pawaPass is committed to protecting and respecting your privacy. We do not sell your information and will only share your information with your permission.
This notice was last updated on 13 June 2023. We will always let you know when something meaningful changes with our data privacy notice and ask you if we want to share your information with new companies or categories of companies.
Privacy Notice
WE ARE COMMITTED TO PROTECTING AND RESPECTING YOUR PRIVACY.
1.0 INTRODUCTION
pawaPass is part of Technology Assets Limited (a Mauritius registered company with no. 218479). This Privacy Notice helps you understand how we will look after your personal information.
Your Privacy is important to us. We respect your Privacy and comply with all applicable laws and regulations regarding the Personal Data we may collect about you. This includes data from across our website and/or apps.
Personal Data is information about you which can be used to identify you. This includes information about you as a person (things such as name, address and date of birth), your devices (such as information about your specific mobile phone or computer), payment details; even information about how you use a website and apps, or an online service.
Our website and/or apps may contain links to Third-Party sites and services. Please be aware that those sites and services have their own Privacy notices, and you should read their posted Privacy Notice information about how they collect and use personal information. This Privacy notice only applies to Personal Data that we process or share ourselves.
2.0 YOUR PERSONAL DATA AND THE LAW
This Privacy Notice has been developed to reflect the requirements of applicable data protection laws in various jurisdictions, including the UK Data Protection Act 2018 , the EU General Data Protection Regulation (GDPR), and Rwanda's Law n°058/2021 Relating to the Protection of Personal Data and Privacy.
We collect and use Personal Data only where we have a lawful and legitimate reason to do so, and only to the extent necessary to provide our services
We process personal data lawfully, fairly and transparently, for specified purposes, and implement appropriate measures to ensure its security and confidentiality in accordance with applicable data protection laws.
3.0 THE PERSONAL DATA WE COLLECT & USE
Information we collect includes information you knowingly and actively provide us when using or participating in any of our services and promotions, and any information automatically sent by your devices in the course of accessing our products and services.
3.1 Personal Information
We may ask for Personal Data which may include one or more of the following:
- Identity Data such as your name, date of birth, copies of personal identification documents (such as your passport or driving licence, which may also indicate ID numbers, nationality and sex) and photographs or other descriptions of your likeness
- Contact information such as your email address, telephone number, and home address
- Financial information such as your mobile phone number (when linked to mobile money through a Telco), bank account details, financial transactions from pawaPass partners or services
- Biometric data which uses technical processing of facial images for the purpose of verifying your identity against an identity document or facial image you have previously provided to pawaPass or the partner verifying your identity.
Some of this information may be sensitive personal data which we will only process with your consent or for purposes where the processing is necessary to comply with our own or our partners obligations.
3.2 Log Data
When you visit our website and apps, our servers may automatically log the standard data provided by your web browser. It may include your device’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details about your visit.
We use this information to help us improve our services by understanding what types of devices use our service to improve compatibility and to ensure we protect your information from fraud.
3.3 Device Data
When you visit our website and apps or interact with our services, we may automatically collect data about your device, such as:
- Device Type
- Operating System
- Web browser
- Unique device identifiers
- Device settings
- Geo-location data
Data we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.
3.4 How we collect your information
We may collect Personal Data from you when you undertake any of the following on our website and/or apps:
- Register for an account
- Use a mobile device or web browser to access our content
- Contact us via email, social media, or on any similar technologies
- When you mention us on social media
When we are processing your information on behalf of a third-party service, we will collect the information they send to us, in addition to any further information we collect for you.
We may also collect Personal Data from third parties or public sources to comply with our legal obligations and to ensure we can protect you and others from financial crime and fraud. This may include our business partners, payment providers, other financial institutions, telecom providers, and government agencies.
3.5 How we use your information
We may collect, hold, use, and disclose information for the following purposes. Your Personal Data will not be further processed in a manner that is incompatible with these purposes:
- To provide and operate services
- To manage user accounts
- To communicate with users
- To prevent fraud and ensure security
- To comply with legal obligations
- To improve services
We process personal data for the purposes described above and only where we have a lawful basis to do so, including contract performance, legal obligations, legitimate interests, or consent, as applicable.
Please be aware that we may combine information we collect about you with general information or research data we receive from other trusted sources.
