Privacy Policy

Effective Date: 01.01.2022

This Privacy Policy explains how Penuel's Investment (T) Ltd ("we," "our," or "us") collects, uses, and protects your personal information when you use our Customer Relationship Management System (the "System"). We are committed to safeguarding your personal data and ensuring its privacy, security, and accuracy in compliance with Tanzanian data protection laws and relevant global standards.

1. Information We Collect

We collect personal information from clients, users, and members of the System to provide our services and enhance your experience. The types of personal data we collect include:

a) Personal Information

  • Name
  • Email address
  • Phone number
  • Postal address

b) Project Information

  • Project details and descriptions
  • Proposal data
  • Invoice records
  • Payment history

c) Payment Information

  • Payment details for services rendered (e.g., transaction ID, amount, payment method)
  • Mobile payment details (e.g., M-Pesa, Airtel Money, TIGO Pesa)
  • Payment details via bank transfers for international transactions

d) Communication Preferences

  • Preferences for receiving newsletters, updates, and marketing communications
  • Consent status for marketing communications

2. How We Use Your Information

The personal data we collect is used to manage your interactions with us, process payments and communicate with you regarding our services. Specifically, we use your information for the following purposes:

  • Client Management: To register clients, process proposals, track project status and send reminders for upcoming tasks or renewals.
  • Payment Processing: To collect and process payments for services rendered through various payment methods, including bank transfers for international transactions.
  • Communication: To send you newsletters, updates and other communications relevant to your projects or interactions.
  • Compliance: To comply with legal obligations related to financial reporting, anti-fraud and anti-money laundering laws in Tanzania and other jurisdictions.

3. Legal Basis for Processing

We process your personal data under the following legal bases:

  • Consent: Where applicable, we obtain your consent to process your personal data, such as when you subscribe to newsletters or provide feedback.
  • Contractual Necessity: We process your data to fulfill our obligations under service agreements with you, including managing projects and processing payments.
  • Legal Obligation: We process your data to comply with applicable laws, such as financial reporting and tax obligations.

4. Data Sharing and Disclosure

We do not sell, rent, or share your personal data with third parties for marketing purposes. However, we may share your personal data with the following entities:

a) Service Providers

  • We may share your personal data with third-party service providers (e.g., payment processors like M-Pesa, Airtel Money, TIGO Pesa, and banks) who assist us in processing payments, sending communications or hosting our System. These service providers are bound by confidentiality agreements and are required to comply with data protection laws.

b) Legal Compliance

  • We may disclose your personal data to government authorities or regulatory bodies if required to comply with legal obligations, such as financial reporting, anti-money laundering regulations, or fraud investigations.

5. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected or to comply with legal obligations. Specifically:

  • Project Information: We retain project-related data as long as there is an active contract or agreement with the client. If a project is terminated, we will continue to store relevant data securely for future reference and potential reuse with the same client, unless otherwise requested by the client. This practice ensures continuity and enhances our ability to provide informed service in future engagements.

  • Payment Records: We maintain comprehensive records of all payment transactions for our internal financial auditing purposes. Payment records are stored securely on our servers and are not subject to deletion. This retention policy is in place to comply with legal and regulatory requirements, as well as to facilitate financial reporting and accountability.

Once the retention period has expired for project information (when no longer needed for future reference or contractual obligations), your personal data will be securely deleted or anonymized. All retained data is handled in accordance with our data security protocols to ensure confidentiality and protection against unauthorized access.

6. Data Security

We take the security of your personal data seriously and have implemented comprehensive technical and organizational measures to protect it from unauthorized access, loss, or misuse. These measures include:

  • Encryption: All sensitive data, such as payment information, is encrypted both in transit and at rest.
  • Access Controls: Only authorized personnel have access to your personal data, with access restricted based on role and necessity.
  • Two-Factor Authentication: Where applicable, we implement two-factor authentication (2FA) to add an extra layer of security to your account.
  • Regular Audits: We conduct regular security audits and risk assessments to ensure our systems and processes are secure.

However, no system is completely secure, and we cannot guarantee the absolute security of your personal data. You are responsible for keeping your login credentials confidential.

7. Your Data Protection Rights

You have certain rights regarding your personal data under Tanzanian law and global data protection standards. These rights include:

a) Right to Access

  • You have the right to request a copy of the personal data we hold about you and to know how we are processing it.

b) Right to Rectification

  • You have the right to request corrections to any inaccuracies in your personal data.

c) Right to Erasure

  • You may request the deletion of your personal data if it is no longer necessary for the purposes for which it was collected, or if you withdraw your consent (where applicable).

d) Right to Restrict Processing

  • You can request that we limit the processing of your personal data in certain circumstances, such as when you contest its accuracy.

e) Right to Object

  • You have the right to object to the processing of your personal data for direct marketing purposes.

f) Right to Withdraw Consent

  • You can withdraw your consent to receive newsletters, marketing communications, or other services at any time by unsubscribing or contacting us.

8. International Data Transfers

As part of our operations, personal data may be transferred internationally, particularly for payments processed through bank transfers. We ensure that appropriate safeguards are in place to protect your personal data during international transfers, in compliance with Tanzanian and international data protection regulations.

9. Cookies and Tracking Technologies

We may use cookies and similar tracking technologies to improve your experience on the System. Cookies are small data files stored on your device to help us recognize you when you return and provide a more personalized experience.

  • Types of Cookies: We use session cookies (which expire when you close your browser) and persistent cookies (which remain on your device until you delete them).
  • Managing Cookies: You can manage your cookie preferences through your browser settings, where you can block or delete cookies. However, disabling cookies may affect the functionality of the System.

10. Third-Party Links

The System may contain links to third-party websites or services, such as payment processors. We are not responsible for the privacy practices or content of these third-party websites. Please review their privacy policies before providing them with any personal information.

11. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. When we make changes, we will notify you by posting the updated Privacy Policy on the System or by sending you an email. Your continued use of the System after the changes have been made constitutes your acceptance of the updated Privacy Policy.

12. Contact Us

If you have any questions, concerns, or requests regarding your personal data or this Privacy Policy, please contact us at: