Nassham Pay Privacy Policy

Nassham Pay is a marketplace platform operated by:

For purposes of this Privacy Policy, NASSHAM TECHNOLOGIES & COMPANY LIMITED is the entity responsible for operating and administering the Nassham Pay Platform, subject to applicable law.

Throughout this Privacy Policy:

• "Nassham Pay" means the marketplace platform, website, application, systems, features, and related services operated by NASSHAM TECHNOLOGIES & COMPANY LIMITED.
• "Nassham Technologies", "we", "us", or "our" means NASSHAM TECHNOLOGIES & COMPANY LIMITED.
• "User", "you", or "your" means any person who accesses or uses Nassham Pay.
• "Buyer" means a User who browses, orders, or purchases Products through the Platform.
• "Seller" means a User whose application to sell on the Platform has been approved by Nassham Pay.
• "Product" means goods listed for sale through the Platform.
• "Order" means a request submitted by a Buyer to purchase one or more Products.
• "Personal Data" or "Personal Information" means information relating to an identified or identifiable individual.
• "TradeTalk" means the communication and messaging functionality provided through Nassham Pay.
• "Platform" means the Nassham Pay website, application, marketplace, systems, features, and related services.
• "Payment Provider" means a third-party payment service provider used to process payments, including AzamPay where applicable.

We collect information that is reasonably necessary to create accounts, operate the marketplace, process transactions, provide services, maintain security, comply with applicable law, and improve the Platform.

The information we collect depends on how you use Nassham Pay.

2.1 Account Registration Information

When you register for a Nassham Pay account, we may collect:

• First name;
• Surname;
• Gender;
• Email address;
• WhatsApp-enabled telephone number;
• Country associated with your telephone number;
• Country calling code;
• Account authentication information;
• Account preferences;
• Account status; and
• Other information reasonably necessary to create and maintain your account.

Your WhatsApp-enabled telephone number and country calling code are used as part of our account login and authentication process.

Your email address may be used for account recovery if you lose access to your account, as well as for security and account-related communications.

2.2 Information You Provide Voluntarily

You may provide additional information when using particular Platform features, including:

• Profile information;
• Addresses;
• Delivery information;
• Store information;
• Business information;
• Product information;
• Reviews and ratings;
• Customer-support information;
• Communications with Sellers or Buyers;
• Images or files;
• Return or refund information; and
• Information submitted during disputes.

If you apply to become a Seller, we may collect additional information required to review, approve, administer, and operate your Seller account.

This may include:

• Business or store name;
• Business address;
• Business location;
• Business contact information;
• Business type;
• Business registration information where applicable;
• Tax or regulatory information where legally required;
• Seller profile information;
• Store information;
• Product information;
• Product images;
• Product prices;
• Stock information;
• Delivery and pickup information;
• Bank or payout information where applicable;
• Seller verification information;
• Documents submitted for verification; and
• Information relating to your Seller activities.

Nassham Pay may review Seller applications before approving or rejecting Seller access.

We may also review product listings before making them available on the marketplace.

Where a Seller application or Product listing is rejected, we may retain information concerning the application, listing, review, and decision for legitimate business, security, dispute-resolution, and legal purposes.

When Sellers create or manage Product listings, we may collect and process:

• Product names;
• Product descriptions;
• Product categories;
• Product types;
• Product images;
• Product prices;
• Stock information;
• Seller/store information;
• Delivery information;
• Pickup information;
• Product status;
• Product approval status; and
• Other information reasonably necessary to operate the marketplace.

Product information may be displayed publicly on the Platform so that Buyers can browse and purchase Products.

Sellers should not include unnecessary personal information in Product listings.

When a Buyer places an Order or a Seller receives an Order, we may collect and process information relating to the transaction, including:

• Order number;
• Buyer account information;
• Seller account information;
• Products ordered;
• Quantities;
• Prices;
• Order date and time;
• Order status;
• Delivery or pickup method;
• Delivery information;
• Delivery charges;
• Payment status;
• Refund information;
• Cancellation information;
• Return information;
• Dispute information; and
• Other information necessary to administer the Order.

This information enables Nassham Pay to facilitate and maintain records of transactions between Buyers and Sellers.

Where a Buyer selects delivery, we may process information necessary to facilitate fulfillment and delivery of the Order.

• Buyer name;
• Telephone number;
• Delivery location;
• Delivery instructions;
• Order details;
• Seller information;
• Delivery fee information; and
• Delivery status.

Where a Buyer selects pickup, we may process information necessary to identify and administer the pickup transaction.

Delivery or pickup information may be made available to the relevant Seller and, where applicable, a delivery or logistics provider.

Nassham Pay provides Nassham TradeTalk, an integrated communication system that allows Buyers and Sellers to communicate through the Platform.

TradeTalk may collect and process:

• Messages;
• Product-related conversations;
• Images and files sent through the chat system;
• Conversation participants;
• Dates and times;
• Message status;
• Related Order information; and
• Other information necessary to operate the communication service.

TradeTalk information may be used to:

• Enable Buyer-Seller communication;
• Facilitate transactions;
• Provide customer support;
• Investigate disputes;
• Investigate fraud or abuse;
• Enforce Platform policies;
• Protect users; and
• Comply with applicable law.

Transaction Communications

We strongly encourage Buyers and Sellers to conduct important transaction-related communications through Nassham TradeTalk.

Where a dispute arises, TradeTalk communications may assist Nassham Pay in understanding what was communicated or agreed between the parties.

If a Buyer and Seller move important transaction communications to WhatsApp, social media, telephone calls, SMS, email, or another external service, Nassham Pay may not have access to those communications.

As a result, Nassham Pay may be unable to independently verify external communications when investigating a dispute.

Nassham Pay may facilitate payments through third-party payment service providers, including AzamPay, where applicable.

Depending on the payment method, you may be redirected to or otherwise interact with a payment environment operated by the applicable Payment Provider.

Payment information is processed by the applicable Payment Provider in accordance with its own terms, privacy practices, and applicable law.

Nassham Pay may receive limited payment-related information necessary to:

• Confirm whether payment was successful;
• Update Order status;
• Confirm payment;
• Process refunds where applicable;
• Reconcile transactions;
• Prevent fraud;
• Resolve payment disputes; and
• Administer Seller payouts.

The specific information received by Nassham Pay may depend on the payment method and Payment Provider.

When you access or use Nassham Pay, certain technical information may automatically be collected.

• IP address;
• Browser type;
• Operating system;
• Device type;
• Device identifiers where applicable;
• Screen information;
• Language preferences;
• Time zone;
• Date and time of access;
• Referring pages;
• Pages and features accessed;
• Error logs;
• Security logs;
• Session information; and
• Other technical information generated through use of the Platform.

We may use this information to operate, secure, monitor, troubleshoot, and improve Nassham Pay.

Nassham Pay may use cookies and similar technologies to:

• Maintain login sessions;
• Keep users authenticated;
• Remember preferences;
• Improve Platform functionality;
• Protect accounts;
• Detect suspicious activity;
• Understand Platform usage;
• Improve performance; and
• Provide relevant features.

Some cookies may be essential for the Platform to function.

You may control certain cookies through your browser settings. Disabling required cookies may cause some Platform features to stop functioning properly.

Where applicable law requires consent for particular cookies or similar technologies, Nassham Pay will provide the appropriate notice and obtain consent where required.

11.1 Providing Platform Services

• Create and manage accounts;
• Authenticate Users;
• Operate Buyer accounts;
• Operate Seller accounts;
• Operate online stores;
• Display Products;
• Facilitate Orders;
• Facilitate delivery and pickup;
• Provide TradeTalk; and
• Provide customer support.

11.2 Processing Transactions

• Process Orders;
• Confirm payment status;
• Communicate Order information;
• Manage cancellations;
• Facilitate delivery;
• Process returns and refunds;
• Manage Seller payouts; and
• Maintain transaction records.

11.3 Security and Fraud Prevention

• Detect fraud;
• Prevent unauthorized access;
• Protect accounts;
• Investigate suspicious activity;
• Prevent abuse;
• Enforce Platform rules;
• Protect Users and the Platform; and
• Maintain system security.

11.4 Marketplace Administration

• Review Seller applications;
• Review Product listings;
• Approve or reject Product listings;
• Monitor marketplace activity;
• Investigate complaints;
• Administer disputes;
• Maintain marketplace quality; and
• Enforce Platform policies.