3.6 Data relating to individuals under 18
Where we process the personal data of individuals under the age of 18, we will ensure we have taken appropriate technical and organisational measures to safeguard the information and ensure it is only processed when necessary.
We will only collect this information where we can justify the processing is necessary and will ensure that we evaluate any purpose for processing of such personal data, and the period for which it is to be stored, separately from other data.
4.0 STORING YOUR PERSONAL DATA
We keep your Personal Data only for as long as necessary to fulfil the purpose for which it was obtained. . If your Personal Data is no longer required, we will delete it or make it anonymous by removing all details that identify you.
We will retain Personal Data for a maximum of one year after we have collected it if we have not entered into a contract with you for the provision of services. We may retain your Personal Data for longer if there is a lawful justification for it to be retained.
Personal Data is retained for no more than six years after a customer has exited our services unless the retention is required to comply with any legal, accounting, or reporting obligations, technical reasons (remedial action will be undertaken as soon as practicable) or for archiving purposes in the public interest as defined in Data Protection legislation.
5.0 COOKIES
We use “Cookies” to help us remember information about you and your activity across our site. A Cookie is a small piece of data that our website and/or apps store on your computer and access each time you visit. Cookies do this to understand how you use our site. This helps us to provide you with content based on preferences you have specified and can also help us improve our website, service and app.
Please refer to our Cookie Notice for more information.
6.0 YOUR RIGHTS
You have the following rights in relation to your personal data, subject to applicable data protection laws:
- The right to access your personal data
- The right request correction of inaccurate or incomplete personal data
- The right to request deletion of your personal data in certain circumstances
- The right to request restriction of processing
- The right to object to the processing of your personal data
- Where applicable, the right to withdraw your consent at any time, without affecting the lawfulness of processing carried out before withdrawal
- The right to data portability, where applicable and
- The right to lodge a complaint with a competent data protection authority.
To exercise any of these rights, you may contact us at dpo@pawapass.com
7.0 DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
We ensure Personal Data remains confidential but to meet our operational obligations and provide the services and products to our customers as required, we may need to share information with Third Parties. We always ensure full compliance with Data Protection Laws when information sharing is necessary. We may share your data with the following:
- Courts, tribunals, regulatory authorities, law enforcement and any other body as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise, or defend our legal rights
- Any authorities and regulators
- Law enforcement and fraud prevention agencies in order to prevent money-laundering and fraud
- Revenue services or Tax authorities where there is a legal requirement
- A parent, subsidiary, or affiliate of our company
- Credit reference or fraud agencies who may in turn share your Personal Data with other organisations, which those organisations may use to make decisions about you
- Third Parties we use to operate our service including communicating with you for example, IT service providers, Customer Support systems, data storage, hosting and server providers, or analytics platforms
- Agents or subcontractors, who assist us in providing information, products, services, or direct marketing to you
- Our employees, contractors, and/or related entities
- Our existing or potential agents or business partners insomuch as it is necessary to conduct our business
pawaPass enables third-party partners to verify your identity through our service. Where you have agreed to share your information, we will share your information with the specific partner.
In some jurisdictions, in accordance with local laws and restrictions, pawaPass may provide further services to our partners which involves processing information we receive from yourself or other partners, which is then shared in some form with third-party partners you sign up to. We do not share your information with third parties not included above where you have not signed up (or are in the process of signing up).
8.0 MARKETING
If you have consented to receiving direct marketing from us, then we may contact you if we think you might be interested in our products and services and may use your Personal Data to make an informed decision regarding this.
If you have previously consented to us using your Personal Data for direct marketing purposes, you may change your mind at any time. We will provide you with the ability to unsubscribe from our email database or opt out of communications.
9.0 PERSONAL DATA AND AUTOMATED DECISIONS
Automated individual decision-making is a decision made by automated means without any human involvement. Such decisions are based on Personal Data that we are able, by law, to collect. Any automated decision-making is limited, which may have a significant material impact on you, is reviewed by a human.
You have the right to object to automated decision-making and should contact the Data Protection Officer in the first instance at dpo@pawaPass.com
10.0 INTERNATIONAL TRANSFERS
The Personal Data we collect is stored and/or processed in the United Kingdom and European Union, or where we or our partners, affiliates, and Third-Party providers maintain facilities.
