records.
Keshopay acts as a data controller for its account security, onboarding, legal compliance, fraud prevention, service operations, complaints, and direct relationships. Where a merchant determines why and how its customer data is processed and instructs Keshopay to process that data, Keshopay may act as the merchant's data processor. The merchant remains responsible for its own privacy notice and lawful instructions.
- Legal entity:
- Kesho Technologies Company Limited
- BRELA registration number:
- [insert BRELA company registration number]
- TIN:
- [insert Tanzania Revenue Authority TIN]
- Business licence number:
- [insert business licence number]
- Regulatory role:
- Kesho Technologies Company Limited does not hold or claim a direct Bank of Tanzania payment-service licence or approval. Regulated payment processing is provided through Malipo Pay and AzamPay under their applicable licences and approvals, where each provider integration is enabled and operationally certified.
- Address:
- [insert registered physical and postal address, Tanzania]
- Email:
- [insert privacy or data-protection email]
Personal data we process
- Identity and organisation data: names, contact details, roles, business identity, registration, tax, beneficial-owner, director, authorised-person, and settlement-verification information.
- Transaction data: payment references, amount, currency, phone number, customer or invoice reference, beneficiary details, refund and payout records, status, timestamps, provider references, and fee breakdowns.
- Account and security data: credential metadata, session and device information, verified contact status, MFA state, access grants, authentication events, IP address, user agent, and audit records.
- Support and complaint data: complaint description, category, linked transactions, correspondence, evidence, resolution, compensation, and delivery records.
- Technical and usage data: service requests, callbacks, webhook delivery evidence, reliability telemetry, error information, and masked provider responses.
Where data comes from
Data may come directly from the individual, a merchant or its authorised user, a payment or mobile-network provider, a bank or settlement partner, an identity or fraud-control service, a regulator or lawful authority, a customer's device and browser, or records generated when the service processes an instruction.
Why we process personal data
- Provide, authorise, route, reconcile, refund, settle, report, and support payment services.
- Verify merchants, owners, settlement accounts, users, beneficiaries, and production eligibility.
- Protect accounts and transactions; prevent fraud, abuse, duplicate processing, and unauthorised access.
- Meet AML, sanctions, tax, accounting, audit, consumer-protection, data-protection, court, and regulatory obligations.
- Resolve complaints, deliver redress, investigate incidents, and preserve evidence.
- Measure reliability, troubleshoot, improve accessibility and service quality, and communicate service changes.
- Send marketing only where permitted and subject to the individual's right to object or withdraw consent.
Authority for processing
We process data where it is necessary to perform or prepare a contract, comply with a legal obligation, carry out an authorised payment instruction, protect systems and people, establish or defend legal claims, perform a task authorised by law, or pursue a legitimate and proportionate operational need. Where consent is the required basis—such as certain marketing or transfers—we request it clearly and permit withdrawal. Withdrawal does not invalidate earlier lawful processing or prevent processing required by law.
International transfers
Where data is transferred outside Tanzania, we assess the destination and purpose and use a lawful transfer mechanism, consent where required, contractual and security safeguards, or authorisation from the Personal Data Protection Commission where applicable. Provider routing does not itself authorise an unrestricted transfer of personal data.
Retention and deletion
We keep personal data only for the purpose and period required by applicable law, contract, dispute needs, audit, financial integrity, and security. Retention varies by record: complaint records are retained for at least five years; KYB evidence and legally required financial or audit records may be retained for seven years or another approved statutory period; short-lived security and checkout tokens expire much sooner.
At the end of the applicable period, data is securely deleted, anonymised, or restricted. Active legal holds, unresolved transactions, regulatory directions, fraud investigations, or legal claims may delay deletion. Financial totals, references, and audit evidence may be preserved after customer contact data is redacted.
Security and breach response
Safeguards include encryption in transit, private secret and object storage, malware scanning, checksums, role and project access controls, MFA for privileged access, environment isolation, data masking, signed callbacks and webhooks, immutable audit evidence, monitored recovery, and least-privilege operational identities.
No system is risk-free. We investigate suspected incidents, contain exposure, preserve evidence, notify the Personal Data Protection Commission without undue delay where required, and notify affected people when law or the assessed risk requires it.
Your data-protection rights
Subject to lawful conditions and exceptions, a data subject may request to be informed, access personal data, correct inaccurate data, erase or destroy eligible data, restrict or object to processing, stop direct marketing, withdraw consent, obtain portable data where applicable, understand and challenge significant automated decisions, complain, seek compensation, and exercise other rights recognised by Tanzanian law.
We may verify identity and authority before acting. We will explain any lawful refusal or restriction. Requests can be sent to the privacy contact below; a person may also complain to Tanzania's Personal Data Protection Commission.
- Legal entity:
- Kesho Technologies Company Limited
- BRELA registration number:
- [insert BRELA company registration number]
- TIN:
- [insert Tanzania Revenue Authority TIN]
- Business licence number:
- [insert business licence number]
- Regulatory role:
- Kesho Technologies Company Limited does not hold or claim a direct Bank of Tanzania payment-service licence or approval. Regulated payment processing is provided through Malipo Pay and AzamPay under their applicable licences and approvals, where each provider integration is enabled and operationally certified.
- Address:
- [insert registered physical and postal address, Tanzania]
- Email:
- [insert privacy or data-protection email]
Automated risk decisions
Keshopay uses deterministic risk rules that may decline an instruction or place it in review. Material review holds can be examined by an authorised human operator. A person may request information about a significant automated decision and challenge it through the privacy or complaints channels, subject to fraud-prevention and legal restrictions.
Changes to this notice
We review this notice when processing, providers, laws, or products change. Material changes will be identified and communicated before they take effect where required. The version and effective date appear at the top of the page.