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


pawaPass is part of Pawapass Trustsee Services (a Rwanda registered company 120660123). This Privacy Policy is to help 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.


This notice has been developed incorporating the requirements of various privacy laws around the world for example this includes the Data Protection Act 2018 in the UK, the General Data Protection Regulation (GDPR in the EU), and Law n°058/2021 Relating to the Protection of Personal Data and Privacy in Rwanda (and others).

Data Protection laws exist to protect the accuracy, integrity and confidentiality of your Personal Data and to ensure that you are able to exercise any rights you may have.

We only collect and use your Personal Data when we have a legitimate reason for doing so. As such, we only collect Personal Data that is reasonably necessary to provide our services to you.

When processing your Personal Data we adhere to the following principles:


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:

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.

Additionally, if you encounter certain errors while using the site, we may automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error happened and so forth. You may or may not receive notice of such errors occurring.

We wish to make you aware that although this information may not be personally identifying per se, it may be possible to combine it with other data to identify individuals.

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:

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:

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:

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 Children’s Privacy

Where we process the personal data of children 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 children’s personal data, and the period for which it is to be stored,  separately from other data.


We keep your Personal Data only for only as long as necessary to fulfil the purpose for which it was obtained. This time period may depend on what we are using your information for, in accordance with this Privacy Notice. 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 not more than six years after a customer has exited our services unless there is a lawful justification for it to be retained. We may retain your information for longer if retaining it requires our compliance with any legal, accounting, or reporting obligation, 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. 

In all cases, the Data Protection Officer will ensure the secure deletion of all Personal Data that is no longer allowed to be held by us. If it is necessary to retain your data for us to be compliant with our obligations (as outlined above), the Data Protection Officer will ensure your data is safely and cryptographically stored.


You always retain the right to withhold Personal Data from us, with the understanding that your experience of our website and/or apps may be affected. We will not discriminate against you for exercising any of your rights over your personal information. 

If you do provide us with Personal Data, you understand that we will collect, hold, use and disclose it only in accordance with this Privacy Notice. 

You retain the right to request details of any Personal Data we hold about you.

If we receive Personal Data about you from a Third Party, we will protect it as set out in this Privacy Notice. If you are a Third Party providing Personal Data about somebody else, you represent and warrant that you have such person’s consent to provide the Personal Data to us.


We use “Cookies” to help us remember information about you and your activity across our site. A Cookie may not always be classed as Personal Data per se; it is a small piece of data that our website and/or apps stores on your computer and accesses 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 with improving our website, service and app.

Please refer to our Cookie Notice for more information.


If you believe or identify that any Personal Data we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading then please contact us. It is our obligation to take reasonable steps to correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading.


In accordance with Data Protection laws, where we process your personal information, you have certain rights when it comes to how we handle your Personal Data which include the rights to:

8.1 Right To Your Personal Data - Subject Access Requests

If you wish to make a Personal Data Subject Access Request (SAR) we ask that you make any request to our Data Protection Officer at but you can make a verbal, written or electronic (email, social media etc) SAR to anyone at pawaPass, through an official channel. We will ensure that your request is forwarded to the Data Protection Officer.

SARs should be submitted, with the following information:

When responding to a SAR, we will ensure that we will respond: 

Each SAR will be considered on a case-by-case basis and should an exemption be applicable and/or an SAR is unfounded or excessive, we reserve the right to refuse to provide some or all of the requested information. In such cases, we will inform you of the reasons for the decision and advise you of your right to make a complaint to the appropriate supervisory authority.

8.2 Right To Withdraw Your Consent

It is your right to withdraw consent where it has been provided,  please contact us if you want to follow this course of action. We want to make you aware of the following:

8.3 Right To Object

You have rights in respect of what Personal Data we can and cannot keep or cannot use. You need to tell us if this is applicable to you. This right may not apply if we have compelling legitimate grounds for processing your information such as a legal obligation to process your data.

8.4 Right To Be Forgotten

You have the ‘right to erasure’ or the ‘right to be forgotten’ if you believe that there is no requirement for us to retain your information. You need to tell us if this is applicable to you. If there is a legal and/or other official and justifiable reason that your data is still required by us, then we will advise you accordingly. In such cases we may be able to restrict the use of your data for legal and/or other official and justifiable reasons only if requested. 