Personal Data may be transferred to countries outside these countries for any of the purposes described in this Notice.
The countries to which we store, process, or transfer your Personal Data may not have the same Data Protection laws as us and if we transfer your Personal Data to Third Parties in other countries we will always take all identifiable and reasonable safeguarding steps to ensure that your information remains adequately protected including in all cases:
- We will perform those transfers in accordance with the requirements of applicable law, ensuring that you have the same level of data protection through our agreement with any third parties
- We will protect the transferred Personal Data in accordance with this Privacy Notice
11.0 CLARIFICATION, CONCERNS, COMPLAINTS
If you wish to raise concerns, seek clarification or make a complaint regarding Personal Data processing, we ask that you contact the Data Protection Officer via email dpo@pawapass.com
12.0 CHANGES TO THIS NOTICE
We may change our Privacy Notice to reflect updates to our business processes, current acceptable practices, or legislative or regulatory changes. If we decide to change this Privacy Notice, we will post the changes here and on our website.
If the changes are significant, or if required by applicable law, we will contact you with the new details and links to the updated or changed notice.
Cookie Notice
This cookie Notice explains how pawaPass uses cookies and similar technologies when you visit our website. It should be read together with our Privacy Notice, which explains how we use personal data more generally.
1.0 WHAT ARE COOKIES?
Cookies are small text files that are placed on your device when you visit a website. They are widely used to make websites work efficiently, improve user experience, and provide information to website owners. ..
2.0 WHY WE USE COOKIES
We use Cookies to help improve your experience of our website and/or apps at https://www.pawaPass.com.
With regard to the Cookies we use, some require your consent and some do not. You can change your choices at any time in relation to your consent preference and if you do not wish to accept Cookies from us, you should instruct your browser to refuse Cookies from https://www.pawaPass.com. In such cases, we may be unable to provide you with some of your desired content and services.
4.0 THE TYPES OF COOKIES WE USE
We use Cookies in various ways to operate our products and services and to help us keep your data and our products and services safe and secure.
We use the following categories of cookies:
- Strictly necessary cookies: These cookies are essential for the operation of our website and apps and cannot be switched off. They enable core functionality such as security, network management, and accessibility.
- Performance and analytics cookies: These cookies allow us to measure and improve the performance of our website and apps by collecting information about how visitors use it. These cookies are only set with your consent. Functionality cookies
- Functionality cookies: These cookies enable enhanced functionality and personalisation, such as remembering your preferences. These cookies are only set with your consent. Targeting and advertising cookies
- Targeting and advertising cookies: These cookies may be set by us or by third parties to deliver relevant content or measure the effectiveness of campaigns. These cookies are only set with your consent.
5.0 THIRD-PARTY COOKIES
Some cookies on our website are placed by third parties that provide services to us, such as analytics or security services. These third parties may process information about your use of our website in accordance with their own privacy policies linked below:
Angel List Talent
Intercom
6.0 COOKIE DURATION
Cookies may be session cookies, which are deleted when you close your browser, or persistent cookies, which remain on your device for a defined period or until you delete them.
7.0 CHANGES TO OUR COOKIE POLICY
We may change our Cookie Notice at any time so it is worthwhile reviewing our Cookie Policy from time to time. Details of any changes will be included at the top of this page and the changes will become binding on your first visit to our website and/or apps after such change.
Website Terms of Use
pawaPass is a product created by Pawapass Trustee Services Limited (a Rwanda registered company 120660123). This document sets out the Terms of Use for your relationship with Pawapass and its related services. It also sets out other important things that you need to know and you should read these Terms of Use carefully before using this website. These Terms of Use, together with any other terms and policies provided on our app or website, form a legal agreement between You and Pawapass.
These Terms of Use govern your use of the website and/or apps located at pawaful.org, pawapass.com, pawabank.com and any related services provided by pawaPass.
The website and/or apps are ordinarily available every minute of every day throughout the year. Should the website be unavailable due to maintenance, repair, system failure, temporary suspension or any other reason beyond our control we shall not be liable.
