Privacy Policy

1. Our role: controller and processor

Our role differs depending on the data:

• Controller. For information about the Merchant relationship itself — account registration, owner and staff identities, device registrations, licensing and entitlement records, billing, support correspondence, website analytics and security and anti-fraud telemetry — we act as controller and decide how it is processed.
• Processor. For Merchant Data you enter into the Service about your own customers, suppliers and employees, you are the controller and we act as processor, processing it only on your instructions and as described here. You are responsible for having a lawful basis, for providing notice to those individuals, and for honouring their rights.

Where required, a separate Data Processing Agreement including standard contractual clauses is available on request from privacy@masanchara.com.

2. Information we collect

• Account and identity: business name, owner and staff names, role, gender where you choose to provide it, email address, phone number, hashed PINs (we never store PINs in plain text).
• Subscription and billing: plan tier, entitlement history, invoices, payment status, billing country, partial payment-instrument details and transaction references received from our payment processors. We do not store full card numbers.
• Device and integrity data: device and install identifiers, device model and operating-system version, application version, registration and approval status, entitlement validation results, offline-lease state, signature and integrity-check outcomes, clock-drift indicators, and licence and revocation events.
• Usage and diagnostics: feature usage, screen and action events, crash reports, error logs, performance metrics.
• Merchant Data (as processor): sales, inventory, stock movements, ledger and journal entries, audit logs, and records of your customers, suppliers and staff, including names, contact details, credit terms and balances.
• Support and communications: tickets, messages, attachments and call notes.
• Website data: IP address, approximate location derived from it, browser and device characteristics, referring pages, and cookie identifiers.

We do not intentionally collect special-category data (such as health, biometric, racial, religious, political or trade-union information) or government identifiers, and you must not enter them into free-text fields. We do not knowingly collect data from children under 16, and the Service is not intended for them.

3. Why we process it, and our lawful bases

Where the GDPR, UK GDPR or an equivalent law applies, we rely on the following bases:

• Performance of a contract — to create and administer your Account, provide the Service, process subscriptions and entitlements, and deliver support.
• Legitimate interests — to secure the Service; to detect, investigate and prevent licence circumvention, tampering, fraud, abuse of trials and pricing, and unauthorised access; to maintain the integrity and evidential value of ledgers and audit logs; to analyse and improve the Service; and to enforce our Terms and legal rights. We have assessed these interests against your rights and interests, and a summary of that assessment is available on request.
• Legal obligation — to comply with tax, accounting, corporate, sanctions and law-enforcement requirements.
• Consent — for optional analytics and marketing communications, where required. You may withdraw consent at any time without affecting prior processing.
• Vital interests or public interest — only where necessary, for example to report a serious crime.

Anti-fraud and integrity processing described in clause 12 of the Terms is necessary for the provision of a licensed, audit-grade accounting product. If you object to it, we cannot provide the Service.

4. Automated decisions and enforcement

The Service applies automated rules that can restrict access — for example blocking a device whose licence cannot be validated, whose signature or hash chain fails verification, or whose system clock indicates manipulation, and flagging behaviour patterns as possible fraud.

These measures protect the integrity of the product and of your own records. Where a decision restricting your access is made solely by automated means and has a significant effect on you, you may request human review by contacting privacy@masanchara.com, explain your circumstances, and contest the outcome. We will review promptly and, where the restriction was mistaken, restore access.

Fraud indicators generated within your own installation about your own staff are Merchant Data: you are the controller, and you are responsible for how you use them, including any employment consequence and any obligation to inform or hear the individual concerned.

5. When we share information

We do not sell personal information, and we do not share it for cross-context behavioural advertising. We disclose it only as follows:

• Service providers and sub-processors — cloud hosting, database, error-monitoring, analytics, email, payment processing and customer-support providers, bound by written terms restricting their use to our instructions. A current list of sub-processors is available at PLACEHOLDER URL or on request.
• Payment processors — to take payment and manage subscriptions, chargebacks and refunds.
• Professional advisers — auditors, accountants, insurers and lawyers, under duties of confidentiality.
• Authorities — law enforcement, regulators and tax authorities where legally required, or where we consider disclosure necessary to investigate or report suspected tampering, fraud or other unlawful conduct, or to establish, exercise or defend legal claims.
• Corporate transactions — an acquirer or successor in a merger, acquisition, financing or sale of assets, subject to this Policy.
• With your direction — where you instruct an integration or export.