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 to Third Parties. We always ensure full compliance with Data Protection Laws when information-sharing is necessary. We may share your data with the following:

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).


If you have consented to receiving direct marketing from ourselves, 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. We may also provide you with marketing material if there is a legitimate interest and we have a commercial reasoning to use your data. 

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. 


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


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 Policy. 

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: 


If you wish to raise concerns, seek clarification or make a complaint regarding Personal Data processing, ask that you contact the Data Protection Officer in the first instance providing us with  full details of your query, concern or complaint.

We will promptly look into your request, investigate and take remedial steps where applicable and respond to you, in writing. This communication will detail outcomes of any investigation, remedial actions undertaken and further steps we will take to deal with your query, concern or complaint. 

You can contact the Data Protection Officer via email

You also have the right to contact your local Data Protection authority at any time if you have concerns or a complaint regarding how we have handled your Personal Data or Data Subject rights. 


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


All Cookies used by and on our website and/or apps are used in accordance with current Cookie Laws and Privacy laws: such as the Privacy and Electronic Communications Regulations 2003 in the UK and EU, GDPR in the EU and ELECTRONIC COMMUNICATIONS REGULATIONS, 2011 (LI 1991) in Ghana (and others).


A Cookie is a small piece of data that a website and/or apps stores on your device when you visit. Consider it like a memory for your visit. Ordinarily it contains information about the website and/or apps themselves, a unique identifier that allows the site to recognise your web browser when you return to a webpage for example and I also contain additional data that serves the purpose of the Cookie.

Cookies are used to enable certain features such as:


We use Cookies to help improve your experience of our website and/or apps at This Cookie Policy is part of our Privacy Notice. It covers the use of Cookies between your device(s) and our website and/or apps.

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 In such cases, we may be unable to provide you with some of your desired content and services.


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.

4.1 First-Party Cookies

First-Party Cookies are Cookies which are set by the website and/or apps you are visiting. Ordinarily they only track your activity on the particular site you are visiting, storing key pieces of data enabling the site to recall user preferences, credentials and so forth.

4.2 Third-Party Cookies

Third-Party Cookies Cookies are set by other sites and companies (ie Third Parties) such as search engines, social media and so forth. They can be used to track you on other websites and/or apps that use the same Third-Party service. You will need to give your consent for Third-Party Cookies to be on your device(s); you can change your consent preference by visiting the Third Parties directly. 

We use both First-Party and Third-Party Cookies. The links to relevant policies for our Third Parties are below: 

4.3 Essential Cookies

Essential Cookies are crucial to your experience of a website and/or apps, enabling core features like user logins, account management, shopping carts, and payment processing. These Cookies are needed for our website and/or apps to function.

4.4 Performance Cookies

We use Performance Cookies to track how you, as a user, use our website and/or apps during your visit. Typically, this information is anonymous and aggregated (i.e. non-personally identifiable with respect to the user; a statistic for example), with information tracked across all site users. Performance Cookies help us understand visitor usage patterns, identify and diagnose problems or errors their users may encounter, and make better strategic decisions to improve your overall website and/or app experience. These Cookies may be set by the website and/or apps you are visiting (First-Party) or by Third-Party services. These Cookies do not collect Personal Data about you.

4.5 Functionality Cookies

We use Functionality Cookies to collect information about your device and any settings you may configure on the website and/or apps you’re visiting (like language and time zone settings). With this information we can provide you with customised, enhanced, or optimised content and services on our website and/or apps. These Cookies may be set by the website and/or apps you’re visiting (First-Party) or by Third-Party services.

4.6 Targeting/Advertising Cookies

Targeting/Advertising Cookies help determine what promotional content is most relevant and appropriate to you and your interests. Websites and/or apps may use them to deliver targeted advertising or limit the number of times you see an advertisement which helps companies improve the effectiveness of campaigns and the quality of content presented to you. These Cookies can be set by our website and/or apps (First-Party) or by Third-Party services with the Third-Party Cookies also being used to track you on other websites and/or apps that use the same Third-Party service.


If you have previously agreed to us using your personal information for direct marketing purposes we will track emails to you using pixels within the email. This will enable us to gather information and personalise the products and services suggested for you. 

You may change your mind at any time and we will provide you with the ability to unsubscribe from our email-database or opt out of communications. Please be aware we may need to request specific information from you to help us confirm your identity.


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,, 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.


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.


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:


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.


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.


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.


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.


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.


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.