By accessing our sites, you agree that you have the authority to and are accepting of these Terms of Use and are agreeing to be compliant with all applicable laws and regulations. On entering into this agreement, you are confirming that you are capable of assuming and do assume any risks related to the use of this website and/or apps and its content, and that you understand and accept the terms, conditions and risks relating to their use. If you do not agree with these Terms of Use, you are prohibited from using or accessing any of Pawapass's webpages and/or apps or using any other services provided by Pawapass. You should stop using our website and/or apps with immediate effect.
We reserve the right to review and amend any of these Terms of Use at our sole discretion. Upon doing so, we will update this page. Any changes to these Terms of Use will take effect immediately from the date of publication.
1.0 INTELLECTUAL PROPERTY
The intellectual property in the materials contained in any of our webpages and/or apps are owned by or licenced to Pawapass and are protected by applicable copyright and trademark law. We grant our users permission to download one copy of the materials for personal, non-commercial transitory use.
This constitutes the grant of a licence, not a transfer of title. This licence shall automatically terminate if you violate any of these restrictions or the Terms of Use and may be terminated by Pawapass at any time.
ACCEPTABLE CONDUCT
By using any of Pawapass's webpages and/or apps, you warrant on behalf of yourself, your users, and other parties you represent that you will not:
- Modify, copy, prepare derivative works of, decompile, or reverse engineer any materials and software contained on any of Pawapass's webpages and/or apps
- Remove any copyright or other proprietary notations from any materials and software on any of Pawapass's webpages and/or apps
- Transfer the materials to another person or “mirror” the materials on any other server
- Knowingly or negligently use any of Pawapass's webpages and/or apps or any of its associated services in a way that abuses or disrupts our networks or any other service Pawapass provides
- Use any of Pawapass's webpages and/or apps or its associated services to transmit or publish any harassing, indecent, obscene, fraudulent, or unlawful material
- Use any of Pawapass's webpages and/or apps or its associated services in violation of any applicable laws or regulations
- Use any of Pawapass's webpages and/or apps in conjunction with sending unauthorised advertising or spam
- Harvest, collect, or gather user data without the user’s consent
- Use any of Pawapass's webpages and/or apps or its associated services in such a way that may infringe the privacy, intellectual property rights, or other rights of third parties.
1.0 LINKS
Pawapass has not reviewed all of the sites linked to its website and/or apps; it is not responsible for the contents of any such linked site. The inclusion of any link does not imply endorsement, approval, or control by Pawapass of the site. Use of any such linked site is at your own risk and we strongly advise you make your own investigations with respect to the suitability of those sites.
Our website and/or apps may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites and cannot accept responsibility or liability for their respective privacy practices.
2.0 REGISTRATION & PASSWORDS
On our website and/or apps, individuals may be invited to register. You will require a password for such registration and the security of the password is your sole responsibility.
Registrations are for single users only; usernames and passwords must not be shared.
3.0 LIABILITY
Our website and/or apps and the materials on our website and/or apps are provided on an 'as is' basis. In no event shall we be liable for any consequential loss suffered or incurred by you or any third party arising from the use or inability to use any of our webpages and/or apps or the materials on any of our webpages and/or apps, even if Pawapass or an authorised representative has been notified, orally or in writing, of the possibility of such damage.
In the context of this agreement, “consequential loss” includes any consequential loss, indirect loss, real or anticipated loss of profit, loss of benefit, loss of revenue, loss of business, loss of goodwill, loss of opportunity, loss of savings, loss of reputation, loss of use and/or loss or corruption of data, whether under statute, contract, equity, tort (including negligence), indemnity, or otherwise.
4.0 ACCURACY OF MATERIALS
The materials appearing on our website and/or apps are not comprehensive and are for general information purposes only. We do not warrant or make any representations concerning the accuracy, likely results, or reliability of the use of the materials on any of our webpages and/or apps, or otherwise relating to such materials or on any resources linked to any of our webpages and/or apps.
5.0 SEVERANCE & RIGHT TO TERMINATE
Any term of these Terms of Use which is wholly or partially void or unenforceable is severed to the extent that it is void or unenforceable. The validity of the remainder of these Terms of Use is not affected.
We may suspend or terminate your right to use our website and apps and terminate these Terms of Use immediately upon written notice to you for any breach of these Terms of Use.
6.0 GOVERNING LAW
These Terms of Use are governed by and construed in accordance with the laws of the United Kingdom. You irrevocably submit to the exclusive jurisdiction of the courts in that location.
