Privacy Policy & Data Notice

1. Introduction & Data Controller

This Privacy Policy applies to all merchants, till cashiers, developer integration partners, and customers interacting with PANO payment links, hosted checkout storefronts, e-ticketing scanners, and REST APIs.

The designated Data Controller responsible for your personal information is:

• Entity: PANO Technologies Limited
• Jurisdiction: Dar es Salaam, United Republic of Tanzania
• Compliance Office: Data Protection & Regulatory Compliance Unit

2. Personal Data We Collect

We collect only the information necessary to fulfill our statutory AML/CFT obligations, operate payment switches, and maintain a balanced financial ledger:

A. Merchant & Business Information (KYC Data)

• Identity Details: Full legal name, date of birth, nationality, and National Identification Number (NIDA NIN).
• Business Credentials: Taxpayer Identification Number (TRA TIN) certificate, BRELA Certificate of Incorporation, Business License, and MEMARTS.
• Contact Details: Business email address, telephone numbers, and physical business location address.
• Financial Payout Information: Commercial bank account details and verified mobile money settlement numbers.

B. Customer & Transaction Information

• Mobile Money Numbers (MSISDN): Customer phone numbers used to initiate M-Pesa, Airtel Money, Mixx by Yas, and Selcom Pesa prompts.
• Card Metadata: Masked PAN (e.g. 4111****9982), card brand, expiry, and 3D-Secure authentication tokens. Full cardholder CVV and primary account numbers are processed directly via PCI-DSS compliant vault tokenization and are never stored on PANO servers.
• Transaction Details: Amount, timestamp, unique payment reference, customer name, and itemized order descriptors.

3. Legal Basis for Processing

Under Section 27 of the Tanzania Personal Data Protection Act (PDPA 2022), we process personal data under the following lawful grounds:

• Performance of Contract: To process payments, execute settlements, and provide merchant dashboard functionality.
• Legal & Regulatory Compliance: To satisfy statutory record-keeping, anti-money laundering (AML), and Bank of Tanzania payment reporting rules.
• Legitimate Interests: To detect payment fraud, defend against chargeback disputes, and secure our network infrastructure.

4. How We Use Information

Your information is strictly utilized to:

• Route USSD payment prompts and card authorization requests via local mobile network operators and banking switches.
• Record balanced, immutable entries in the PANO double-entry general ledger.
• Execute automated daily or scheduled payouts to verified merchant bank accounts.
• Provide automated SMS customer receipts and downloadable PDF invoices.
• Run real-time anomaly detection and AML sanction screening.

5. Data Sharing & Disclosures

PANO does not sell, rent, or monetize your personal or commercial transaction data. Information is shared strictly with:

• Licensed Telecom Operators & Switches: Vodacom Tanzania, Airtel Tanzania, Yas Tanzania (Mixx), Halotel, and TIPS/TISS for payment clearance.
• Regulatory & Law Enforcement Authorities: The Bank of Tanzania (BOT), Financial Intelligence Unit (FIU), Tanzania Revenue Authority (TRA), and judicial bodies when required by formal legal subpoena.
• Authorized Merchant Staff: Cashiers and branch managers accessing transaction history restricted by their granular staff role permissions.

6. Ledger Security & Encryption Standards

PANO implements multi-layered security controls to protect information against unauthorized access, loss, or alteration:

• Encryption in Transit: All web traffic and API endpoints are protected using TLS 1.3 with modern cryptographic cipher suites.
• Encryption at Rest: Database records, KYC identity documents, and ledger journals are encrypted using industry-standard AES-256.
• HMAC Webhook Signatures: All outbound webhook event payloads are signed with HMAC-SHA256 to guarantee integrity.
• Access Governance: Staff access is restricted via PIN authentication, 2-Factor Authentication (2FA), and dual-control Maker-Checker protocols.

7. Retention of Financial Records

In accordance with the Anti-Money Laundering Act and Tanzanian financial regulatory mandates, all transactional records, customer identification documents, and general ledger journal entries must be retained for a minimum period of seven (7) years following the date of transaction or account closure.

8. Your Rights Under PDPA 2022

Subject to statutory financial record-keeping exemptions, you possess the following rights under Tanzanian law:

• Right to Access: Request a full copy of the personal data we hold regarding your merchant account.
• Right to Rectification: Update inaccurate KYC or business contact information via your merchant portal.
• Right to Object: Object to automated processing or non-mandatory communications.
• Right to Lodge a Complaint: File a formal grievance with the Personal Data Protection Commission (PDPC) of Tanzania if you believe your privacy rights have been infringed.

9. Cookies, Analytics & Webhook Security

PANO uses session cookies solely for authentication state maintenance and dark/light theme preference storage. We do not employ intrusive cross-site third-party tracking beacons.

10. Contacting Our Data Protection Officer

For inquiries regarding this Privacy Policy, KYC record updates, or to exercise your data subject rights, please contact our Data Protection Officer: