Draft for review by qualified lawyers in each country where TeePay operates (starting with Tanzania) before publication. Items marked [TO CONFIRM] must be completed or checked before this page is published.
Effective date: [TO CONFIRM: effective date]
This Privacy Policy explains how [TO CONFIRM: company legal name] ("TeePay", "we", "us") collects, uses, shares and protects personal data when you use teepay.me and the TeePay Services. It applies to:
merchants: businesses and the people who open, own, manage or work on a TeePay account;
customers: people who pay a TeePay merchant through a payment page, payment link, hosted checkout, invoice or Control Number; and
visitors to our website.
We process personal data in line with the data protection laws that apply where we operate and where you are. In Tanzania, that is the Personal Data Protection Act, 2022 and its regulations. In this policy, "data protection law" means whichever of these laws applies to you. [TO CONFIRM: TeePay's registration with the data protection authority in each country where it operates (in Tanzania, the Personal Data Protection Commission) as a data controller and/or processor, and the registration number if issued.]
1. Who is responsible for your data
For merchant account data, verification data, security data and the payment records we must keep, TeePay is the data controller.
When a customer pays a merchant, the merchant decides what it sells and what extra information it asks for (for example custom questions on a payment page, or customer details on an invoice). The merchant is responsible for that information and for its own privacy notice. [TO CONFIRM: whether TeePay acts as controller or processor for customer data that merchants collect through TeePay.]
Contact: info@teepay.me, [TO CONFIRM: registered address]. [TO CONFIRM: name or contact of the data protection officer, if appointed.]
2. What we collect
Merchant account information
Name, email address, phone number and password. We store passwords only as a salted, one-way hash, never in readable form.
If you sign in with Google, the basic profile information Google shares with us, such as your name and email address.
Account settings, preferences, team members and their roles.
Verification (KYC and KYB) information
Identity: full name, date of birth, gender, residential address, occupation, identity document type and number (national ID, passport, driving licence or voter ID), and images or scans of the front and back of the document.
Business: business name, type, address, industry, website, description, Taxpayer Identification Number (TIN), and documents such as a TIN certificate, certificate of incorporation or business licence.
Our reviewers' decisions and the reasons for them.
Payment and payout information
For each payment: the amount, currency, mobile network or payment method, the customer's phone number or Control Number, references, status, time and the merchant it belongs to.
For payouts: the destination mobile money number or bank account details, the account name you give us, amounts, fees and status.
Your balance, transaction history, invoices, payment links, payment pages and receipts.
Customer information
When you pay a TeePay merchant we receive:
your mobile money phone number and network, which you enter so we can send the payment prompt to your phone;
the amount, what you are paying for, and the payment result;
any details the merchant asks you to provide, such as your name, email address, delivery address or answers to the merchant's questions; and
your email address or phone number if you ask for a receipt, ticket or download link.
We never receive or store your mobile money PIN. You enter it only on your own phone, in your network's prompt.
Merchant content
Payment pages, product details, images, logos, invoices and other content merchants publish or upload, and files they upload to the media library.
Security, device and network information
To keep accounts safe and prevent fraud, we record security events such as sign-ins, failed sign-ins, one-time code checks, password resets, verification steps and changes to important settings. With these events we record your IP address and the browser "user agent" (which describes your browser and operating system).
Our risk and security reviewers do not see your raw IP address or full user agent in their review screens. They see a privacy-preserving version: a coarse label for the browser and operating system family, and a keyed, one-way code derived from the network part of your IP address (not the full address). We use this to spot, for example, a sign-in from a new device or network compared with your own previous 90 days of activity. We do not use device fingerprinting and we do not work out your location from your IP address.
When you verify a new browser, we place a cookie on it so we can recognise it as trusted for up to 30 days (see our Cookie Policy).
Website and payment page usage
When someone views a merchant's payment page, we record a view count for that merchant using a random identifier kept only for the browser session, the referring website, the device type and the browser family. We do not use this to identify individuals.
Our servers keep standard technical logs needed to run and secure the Services.
We do not use third-party advertising or analytics cookies on teepay.me.
Communications
Messages you send us, support requests, appeals, and records of emails and SMS messages we send you (for example one-time codes, receipts and account notices).
3. Why we use your data, and our legal basis
Providing the Services: creating your account, processing payments and payouts, sending receipts, showing your history. Legal basis: performance of our contract with you, or steps you ask us to take.
Verifying identity and businesses: KYC and KYB checks and document review. Legal basis: legal obligation (including anti-money laundering law) and our contract.
Preventing fraud and keeping accounts secure: sign-in checks, new-browser verification, extra verification for payouts, risk reviews of payments, payouts and sign-in activity, and review of merchant content. Legal basis: legal obligation and our legitimate interest in protecting customers, merchants and TeePay.
Meeting legal and regulatory obligations: keeping transaction records, responding to lawful requests from regulators, courts and law enforcement, and reporting suspicious transactions where required. Legal basis: legal obligation.
Enforcing our terms: content review, holds, restrictions and appeals. Legal basis: our contract and legitimate interests.
Customer support: answering questions and investigating payment problems. Legal basis: our contract and legitimate interests.
Improving the Services: understanding how features are used and fixing errors. Legal basis: legitimate interests.
Service and marketing messages: account notices and product announcements to merchants. Legal basis: our contract for service messages; legitimate interests or consent, where required, for marketing. You can opt out of marketing at any time.