11.5 Communications

• Account notifications;
• Security notifications;
• Account recovery communications;
• Order updates;
• Delivery updates;
• Payment notifications;
• Seller notifications;
• Customer-support responses; and
• Other service-related communications.

11.6 Legal and Regulatory Compliance

• Comply with applicable laws;
• Respond to lawful requests;
• Meet regulatory obligations;
• Establish or defend legal claims;
• Investigate suspected unlawful activity; and
• Cooperate with competent authorities.

Depending on the circumstances and applicable law, Nassham Pay may process Personal Data on one or more lawful grounds, including:

• Performance of a contract or steps taken at your request before entering into a contract;
• Compliance with legal obligations;
• Your consent where consent is required;
• Legitimate interests where permitted by applicable law; and
• Other lawful grounds recognized under applicable law.

The applicable legal basis may depend on the type of Personal Data and the purpose of processing.

NASSHAM TECHNOLOGIES & COMPANY LIMITED does not sell Personal Data to third parties as a commercial product.

However, we may disclose or make Personal Data available where reasonably necessary to operate Nassham Pay, fulfill transactions, provide services, protect Users, resolve disputes, prevent fraud, or comply with applicable law.

13.1 Sellers

Where necessary to fulfill an Order, the relevant Seller may receive information such as:

• Buyer name;
• Contact information;
• Delivery information;
• Order details; and
• Other information reasonably necessary to fulfill the transaction.

13.2 Buyers

Where necessary to complete a transaction, Buyers may receive relevant Seller or store information, including:

• Seller/store name;
• Product information;
• Order information;
• Fulfillment information; and
• Other information necessary for the transaction.

13.3 Payment Providers

We may share information necessary to facilitate:

• Payments;
• Payment confirmation;
• Refunds;
• Reconciliation;
• Fraud prevention; and
• Related payment services.

13.4 Delivery and Logistics Providers

Where applicable, information necessary to deliver an Order may be shared with the relevant delivery or logistics provider.

13.5 Technology and Service Providers

We may use third-party providers for:

• Hosting;
• Cloud infrastructure;
• Security;
• Communications;
• Email;
• WhatsApp or messaging services;
• Analytics;
• Database services;
• Customer support;
• Payment processing;
• Technical maintenance; and
• Other services necessary to operate Nassham Pay.

13.6 Authorities

We may disclose Personal Data where required or permitted by law, court order, regulatory requirement, or lawful request from a competent authority.

Nassham Pay seeks to collect Personal Data that is adequate, relevant, and reasonably necessary for the purposes for which it is processed.

We do not intend to collect Personal Data merely because it is available.

Where information is not reasonably necessary for a particular service, we seek to avoid unnecessarily requesting it.

You are responsible for ensuring that information you provide to Nassham Pay is accurate and current.

You should update your account information when it changes.

If you believe Personal Data held by Nassham Pay is inaccurate or incomplete, you may contact us and request correction where applicable.

Nassham Pay takes reasonable technical and organizational measures designed to protect Personal Data against:

• Unauthorized access;
• Unauthorized disclosure;
• Loss;
• Destruction;
• Alteration;
• Misuse; and
• Other unlawful or unauthorized processing.

Security measures may include:

• Access controls;
• Authentication mechanisms;
• Session security;
• Password protection;
• Secure transmission where appropriate;
• System monitoring;
• Logging;
• Database security;
• Restricted access;
• Security procedures; and
• Other appropriate technical and organizational measures.

However, no internet-based system can be guaranteed to be completely secure.

You are responsible for protecting your account credentials and should notify us promptly if you suspect unauthorized access.

Nassham Pay uses the registered WhatsApp-enabled telephone number , together with the applicable country code, as part of the account login and authentication process.

The registered email address may be used for:

• Account recovery;
• Lost-account recovery;
• Security notifications; and
• Other account-related communications.

You are responsible for maintaining access to the telephone number and email address associated with your account.

If you lose access to your registered telephone number and email address, Nassham Pay may require additional information to verify your identity before allowing account recovery.

We may refuse an account-recovery request where we cannot reasonably establish that the requester is authorized to access the account.

Nassham Pay may send communications necessary to operate your account and Orders.

Where permitted by applicable law, we may also send promotional communications regarding:

• Products;
• Sellers;
• Marketplace offers;
• Promotions;
• Services; and
• Other Nassham Pay activities.

