Privacy Policy

1.Information we collect#

Depending on how you use MeeGo Pay, we may collect the following information.

1.1 Account Information

When you create an account, we may collect:

• Full name;
• Telephone number;
• Email address;
• Account type;
• Username or account identifier;
• Profile information;
• Password or authentication credentials; and
• Other information required to operate your account.

1.2 Identity Verification Information

Where identity verification is required, we may collect:

• National identification information;
• Passport or other identification documents;
• Date of birth;
• Verification information;
• Business registration information;
• Business ownership information; and
• Information required by our payment or verification partners.

The specific information requested may depend on the type of account and applicable legal or regulatory requirements.

1.3 Payment Information

When you add a payment card, we may receive information such as:

• Card type;
• Card brand;
• Last four digits;
• Expiry information;
• Payment-provider token/reference;
• Transaction reference; and
• Payment status.

Where card tokenization is used, sensitive card information may be handled directly by our payment provider rather than stored by MeeGo Pay.

We do not intend to store your CVV or full card security information on MeeGo Pay’s ordinary application database.

1.4 Payout Information

If you receive money through MeeGo Pay, we may collect:

• Mobile-money network;
• Mobile-money number;
• Bank account information where applicable;
• Payout-provider reference;
• Payout status; and
• Information necessary to verify and complete the payout.

1.5 Transaction Information

We may collect and retain information about transactions including:

• Transaction ID;
• Payer;
• Recipient;
• Amount;
• Currency;
• Fees;
• Payment method;
• Card reference;
• Payment-provider reference;
• Payout-provider reference;
• Transaction status;
• Date and time;
• Refunds;
• Reversals; and
• Error or failure information.

1.6 Device and Technical Information

When you use the application or website, we may automatically collect certain technical information, including:

• Device type;
• Operating system;
• Application version;
• IP address;
• Browser information;
• Device identifiers;
• Login information;
• Approximate location information where necessary for security or service functionality; and
• Technical logs.

2.How we use your information#

We may use personal information to:

Provide MeeGo Pay services

• Create and manage accounts;
• Process payments;
• Process payouts;
• Generate QR codes;
• Display transaction history;
• Send payment notifications;
• Provide customer support; and
• Operate and improve the Platform.

Security and fraud prevention

We may use information to:

• Verify identity;
• Detect suspicious transactions;
• Prevent fraud;
• Protect accounts;
• Investigate unauthorized transactions;
• Detect abuse; and
• Protect MeeGo Pay users and our systems.

Legal and regulatory compliance

We may process information where necessary to:

• Comply with applicable laws;
• Respond to lawful requests from authorities;
• Meet payment-provider requirements;
• Maintain required records;
• Prevent financial crime; and
• Fulfil other legal obligations.

Service improvement

We may use aggregated or appropriately de-identified information to:

• Understand Platform usage;
• Improve performance;
• Identify technical problems;
• Improve user experience; and
• Develop new services.

3.Payment processing#

MeeGo Pay may work with third-party payment processors and financial service providers to process transactions.

Relevant information may therefore be shared with the providers necessary to complete the transaction.

4.Information we share#

We do not sell your personal information as a general business practice.

We may share information with selected third parties where necessary.

These may include:

Payment providers

For:

• Card processing;
• Payment authorization;
• Settlement;
• Mobile-money payouts;
• Bank transfers; and
• Transaction verification.

Identity-verification providers

Where necessary to verify your identity or business.

Technology providers

Including:

• Cloud hosting providers;
• Database providers;
• Security providers;
• Communication providers;
• Analytics providers; and
• Customer-support systems.

Government and regulatory authorities

We may disclose information where required by law, court order, regulatory requirement or lawful government request.

Professional advisers

We may share appropriate information with legal, accounting, audit, compliance or professional advisers where necessary.

5.Your card information#

MeeGo Pay is designed to minimize the amount of sensitive card information stored directly by us.

Where our payment provider supports tokenization:

1. You enter your card information through the authorized payment interface.
2. The payment provider securely processes the card.
3. MeeGo Pay receives a token/reference.
4. MeeGo Pay uses that token to initiate future authorized transactions.

MeeGo Pay should not store your CVV in its ordinary database.

6.Your PIN#

Your MeeGo Pay PIN is used to authorize certain actions.

We will not intentionally store your PIN in plain text.

PINs should be stored using appropriate security mechanisms such as secure hashing.

You must never disclose your PIN to another person.

MeeGo Pay staff should never ask you to provide your complete PIN.