6. International transfers

We operate internationally and may process information in countries other than your own, including where our cloud providers host infrastructure. Those countries may not offer equivalent protection to your own.

Where we transfer personal data out of the European Economic Area, the United Kingdom or another jurisdiction requiring a transfer mechanism, we rely on an adequacy decision where available, or otherwise on the European Commission Standard Contractual Clauses, the UK International Data Transfer Addendum, or an equivalent lawful mechanism, together with supplementary technical and organisational measures. Copies are available on request.

7. How long we keep it

We keep personal information only as long as necessary for the purposes above, then delete or irreversibly anonymise it. Indicative periods:

• Account and Merchant relationship records — for the term of the relationship and up to 24 months afterwards.
• Billing, tax and accounting records — for the period required by applicable tax and company law, typically 5 to 7 years.
• Licensing, entitlement, device-integrity and anti-fraud records, and audit logs — up to 7 years, reflecting their evidential purpose in detecting and proving tampering and fraud, and any applicable limitation period.
• Support tickets — 36 months from closure.
• Diagnostics, crash and analytics data — up to 24 months.
• Merchant Data held by us as processor — for the term plus a wind-down period of up to 90 days, unless you instruct earlier deletion or law requires longer retention.

Records reasonably required for the establishment, exercise or defence of legal claims, or subject to a legal-hold or preservation obligation, may be retained until those matters conclude.

8. Security

We implement technical and organisational measures appropriate to the risk, including encryption of data in transit, hashing of PINs with per-device salting, role-based access control and least privilege, administrative audit logging, cryptographic hash chaining of ledger entries, tamper and clock-drift detection, secure development practices, dependency monitoring and access reviews.

No system is perfectly secure. You are responsible for the security of your own devices, credentials, staff practices and networks, and for maintaining independent backups.

Where a personal-data breach is likely to result in a risk to individuals, we will notify the competent supervisory authority without undue delay and, where feasible, within 72 hours of becoming aware, and will notify affected controllers and individuals as required by law.

9. Your rights

Subject to applicable law, you may have the right to: access your personal information; correct inaccurate information; delete it; restrict or object to processing, including to processing based on legitimate interests; receive it in a portable format; withdraw consent; and lodge a complaint with a supervisory authority.

Region-specific rights:

• EEA and UK (GDPR / UK GDPR) — the rights above, plus the right to complain to your national data-protection authority or the UK Information Commissioner's Office.
• California (CCPA/CPRA) — rights to know, delete, correct, and to limit use of sensitive personal information, and freedom from retaliation for exercising them. We do not sell or share personal information as those terms are defined.
• South Africa (POPIA) — rights of access, correction and deletion, and the right to complain to the Information Regulator.
• Zimbabwe (Cyber and Data Protection Act) — rights of access, correction and objection, and the right to complain to the Data Protection Authority.
• Kenya (Data Protection Act) and Nigeria (NDPA) — rights of access, rectification, erasure, objection and portability, and the right to complain to the respective Commission.
• Brazil (LGPD), Canada (PIPEDA), Australia (Privacy Act) and other jurisdictions — equivalent rights as provided by local law.

To exercise a right, contact privacy@masanchara.com. We will verify your identity and respond within the statutory period, normally one month. If your request concerns data we hold as processor for a Merchant, we will refer you to that Merchant, who is the controller.

10. Cookies and website analytics

Our websites use only strictly necessary cookies and similar storage, for example to keep you signed in to the administrative console and to remember your privacy choice. We do not use advertising or analytics cookies, so no cookie banner is shown. Our website analytics are cookieless; you can turn off optional measurement at any time with "Privacy settings" at the bottom of masanchara.com, and we treat a Global Privacy Control signal from your browser the same way. Blocking strictly necessary cookies may break the site.

The mobile application does not use advertising identifiers for advertising purposes and contains no third-party advertising SDKs.

11. Changes to this Policy

We may update this Policy. Where changes are material, we will notify you in the Service or by email before they take effect. The current version is always published at this URL with its "last updated" date.

12. Contact us

Privacy enquiries and rights requests: privacy@masanchara.com.

Security and vulnerability reports: security@masanchara.com.

Masanchara (Private) Limited, Zimbabwe. Registered office address: Contact Support for this information.

Data Protection Officer / EU-UK representative: TO BE APPOINTED IF REQUIRED.