This Privacy Policy describes how Thuma Mina Pay (a product of Mdiga Dynamics, hereafter "we", "us", or "our") collects, uses, and discloses your information when you use our WhatsApp-based payment service (the "Service").
Your privacy is critically important to us. We are committed to protecting your personal information and your right to privacy in compliance with South Africa's Protection of Personal Information Act (POPIA), Act 4 of 2013.
1. Information We Collect
To provide our Service, we collect the following personal information directly from you via WhatsApp:
- Full Name: We may receive your full name from the client whose service you are paying for, in order to verify your account. We do not ask you for it directly.
- Cellphone Number: Your WhatsApp number is collected automatically when you message us.
- Client Account Number: The unique identifier for your account with the company you wish to pay (e.g., your DSTV account number).
- OTT Voucher PIN: The 16-digit PIN of the OTT voucher you purchase to make a payment.
We **do not** collect any sensitive personal information (Special Personal Information as defined by POPIA) such as your race, ethnic origin, religious beliefs, or health data.
2. How We Use Your Information
We use the information we collect for the following purposes:
- To Provide the Service: To process your payment request, which includes verifying your account with our client, redeeming your OTT voucher, and confirming the payment.
- To Communicate With You: To send you messages on WhatsApp related to your transaction, such as payment confirmations, error messages, and support responses.
- To Maintain Transaction Records: To keep a secure record of all transactions, including the flat R20 service fee charged, for accounting, support, and legal purposes.
- To Improve Our Service: To analyse usage patterns and identify which new services our users are requesting. All data used for analysis is anonymised.
3. How We Share Your Information
We only share your information with the following parties, and only as is strictly necessary to provide the Service:
- The Client You Are Paying: We share your account number with the client to verify your account details (e.g., account holder name and amount due).
- OTT Payments (Pty) Ltd: We share the OTT voucher PIN with OTT's official API to validate and redeem the voucher directly into our client's designated OTT Merchant account.
We never hold your funds. The value of the voucher is transferred directly from OTT to the client's merchant account. We are a technology provider that facilitates this connection.
We will **never** sell, rent, or share your personal information with any third-party marketers or data brokers.
4. Data Security
We have implemented appropriate technical and organisational security measures designed to protect the security of any personal information we process. This includes:
- Using encrypted connections (HTTPS) for all API calls.
- Storing sensitive information like API keys and database credentials in a secure, access-controlled environment.
- Restricting access to personal information to only those employees and contractors who need to know that information in order to operate, develop, or improve our Service.
However, please remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
5. Data Retention
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it.
6. Your Rights Under POPIA
As a South African data subject, you have the following rights:
- The right to be notified that your personal information is being collected.
- The right to access the personal information we hold about you.
- The right to request correction of inaccurate or incomplete information.
- The right to request deletion of your personal information.
- The right to object to the processing of your personal information.
- The right to lodge a complaint with the Information Regulator if you believe we have not complied with POPIA.
To exercise any of these rights, please contact us at info@thumamina.space.
7. Changes to This Privacy Policy
We may update this privacy policy from time to time. The updated version will be indicated by a "Last Updated" date and will be effective as soon as it is accessible. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.
8. Contact Us
If you have questions or comments about this policy, you may email us at info@thumamina.space or contact us by post at:
Mdiga Dynamics
[Your Company's Physical Address]
[City, Postal Code]
South Africa