Stella Pay Limited (“us”, “we”, or “our”) is a is an online platform that offers it s customers an all-in-one digital payments platform where they can perform numerous transactions used to offer financial services. We operate the www.stellapay.africa website, which provides more information of us and our various services / facilities as well as the Stella Pay Mobile application (the “Service”).
As an organization, we take our responsibility regarding the management of our stakeholders’ data very seriously. This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Services sets out how we manage our responsibility in the use of your data and the choices you have associated with that data.
We use your data to provide and improve the Services. By using these Services, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Data Privacy Policy, terms used in this Data Privacy Policy have the same meanings as in our Terms and Conditions.
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.
As Stella Pay we shall be requesting the following access from mobile app users;
1. Phone contacts (for their convenience in uploading contacts).
2. Messages (for the sole purpose of automatically reading OTP).
3. Reading Sim Card information (for security purposes, to ensure the phone number on the phone is the same as the one being registered).
We collect several different types of information for various purposes in order to provide and improve our Service to you including Names, I.D./Passport Number, Date of Birth, Gender, Details, Postal Address, Telephone Number. Some of the purposes for which we collect and process your data includes:
• To provide and maintain our Service.
• To notify you about changes to our Service
• To allow you to participate in interactive features of our Service when you choose to do so.
• To provide member support
• To gather analysis or valuable information so that we can improve our Service.
• To monitor the usage of our Service
• To detect, prevent and address technical issues.
• To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
Stella Pay Limited may disclose your Personal Data in the good faith belief that such action is necessary to:
•To comply with a legal obligation
• To protect and defend the rights or property of Stella Pay Limited.
• To prevent or investigate possible wrongdoing in connection with the Service.
•To protect the personal safety of users of the Service or the public
• To protect against legal liability
Stella Pay Limited will retain your Personal Data only for as long as is necessary for the purposes set out in this Data Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
Personal data that we collect about End Users
•Paying Stella Pay. If you are buying goods or services directly from Stella Pay, we receive Transaction Data. For example, when you make a payment to Stella Pay we will collect contact information, payment method information, information about that transaction.
•Other Services. We may offer other End User Services directly to you from time to time, including certain financial Services.
How we use and share personal data of End Users
• Services. We use your Personal Data to provide the End User Service to you, including security, delivery, support, personalization and messages related to the End User Service (e.g. communicating Policy updates and information about our Services). We also use your Personal Data for our fraud detection and mitigation Business Services and may share certain Personal Data as part of those Business Services with Business Users that you may seek to do business with. The use of this Personal Data is subject to the Business Users’ privacy policies.
• Transactions. For payment transactions with Stella Pay, End User Personal Data is shared with others to enable the transaction. For example, when you choose to use a payment method for the transaction with Stella Pay, that payment method will receive transaction information that includes your Personal Data. Please review your payment method’s privacy policy to learn more. When you use Stella Pay, the merchant you choose to do business with will also receive Transaction Data that includes your Personal Data. The merchant may share that Personal Data with others.
• Fraud Detection Services. We use your Personal Data collected across our Services (e.g. Stella Pay ) to detect and prevent fraud against us, and financial partners, including to detect unauthorized log-ins using your online activity. You can learn more about how we may use technology to assess the fraud risk associated with an attempted transaction.
• Advertising. We may use your Personal Data to assess your eligibility for and offer you other End User Services. With your permission or were allowed by law, we use and share End User Personal Data with others so that we may market our products and services to you, including through interest-based advertising where allowed by applicable law, including subject to any consent requirements. We do not share End User Personal Data with third parties for their marketing or advertising unless you give us or the third-party permission to do so. We do not sell the data of End Users.
End Customers
Stella Pay offers Business Services to our users and for this we will process Personal Data in accordance with the terms of our agreement with the Business User and the Business User’s lawful instructions. For example, we process payment transactions for a Business User because you bought a product from them through our platform. Business Users are responsible for making sure that their End Customer’s privacy rights are respected, including ensuring appropriate disclosures about data collection and use that happens in connection with their services. If you are an End Customer, please refer to the privacy policy or notice of the Business User for information regarding the Business User’s privacy practices, choices and controls, or contact the Business User directly.
a. Personal data that we collect about End Customers
• Transaction Data. If you are an End Customer, when you make payments to, get refunds from, begin a purchase, make a donation or otherwise transact within our platform, we will receive transaction data. The “Transaction Data” that we collect includes Personal Data, and may include the following: your name, payment method information (such as M-Pesa name ), purchase amount, date of purchase, and in some cases, and your phone number. We may also receive your transaction history with the Business User. We may collect information typed into a checkout form, even if you choose not to complete the form or purchase with the Business User.
• Identity/Verification Information. Stella Pay provides a verification and fraud Service that allows us to verify Personal Data about you, such as your name or your authorization to use a payment method. You will be asked to share Personal Data and we will collect the information that you share for this purpose, such as your government ID, your image, and Personal Data you input or that is apparent from the physical payment method (e.g. M-Pesa name). We may compare this information with information about you we collect from IPRS, financial partners, business partners, identity verification services, publicly available sources, and third-party service providers.
Please see below for information about additional types of Personal Data that we may collect, including about online activity.
b.How we use and share personal data of End Customers
We generally use Personal Data of End Customers for Stella Pay’s own purposes to secure, improve and provide our Business Services, as described below.
• Payments. We use your Transaction Data to provide our Payments related Business Services, including to processing payment transactions, to calculate applicable sales tax, to invoice and bill, and to calculate their revenue. We may also use Personal Data to provide and improve our Business Services.
◦ For payment transactions, your Personal Data is shared with a number of parties in connection with your transaction. As we processes the payment, we share Personal Data to enable the transaction. For example, when you choose to use a third party payment method for the transaction (e.g. M-Pesa), your payment method will receive the Transaction Data that includes your Personal Data. Please review your payment method’s privacy policy to learn more about how they use and share this information.
◦ The merchant you choose to do business with will also receive Transaction Data that includes your Personal Data and the merchant may share that Personal Data with others. Please review your merchant’s privacy policy to learn more.
•Identity/Verification Services. We use Personal Data about your identity, including information provided by you and our service providers, to perform verification Services for Stella Pay or for the Business Users that you are doing business with and to reduce fraud and enhance security. If you provide a “selfie” along with an image of your identity document, we will use technology to compare and calculate whether they match and you can be verified.
• Advertising by Business Users. If you have begun a purchase, we share Personal Data with that Business User in connection with our provision of Services and that Business User may use your Personal Data to market and advertise their products or services. Please review your merchant’s privacy policy to learn more, including your rights to stop their use of your Personal Data for marketing purposes. We do not use or share End Customer Personal Data for our marketing or advertising, or for marketing and advertising by third parties who are not the Business User with which you have transacted or attempted to transact. We do not sell the data of End Customers.
As a Data Subject you have the following Rights as set out in the Data Protection Act No. 24 of 2019:
• The right to be informed of the use of your information/data.
• The right to access, update or to delete the information or data in our custody.
• The right of rectification. You have the right to have your information/data rectified or deleted if that information is misleading, inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your Personal Data.
• The right of restriction. You have the right to request that we restrict the processing of your personal information.
• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where Stella Pay Limited relied on your consent to process your personal information, without any detriment to your interests.
Please note that we may ask you to verify your identity and provide signed instructions before responding to such requests.
Stella Pay Limited may update our Data Privacy Policy from time to time. We will notify you of any changes by posting the new Data Privacy Policy on our website. We will let you know via email and / or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.
If you have any questions about this Data Privacy Policy, please contact us at info@stellapay.africa