Where consent is required, we will obtain appropriate consent.

You may opt out of promotional communications using the available unsubscribe mechanism or account settings.

Opting out of marketing communications will not necessarily stop essential service communications, including:

• Security alerts;
• Order notifications;
• Payment notifications;
• Account recovery messages; and
• Other necessary service communications.

Users may submit content through Nassham Pay, including:

• Product reviews;
• Ratings;
• Photographs;
• Comments;
• Product descriptions;
• Messages;
• Seller information; and
• Other content.

Some User Content may be displayed publicly or made available to other Users where necessary to operate the marketplace.

Users should avoid submitting unnecessary Personal Data in public reviews, Product listings, or other publicly visible areas.

Users must not submit another person's Personal Data without appropriate authorization or lawful basis.

Reviews and ratings may be associated with your account and transaction activity.

Nassham Pay may process reviews and ratings to:

• Display marketplace feedback;
• Improve marketplace quality;
• Detect fraudulent reviews;
• Investigate complaints;
• Prevent rating manipulation; and
• Maintain marketplace trust.

Nassham Pay may remove or restrict reviews that violate Platform policies or applicable law.

Sellers may receive certain Buyer information only where reasonably necessary to fulfill an Order or provide marketplace services.

A Seller must not:

• Use Buyer information for unrelated purposes;
• Sell Buyer information;
• Disclose Buyer information to unauthorized persons;
• Use Buyer information for spam;
• Use Buyer information for harassment;
• Retain Buyer information unnecessarily;
• Use Buyer information outside the purposes permitted by Nassham Pay and applicable law.

Sellers are responsible for handling Buyer information appropriately and complying with applicable data-protection obligations.

Nassham Pay may integrate with third-party services, including:

• Payment services;
• Hosting services;
• Communication services;
• Analytics services;
• Delivery services;
• Authentication services;
• Security services; and
• Other technology services.

These third parties may process Personal Data according to their own privacy policies and applicable legal requirements.

For example, payments may be processed through AzamPay where applicable.

Nassham Pay does not control the independent privacy practices of third-party service providers.

The Platform may contain links to websites, applications, or services operated by third parties.

A third-party link does not mean that Nassham Pay endorses or controls that third party.

Once you leave the Platform, the third party's privacy policy and terms may apply.

We encourage you to review the applicable third party's privacy policy before providing Personal Data.

Nassham Pay retains Personal Data only for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer period is required or permitted by applicable law.

Retention periods may depend on:

• Type of information;
• Purpose of processing;
• Nature of the relationship with the User;
• Transaction requirements;
• Accounting requirements;
• Financial requirements;
• Dispute-resolution requirements;
• Fraud-prevention requirements;
• Security requirements;
• Legal obligations; and
• Applicable limitation periods.

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

Nassham Pay may use service providers or infrastructure located outside Tanzania.

Where Personal Data is transferred outside Tanzania, Nassham Pay will take reasonable steps to comply with applicable legal requirements relating to cross-border transfers and appropriate safeguards.

Such transfers may be necessary when using:

• Cloud hosting;
• Payment services;
• Communication services;
• Security services;
• Email services;
• Technical infrastructure; or
• Other third-party services necessary to operate the Platform.

Subject to applicable law and any lawful limitations, you may have rights relating to your Personal Data, including rights to:

• Receive information about processing;
• Access Personal Data;
• Request correction of inaccurate Personal Data;
• Request deletion or erasure where applicable;
• Request restriction of processing where applicable;
• Object to certain processing;
• Withdraw consent where processing is based on consent;
• Request data portability where applicable;
• Object to certain direct marketing;
• Raise concerns regarding applicable automated decision-making;
• Lodge a complaint concerning the processing of Personal Data; and
• Exercise other rights available under applicable law.

These rights may be subject to legal exceptions, limitations, verification requirements, and legitimate retention requirements.

To request access, correction, deletion, restriction, objection, or other assistance relating to your Personal Data, contact:

To protect your account and Personal Data, we may need to verify your identity before processing certain requests.

We will handle requests in accordance with applicable law.

You may request deletion of your Nassham Pay account, subject to applicable law and legitimate retention requirements.

Deleting an account may not immediately result in deletion of every record associated with the account.

Nassham Pay may need to retain certain information relating to:

• Completed Orders;
• Financial records;
• Payments;
• Refunds;
• Disputes;
• Fraud prevention;
• Security;
• Legal obligations;
• Regulatory requirements; or
• Enforcement of contractual rights.

Where information must be retained, we will retain it only for the applicable legitimate purpose and period.

Nassham Pay is not intended for persons who are legally unable to enter into transactions under applicable law.

We do not knowingly collect Personal Data from children where such collection is prohibited by applicable law.

If you believe that a child has provided Personal Data to Nassham Pay without appropriate authorization, please contact us.

We will investigate and take appropriate action where required.

If Nassham Pay becomes aware of a Personal Data breach or security incident affecting Personal Data, we will assess and respond to the incident in accordance with applicable law.

Where notification is legally required, we will notify the relevant authority and/or affected individuals within the applicable timeframe and in the manner required by law.

Nassham TradeTalk is intended to provide a Platform-based communication channel between Buyers and Sellers.

TradeTalk messages may be accessed by authorized Nassham Pay personnel where reasonably necessary for:

• Customer support;
• Dispute resolution;
• Fraud investigation;
• Safety and security;
• Technical troubleshooting;
• Enforcement of Platform policies; or
• Compliance with applicable law.

Nassham Pay does not access TradeTalk conversations for unrelated purposes merely because the communication is technically available to the Platform.

Nassham Pay may monitor Platform activity to identify, prevent, investigate, and respond to:

• Fraud;
• Account takeover;
• Payment abuse;
• Fake accounts;
• Suspicious transactions;
• Review manipulation;
• Unauthorized access;
• Prohibited activities;
• Harassment;
• Scams; and
• Other activities that may harm Users or the Platform.

Such processing may be necessary to protect Users, maintain Platform security, and comply with applicable law.

Nassham Pay may use automated systems to assist with:

• Fraud detection;
• Security monitoring;
• Product moderation;
• Spam detection;
• Account security;
• Search;
• Product recommendations;
• Platform performance; and
• Other marketplace functions.

Where applicable law provides rights concerning solely automated decision-making that produces legally significant or similarly significant effects, you may exercise those rights in accordance with applicable law.

Certain information provided by Sellers is intended to be publicly displayed as part of the marketplace.

This may include:

• Store name;
• Business name;
• Store logo;
• Product information;
• Product prices;
• Store information;
• Business location information displayed by the Platform; and
• Other information designated as public.

Sellers should not submit unnecessary personal information that they do not want publicly displayed.

Nassham Pay may associate information relating to Buyers, Sellers, Products, Orders, payments, delivery, pickup, communications, returns, refunds, and disputes in order to operate the marketplace.

This information may be used to:

• Maintain transaction records;
• Process Orders;
• Track Order status;
• Facilitate delivery or pickup;
• Process returns and refunds;
• Investigate disputes;
• Prevent fraud;
• Provide customer support; and
• Comply with applicable law.

Nassham Pay may update this Privacy Policy from time to time to reflect:

• Changes to the Platform;
• Changes to our data practices;
• Changes in technology;
• Changes in applicable law;
• Regulatory requirements;
• Security developments; or
• Other legitimate business requirements.

When we update this Privacy Policy, we will update the Last Updated date shown at the beginning of this document.

Where required by applicable law, we will provide additional notice or obtain consent for material changes.

Your continued use of Nassham Pay after an updated Privacy Policy becomes effective constitutes acknowledgment of the updated Policy to the extent permitted by applicable law.

This Privacy Policy shall be interpreted and applied in accordance with the applicable laws of the United Republic of Tanzania , including applicable personal-data protection legislation and regulations.

Nothing in this Privacy Policy is intended to exclude, restrict, or limit any mandatory rights or protections available to you under applicable law.

If you have questions, concerns, requests, or complaints regarding this Privacy Policy or the processing of your Personal Data, you may contact us using the details below.

When contacting us about Personal Data, please provide sufficient information for us to understand your request.

We encourage you to contact NASSHAM TECHNOLOGIES & COMPANY LIMITED first so that we can investigate and attempt to resolve your privacy concern.

Privacy complaints may be submitted through:

Where applicable, you may also have the right to lodge a complaint with the relevant data-protection authority or seek other remedies available under the laws of the United Republic of Tanzania.

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