[TO CONFIRM: legal bases match the wording of data protection law and its regulations.]
Automated checks
We use automated checks to flag possible fraud and possible breaches of our Acceptable Use Policy, such as unusual payment patterns, repeated failed sign-ins, or flagged words in merchant content. These checks only bring items to the attention of our staff. Decisions that significantly affect you, such as rejecting verification, restricting content or an account, or holding funds, are made by a person. You can ask for a person to review any decision and can appeal as described in our Terms of Service.
4. Who we share data with
We do not sell personal data. We share it only as needed for the purposes above, with:
Payment Providers: mobile network operators (such as M-Pesa, Airtel Money, Mixx by Yas and HaloPesa), payment service providers, aggregators and banks that carry payments, Control Numbers and payouts. They receive the details needed to process each transaction, such as the phone number, amount and reference. [TO CONFIRM: list of payment partners currently used in live.]
Merchants: when you pay a merchant, they see the payment details and any information you gave them through their page or invoice, so they can deliver what you bought.
Service providers who help us run TeePay, under contracts that require them to protect the data and use it only on our instructions, including hosting and cloud storage, email delivery, SMS delivery and sign-in with Google. [TO CONFIRM: named list of hosting, storage, email and SMS providers.]
Regulators, courts and law enforcement in the countries where we operate (in Tanzania, for example, the Bank of Tanzania, the Financial Intelligence Unit, the Personal Data Protection Commission, the Tanzania Revenue Authority and the police), where the law requires it or a lawful request is made.
Professional advisers, such as lawyers, auditors and insurers.
A buyer or successor if TeePay's business is sold or reorganised, subject to this policy.
5. Transfers to other countries
Some of our service providers may store or process data outside the country where it was collected. [TO CONFIRM: where TeePay's servers and backups are hosted, and which providers process data in which countries.] When we transfer personal data to another country, we do so only as permitted by data protection law, for example where the receiving country or organisation provides adequate protection, with appropriate contractual safeguards, or with your consent where required.
6. How long we keep data
We keep personal data only as long as we need it for the purposes in this policy, including to meet legal, regulatory, tax and accounting requirements and to resolve disputes.
Transaction, payout and verification records are kept for at least the period required by anti-money laundering and payment systems laws after the transaction or the end of our relationship with you. [TO CONFIRM: retention period, for example the statutory minimum under the AML framework.]
Account information is kept while your account is open and afterwards for as long as needed for the records above. [TO CONFIRM: retention period after account closure.]
Security event records are kept for [TO CONFIRM: security log retention period]. Our sign-in reviews compare activity with the previous 90 days.
Merchant content is kept while your account is open. Content we restrict for policy reasons is kept, not deleted, so that the decision can be reviewed and reversed.
Payment page view records are kept for [TO CONFIRM: page analytics retention period].
When we no longer need data, we delete it or make it anonymous.
7. How we protect your data
We use technical and organisational measures appropriate to the risk, including:
encryption of sensitive records we store, including identity document numbers, payout destinations, invoices, and secrets such as API signing keys;
passwords stored only as salted, one-way hashes;
verification documents and other uploads kept in private storage that is not publicly reachable, checked for malware before use, and opened by staff only through access-controlled routes that record who opened what;
one-time codes, new-browser verification, and an extra verification step before payouts and other sensitive actions;
access for TeePay staff limited by role and permission, with administrative actions recorded in audit logs;
approval by a second member of staff before certain decisions, such as restricting merchant content or correcting financial records;
signed webhooks, so merchants can check that messages came from TeePay; and
masking of phone numbers in logs for agent-initiated payment prompts.
No system is completely secure. If a personal data breach is likely to put your rights at risk, we will notify the relevant data protection authority (in Tanzania, the Personal Data Protection Commission) and, where required, you, as data protection law requires.
8. Your rights
Under data protection law you have rights over your personal data. Subject to the conditions and exceptions in the law, you can ask us to:
tell you whether we hold personal data about you and give you a copy;
correct data that is inaccurate or incomplete;
delete data we no longer have a reason to keep. We may need to keep some records, such as transaction and verification records, because the law requires it;
stop or limit processing, or object to processing based on our legitimate interests;
stop using your data for direct marketing;
have a person review a decision made by automated means that significantly affects you; and
withdraw consent where we rely on consent. This does not affect processing already carried out.
To make a request, email info@teepay.me. We may need to confirm your identity first. We will respond within the time data protection law requires [TO CONFIRM: response period under the regulations].
If you paid a merchant and want to access or change information you gave that merchant, you can also contact the merchant directly.
If you are not satisfied with our response, you can complain to the data protection authority in your country (in Tanzania, the Personal Data Protection Commission).
9. Children
TeePay merchant accounts are only for people aged 18 or over. We do not knowingly collect personal data from children to open accounts.
10. Cookies
We use a small number of cookies and similar browser storage that are needed to sign you in, keep your account secure and remember your preferences. We do not use advertising or third-party analytics cookies. See our Cookie Policy for details.
11. Changes to this policy
We may update this policy from time to time. We will show the date of the latest version at the top of this page and tell merchants about material changes by email or in the dashboard.
12. Contact
[TO CONFIRM: company legal name]
[TO CONFIRM: registered address]
Email: info@teepay.me