Privacy Policy

1. Introduction

TengaSale ("we", "us", "our") is committed to protecting the privacy of individuals who use the TengaSale platform, including customers who apply for device financing and merchants who operate through the platform. This Privacy Policy explains what personal information we collect, how we use it, and your rights in relation to it.

By using the TengaSale platform, you agree to the collection and use of your information as described in this policy. If you do not agree, you should not use the platform.

2. Information We Collect

From customers

• Identity information: Full name, National ID number, date of birth, and any other information provided during the KYC process.
• Contact information: Phone number, address, and any contact details provided during application.
• KYC documents: Copies of identity documents (National ID or equivalent) submitted as part of the application process.
• Contract information: Device details, contract number, financing terms, repayment schedule, and contract status.
• Payment records: Payment amounts, dates, provider references, and payment status for all transactions made under your contract.
• Device information: Device IMEI number, model, and status information where device management is enabled.

From merchants

• Business name, registration details, and contact information.
• Operational records including applications submitted, contracts created, and actions taken through the platform.
• Login and access records including timestamps and IP addresses.

Automatically collected

• Log data including IP addresses, browser type, pages visited, and timestamps when you access the platform.
• Device information relevant to the payment portal session (browser, operating system).

3. KYC and Identity Information

KYC (Know Your Customer) information is collected to verify your identity as required for financing operations. This includes your National ID number and copies of identity documents. KYC information is:

• Collected at the point of application by the merchant, on behalf of TengaSale;
• Stored securely and linked to your financing contract record;
• Used only for identity verification, contract management, and compliance purposes;
• Not shared with third parties except as described in this policy.

4. Transaction and Payment Records

All payment transactions processed through the platform are recorded. This includes the amount, date, provider reference, payment channel, and status of each transaction. These records are maintained for:

• Contract reconciliation and balance tracking;
• Proof of payment in the event of disputes;
• Audit and compliance purposes;
• Operational reporting and platform oversight.

5. How We Use Your Information

We use the information we collect for the following purposes:

• To process financing applications and make underwriting decisions;
• To create, manage, and track financing contracts;
• To process payments and reconcile contract balances;
• To verify your identity and comply with KYC obligations;
• To communicate with you about your contract, payments, or account status;
• To support merchants in managing their customer portfolio;
• To investigate disputes, fraud, or breach of contract;
• To maintain audit logs and comply with applicable laws and regulations;
• To operate, improve, and secure the platform.

6. Sharing of Information

We may share your information in the following circumstances:

• With merchants: Merchants who created your financing contract have access to your contract details and repayment status. This is necessary for them to support you and manage their portfolio.
• With payment providers: Your payment details are shared with the customer-facing mobile money network and authorised payment processors only as necessary to process your transaction.
• With device management providers: Where MDM or device locking services are enabled for your contract, relevant device and contract details may be shared with the applicable provider.
• For legal compliance: We may disclose information when required to do so by law, court order, or regulatory authority.
• In dispute resolution: We may share relevant records with legal or mediation bodies in the context of a dispute.

We do not sell or rent your personal information to third parties for marketing purposes.

7. Data Retention and Security

We retain personal and contract information for the duration of your contract and for a minimum of five (5) years following the completion or termination of the contract, or as otherwise required by applicable Malawi law or regulation.

We implement appropriate technical and organisational measures to protect your information against unauthorised access, alteration, disclosure, or destruction. These include:

• Encrypted storage and transmission of sensitive data;
• Role-based access controls limiting data access to authorised users only;
• Audit logging of all data access and modification events;
• Regular review of access permissions and security configurations.

No method of electronic storage or transmission is completely secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee absolute security.

8. Your Rights

You have the right to request access to the personal information we hold about you. You may also request correction of inaccurate information or, in certain circumstances, deletion of your data — subject to our legal and contractual obligations to retain records.

To make a data request, contact us at support@tenga.africa. We will respond to requests within a reasonable timeframe.

9. Cookies and Tracking

The TengaSale platform may use session cookies to maintain your login state and manage platform functionality. We do not use cookies for third-party advertising or tracking. The payment portal does not cache sensitive contract data in the browser.

10. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be published on this page with an updated date. Your continued use of the platform after changes are posted constitutes your acceptance of the revised policy.

11. Contact Information

For privacy-related queries, contact TengaSale at:
support@tenga.africa