7.QR codes and personal information#

A MeeGo Pay QR code is designed primarily to identify the intended payment recipient.

The QR code should not contain:

• Bank-card numbers;
• CVV;
• PIN;
• Mobile-money credentials;
• Passwords; or
• Other sensitive authentication information.

The QR code may contain or reference an identifier or secure web address associated with your MeeGo Pay account.

8.Data security#

We take reasonable technical and organizational measures to protect personal information against:

• Unauthorized access;
• Loss;
• Destruction;
• Misuse;
• Alteration;
• Disclosure; and
• Other unlawful processing.

Security measures may include:

• Encryption;
• Secure authentication;
• Access controls;
• PIN protection;
• Card tokenization;
• Secure APIs;
• Transaction monitoring;
• Audit logs;
• Rate limiting;
• Fraud detection;
• Secure cloud infrastructure; and
• Regular security reviews.

No electronic system can be guaranteed to be completely secure.

9.Data retention#

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including:

• Providing services;
• Maintaining transaction records;
• Resolving disputes;
• Preventing fraud;
• Meeting legal and regulatory requirements;
• Accounting and audit purposes; and
• Protecting our legal rights.

Certain transaction and financial records may need to be retained for longer periods where required by applicable law or regulatory requirements.

When information is no longer required, we may securely delete, anonymize or otherwise dispose of it in accordance with applicable requirements.

10.Your data protection rights#

Subject to applicable law and any lawful limitations, you may have rights concerning your personal information, including the right to:

• Request access to personal information we hold about you;
• Request correction of inaccurate information;
• Request information about how your personal information is processed;
• Object to certain processing;
• Request deletion or destruction where legally applicable;
• Request restriction of certain processing;
• Raise a complaint regarding the handling of your information; and
• Exercise other rights provided by applicable data-protection law.

Uganda’s data-protection regulations expressly provide for rights including access, preventing processing, rectification, blocking, erasure and destruction in specified circumstances.

Some requests may be subject to legal, regulatory, security or record-retention requirements.

11.Marketing communications#

We may send service-related communications such as:

• Payment confirmations;
• Security alerts;
• Account notifications;
• Transaction updates;
• Service announcements; and
• Important changes to the Platform.

Where permitted, we may also send promotional communications.

You may opt out of non-essential marketing communications using the unsubscribe mechanism provided or by contacting us.

Service and security communications may continue even if you opt out of marketing.

12.Cookies and similar technologies#

The MeeGo Pay website may use cookies or similar technologies to:

• Keep users signed in;
• Maintain security;
• Remember preferences;
• Understand website usage; and
• Improve website performance.

You may be able to control cookies through your browser settings.

13.Children#

MeeGo Pay is not intended to be used by persons who are legally unable to enter into financial transactions.

We may restrict accounts where we reasonably believe the account holder does not meet applicable age or eligibility requirements.

If we become aware that we have collected personal information from a child in circumstances where collection was not permitted, we may take steps to delete or restrict that information as required by law.

14.International data processing#

Some of our technology or payment providers may process or store information outside Uganda.

Where personal information is transferred or processed outside Uganda, we will take reasonable steps to ensure that applicable data-protection requirements are considered and appropriate safeguards are implemented.

15.Data breaches#

If a security incident occurs that affects personal information, we will assess the incident and take reasonable steps to:

• Contain the incident;
• Investigate what happened;
• Protect affected systems;
• Assess potential impact;
• Take corrective measures; and
• Make notifications where required by applicable law.

Uganda’s Data Protection and Privacy Regulations contain specific provisions concerning data-security breaches and notification.

16.Third-party websites and services#

MeeGo Pay may contain links or integrations to third-party services.

This Privacy Policy does not govern the privacy practices of independent third parties.

You should review the privacy policies of those providers before using their services.

17.Changes to this privacy policy#

We may update this Privacy Policy from time to time.

When material changes are made, we may notify you through:

• The application;
• Website;
• Email;
• SMS; or
• Other appropriate communication channels.

The updated version will include a revised “Last Updated” date.

18.Privacy complaints#

If you believe that your personal information has been handled unlawfully, you may first contact MeeGo Pay so that we can investigate and respond.

You may also have the right to raise a complaint with the relevant data-protection authority in Uganda.

The Personal Data Protection Office (PDPO) is the statutory data-protection authority in Uganda. Its published contact information includes info@pdpo.go.ug and its Kampala office at Padre Pio House, Plot 32 Lumumba Avenue.

By using MeeGo Pay, you acknowledge that you have read and understood this Privacy Policy.